Statement of Exemption from Testing for Phthalates, Lead,
and Mechanical Hazard under CPSIA 2008
See also Federal Rattle End-size Requirements
MY VERY OWN® Rattle - More Information, Place Order
MY VERY OWN RATTLE®
Cleaning, color, etc
MY VERY OWN® Rattle is
not subject to the mandatory requirements for testing for Lead and Phthalates
required by CPSIA2008, because the product to be used by a child is unfinished,
untreated, natural wood, unaltered from its natural state. This statement
has been confirmed by the CPSC Ombudsman, Will Cusey.
The following paragraphs regarding testing for chemical hazard were excerpted in 2008 from “Frequently Asked Questions” on the website of STR Testing Laboratories, a CPSC accredited laboratory. STR is now part of Underwriters Laboratories, Inc. These statements are essentially equivalent to the current CPSC language.
exemption for wood applies to both natural and treated wood. However, accessible
surface coatings on wood do require testing for lead.
“The CPSC’s Final Rule regarding lead content limits of certain materials or products exempts from lead testing include paper and similar materials made from wood. The exempted materials include, but are not limited to, paperboard and linerboard and coatings on such materials which become part of the substrate, provided that no materials have been added that could result in the introduction of lead in the product. Note that while these materials are exempt from testing, they still must comply with the lead limits.
has determined that certain natural materials do not typically exceed the lead
content limits and, while compliance is required, testing of these identified
materials is not. These natural materials include wood, precious gemstones
(diamond, ruby, sapphire, emerald) and certain semiprecious gemstones, natural
fibers, such as cotton, silk, and wool, and other natural materials such as
coral, amber, feathers, and fur.
“Are there any
materials that are exempt from phthalates testing?
For the complete text of
Regulation 16 Part 1510, visit
Full Regulatory Text of 16 CFR 1510
Below is the relevant excerpt regarding rattle end sizes allowed or banned by CPSC regulation 16 CFR (Code of Federal Regulations) Part 1510
Reducing this requirement to simple dimensions, a rattle end must be at
least 1 11/16" (1.688") in diameter. The actual combination of
largest diameter and shape will determine the compliance of the product with
this regulation, and for certainty it is best to use the test fixture.
We have seen some very attractive wooden rattles offered for sale, one end of which was a long, thin handle intended for grasping by the infant. This shape would almost certainly be non-compliant.