I continue to be concerned about the paints and other surface coatings that are marked "AP Non-Toxic / Conforms to ASTM D 4236" and are commonly used by individuals and small batch manufacturers as surface coatings for children's products. //
Personally, I have been given conflicting information from art supply companies about whether the same product is compliant or non-compliant with the CPSIA and CPSC surface coating requirements with regard to lead and phthalates. //
It would benefit Small Batch Manufacturers and everyone else if there were consistency between the requirements for art supplies to be labelled "AP Non-Toxic / Conforms to ASTM D 4236" and the requirements for surface coatings under ASTM F 963 and the CPSIA. //
Is a bottle of paint "AP Non-Toxic / Conforms to ASTM D 4236" purchased at a craft or art supply store ACTUALLY LEGAL to apply to products intended for children under 14 years of age? It should be. Consistency between these standards would greatly help compliance for Small Batch Manufacturers -- and Consumers who are also, legally if not practically -- bound to comply with the CPSIA. It is disingenuous for art supply companies to claim that their paints are not intended for use by children under 14 years of age when parents, grand parents, and commonly use their paints for children's products.
Comment from Pepi Acebo
This is comment on Proposed Rule
Proposed Guidance on Inaccessible Component Parts: Children'sToys and Child Care Articles Containing Phthalates
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