Q.2 RFC Component v. Unit and 3rd party testing

[Eric H]

The table of contents for all the questions in the RFC, including an explanation of what an RFC is can be found at [url=//fashion-incubator.com/phpbb/viewtopic.php?t=3534]Introduction and Table of contents: RFC Component vs unit and 3rd party testing[/url]

This section deals with the second question which is:

[Eric H]

It would be best to allow third-party testing of component parts if there was some assurance that downstream processes did not substitute or fundamentally alter the materials during assembly, and if there was some assurance that no non-tested components could enter the final product. In apparel, natural fiber (wools, cotton, silk) are going to be naturally phthalate and lead free. Skins (leather) may depend on the tanning processes [I don't know enough about it]. However, those are not the sole components used in apparel.

Natural fibers must be dyed and perhaps have other chemical treatments applied. Fusibles, hardware, and other components may be introduced to the material. The common examples of this are the rubberized feet on sleepers and waterproof backing on bibs. If all are tested, there should be no problem.

Again, there is differentiation along the lines of established manufacturers with controlled processes and new entrants with poorly controlled processes. Startup manufacturers are going to separate out into those who use cotton cloth, polyester thread, and fusibles and those who use t-shirt blanks and all manner of glues, hardware, and inks. It will be more sophisticated manufacturers who get into rubberized footies, etc. The sophisticated manufacturers and the startups using cotton cloth could probably be trusted to use component testing. It's the graphic t-shirt and others using art supplies and experimental treatments that would be most worrisome.

This also applies to [url=//fashion-incubator.com/phpbb/viewtopic.php?t=3543] 3.The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.[/url]

[Eric H]

Also, it is possible that third-party testing to some standards, e.g. Oeko-Tex and EU RoHS, may result in exceeding compliance requirements with a suitable safety margin. From what I read about Oeko-Tex, a safety threshold for lead is not given; lead is flat banned. Other chemicals are limited or banned, but phthalates do not seem to be among them at this time.

If these foreign standards are not compatible, CPSC should (1) study them to see how they map to US requirements, and (2) reach out to the governing boards of those other standards to encourage them to adopt US standards and vice versa.

[Kathleen F.]

[jennifer]

I agree - if the components that are third party test are the same that will go into the FINAL product then to me it seems like a no-brainer.

[Vesta]

Yep:

If the components tested are the final components.

If the construction process will not fundamentally alter the character of the components (like sewing two pieces of fabric together).

[Eric H]

I guess that means sewing and not soldering them together.