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Effective February 8, 2013, periodic testing must be conducted on the continuing production of children's products. This requirement comes in addition to those tests conducted when a children's product was initially assessed for certification, or when the product was reassessed and certified following a material change. Periodic testing must be performed by a Consumer Product Safety Commission accepted (CPSC) third-party laboratory.
If you provide children’s product certificates, it may be necessary that you comply with the periodic testing requirements. For products manufactured domestically, the manufacturer is responsible, whereas, for products manufactured overseas, the importer is responsible. Certifiers of component parts used in children’s products must ensure that periodic testing has been conducted on the component parts.
The requirement to conduct periodic testing hinges on the definition of continuing production of children's products. Continuing production is a flow production method used to manufacture, produce or process materials without interruption. Continuous production is a continuous process or a continuous flow process because the materials being processed are continuously in motion, undergoing chemical reactions or subjected to mechanical or heat treatment. These processes operate 24 hours per day, seven days per week with infrequent (semi-annual or annual) maintenance shutdowns.
Conversely, batch manufacturing is the process in which components or goods are produced in groups — batches — and not in a continuous stream. During batch manufacturing, the production line is stopped and restarted for each new product, the key differentiating factor between continuous, or line, production and batch production. Decorated garments are produced using a batch manufacturing process. The requirement to conduct and implement a periodic testing program is not required for facilities engaged in batch manufacturing operations.
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SGIA Members: Take advantage of these resources:
CPSIA Overview
Fact Sheets:
Reasonable Testing Programs – the Final Link in the CPSIA Chain
Additional CPSIA Resources:
Discuss your situation with Marci Kinter, SGIA's in-house CPSIA expert.
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