Enabling you to identify and mitigate the intrinsic risk in your operations, supply chains and business processes.
Evaluating how your products and services meet and exceed quality, safety, sustainability and performance standards.
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The State of Washington’s Children’s Safe Products Act (CSPA) is a two part rule: Part I restricts the use of lead, cadmium and phthalates in children’s products under the scope of the CSPA; while Part II is the Reporting rule, requiring reporting for the presence of any of the 66 chemicals, designated as the chemicals of high concern to children (CHCC).
There is some overlap between part I of CSPA and the federal Consumer Product Safety Improvement Act of 2008 (CPSIA). The children’s products regulated by the CPSIA are preempted from the Washington state CSPA requirements and enforcement.
However, the lead, cadmium and phthalate restrictions of the CSPA Part I are stricter and cover a broader range of children’s products. Thus, for those categories of products considered ‘children’s products’ by the Washington CSPA and not by the U.S. Consumer Product Safety Commission, requirements of the Washington CSPA Part I apply and are subject to enforcement.
Recent enforcement activities by the Washington Department of Ecology have brought to light the rather widespread misbelief that part I of the CSPA is completely preempted by the CPSIA. As a result, on February 12, 2016, the Department of Ecology issued a guidance document intended to clarify the sections of the CSPA part I lead, cadmium and phthalate requirements preempted by the CPSIA and those that are not.
Key points from the guidance document:
The Washington CSPA Part I may be found at: http://app.leg.wa.gov/RCW/default.aspx?cite=70.240.020 and the guidance document can be viewed at: http://www.ecy.wa.gov/programs/hwtr/rtt/cspa/pdf/LeadCadmiumPhthalatesenforcement.pdf