Welcome to Allentown Toy Manufacturing Company’s little corner of the web! Allentown Toy has been doing business since 1948. Since our founder, Morty Hertz, opened the door and proclaimed to the world that we are open for business, we have always, without fail, done our part to comply with any and all safety regulations whether they be to keep our employees or the general public...safe from harm and or contaminants. Every minute of every day of every week of every month of every year we have been in business over the past sixty one years, we have carried product liability insurance. We are proud of the fact that we have had zero claims against us...ever.
So this brings us to the recent law passed by Congress and signed into law last fall by President George W. Bush. It was to become known to the world as the CONSUMER PRODUCT SAFETY IMPROVEMENT ACT. And while even the acting chairperson of the CPSC, Nancy Nord feels that the law needs to be amended, we agree with the fact that there needs to be some regulation in order to insure our childrens safety and to make sure that we do not see repeats in putting our children at risk as was the case last year.
When we first heard of this law, we immediately put considerable effort to learning everything we could about the CPSIA. We spoke to our Congressman, Charlie Dent and his staff both here in the Lehigh Valley and in Washington. We discussed the matter with the offices of both of our Senators, Casey and Specter. We even got through to the Honorable Henry Waxmans office. He is the Congressman who chairs the committee that sponsored the bill before it became law.
Not satisfied that we learned all there was to learn, we had a phone conversation with the General Counsel for the CPSC, Cheryl Falvey. She answered a number of questions to our satisfaction. So, while rumors are flying and most people are woefully under informed, we at Allentown Toy not only feel, but we KNOW that we are UP TO DATE with this law. You can be assured that we will continue to keep a dogged determination to stay on top of the info coming out of Washington.
For the time being, we are listing this FAQ:
Answers were taken directly from the CPSC website. The link below the question and answer is the page on the Consumer Product Safety Commissions Website that we are directly quoting.
WHO IS CONSIDERED TO BE A MANUFACTURER?
Anyone who makes, produces, or assembles a product is considered to be a manufacturer. If what you make is sold to or donated, something as simple as adding ribbons to hair clips, knitting hats, or stringing beads into necklaces makes you a manufacturer. Also under the law importers are also considered to be manufacturers and must meet the same requirements.
http://www.cpsc.gov/about/cpsia/smbus/manufacturers.html#q2
WHAT IS A CHILDREN'S PRODUCT?
A children's product is one designed or intended primarily for a child 12 years of age or younger. Toys, clothes, funiture, books, jewelery, blankets, games, CDs/DVDs, strollers, and footwear may all be considered children's products.
In determining whether a consumer product is intended primarily for a child 12 years of age or younger, the following factors will be considered:
•A statement by the manufacturer about the intended use of the product, including a label on the product, if such a statement is reasonable.•Whether the product is represented in its packaging, display, promotion or advertising as appropriate for use by children 12 years of age or younger.
•Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.
The Age Determination Guidelines (pdf) issued by Commission staff.
If a product
is intended for adults or for general use by consumers of all ages, then it is not intended primarily for children. Products marketed and priced in a manner that would not make them appropriate for use by a child would also not be intended primarily for children. An example would be an expensive telescope-- because it is sold for general use by all ages, it is not a children's product even though it can be used by a child on occasion.
http://www.cpsc.gov/about/cpsia/smbus/manufacturers.html#q2
DO ALL CHILDREN'S PRODUCTS NEED TO BE TESTED? WHAT REQUIREMENTS DOES ALLENTOWN TOY NEED TO MEET?
Manufacturers must be aware of all the standards and testing requirements of the law and take appropriate steps to ensure that they meet not only current requirements, but are also preparing themselves and their products to meet future requirements. As an example, children's products that are painted are subject to both lead paint and lead content limits, though at this time, testing is not required for lead content but it is for lead paint. It should be noted that manufacturers must already be testing for and certifying for lead in paint, as well as standards for small parts, cribs and pacifiers. See the following table and pay close attention to the dates. Table A)
http://www.cpsc.gov/about/cpsia/smbus/manufacturers.html#q2
IS THE CURRENT STOCK INCLUDED IN THE FEBRUARY 10, 2010 DATE SET BY THE CPSIA FOR CONFORMITY?
Testing and certification are not required for products already in inventory that are covered by the new lead and phthalate limits and toy standards.
http://www.cpsc.gov/about/cpsia/smbus/manufacturers.html#q2
WHILE TESTING AND CERTIFICATION ARE NOT REQUIRED (FOR EXAMPLE LEAD CONTENT AND PHTHLATES) WHAT DOES ALLENTOWN TOY NEED TO DO?
For these standards, no third-party testing or certificate is needed before February 10, 2010; however, manufacturers must still ensure their products meet the requirements of the law. There are several things manufacturers can do to be highly confident that their products are compliant:
•Get to know your product and the laws and regulations that effect you. Know what is and is not required of you and your products. These requirements can change.
•Develop sound business processes that put safety (and meeting safety standards) first.
•Although there may be no requirement to test and certify, you may choose to do so in the context of a quality assurance program, which ensures products will meet the requirements of the law. This may also include testing raw materials, components and final products. This will also make it easier for you to meet the mandatory third-party testing and certification requirements when they become effective. For lead content testing, one solution would be to hire a qualified, trained person who can quickly screen all of your raw materials and finished products with a handheld device called an X-Ray Fluorescence (XRF) machine.
•If you choose not to test, ask your suppliers about the chemical/material content of their products. Seek out materials that will enable you to produce products that are in compliance.
http://www.cpsc.gov/about/cpsia/smbus/manufacturers.html#q2
IF ALLENTOWN TOY MAKES MULTIPLE UNITS OF THE SAME THING, DO WE HAVE TO TEST EVERY ITEM?
No. If your products need to be tested and they are materially identical and made in the same fashion with no change in assembly, equipment used, etc., then a single sample may be all that is necessary for testing purposes. A change in materials or design can be enough to alter testing results.
There are many other questions out there. We refer you to the following links:
To download a complete guide to the CPSIA, follow the link below:
http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.pdf
To sign up fo e-mail alerts regarding news about the CPSIA follow the link below. We get them!
https://www.cpsc.gov/about/cpsia/cpsialist.aspx