CPSC Recognizes Redundancy in Testing Requirements for Lead Coatings

To its credit, the Consumer Protection Safety Commission staff has recognized a testing redundancy as applied to lead in surface coatings. A CPSC memo dated July 18, 2011, states:

Both section 4.3.5.2 of [ASTM] F 963-08 and 16 CFR part 1303, Ban of Lead-Containing Paint and Certain Consumer Products Bearing Lead Containing Paint, require no more than 90 parts per million (ppm) of lead in paint or similar surface coatings. The test conducted under section 4.3.5.2 of F 963-08 is a solubility test that measures how much lead is extracted from the paint or similar surface coating. The test conducted under 16 CFR part 1303 measures how much lead content is present in the paint or similar surface coating. You cannot extract more lead from paint or a similar surface coating than the amount contained in the paint/surface coating; therefore, a product that has satisfied the lead content test conducted under 16 CFR part 1303 will necessarily satisfy the lead solubility test conducted under section 4.3.5.2 of F 963-08.
Having reached this conclusion, CPSC staff recommends modifying the draft requirements notice to state that where a product has been tested by a CPSC-accepted third party conformity assessment body and found not to exceed the lead limit in 16 CFR part 1303 [lead content], the product does not need to be tested to the lead solubility [extraction] standard in section 4.3.5.2 of ASTM F 963-08.

You can find the CPSC memo by cutting and pasting this link http://www.cpsc.gov/library/foia/foia11/brief/astmF963mod.pdf into your internet browser.