After joining a Webinar held by the
Printing Industries of America headlined by the Chief General Counsel for the
CPSC, we thought we would share some of the latest information regarding the
new CPSC Children’s Product Requirements.
For those of you who aren’t sure what we
are talking about…these new product requirements we discuss below are part of
the Consumer Product Safety Consumer Act and basically they are making sure
that products aimed towards children aren’t harmful (lead free etc). So, there
has been a lot of talk about how the guidelines and testing apply to Children’s
books.
We have touched on this subject in the
past, but there is still much confusion about what the new regulations mean to
publishers, printers and authors. Listening to the webinar and seeing the many
questions being asked by high level members of the industry coupled with the
non-direct answers by the counsel just confirmed the chaos that the new
regulations are causing.
This is what we took from the Webinar,
and we are applying it to the industry as we know it:
-Publishers and Printers are equally
responsible for labeling their books free of lead and harmful substances
outlined by the new guidelines.
-Printers can get test results from their suppliers. Suppliers of glue, coil
etc, should be responsible for making sure the tests are done, and they can
simply fax you a copy of the results letting you know their products are lead
free.
-When assured by the printer that all materials going into each book meet the
guidelines, publishers can add a few additional lines on the copyright page (as
explained below), stating that the book is safe for children. Or, depending on
how friendly you are with your printer, they can add a page into the front
matter of your books certifying that it meets the new standards.
-By labeling a book safe for children,
they don’t mean stick a label on the book or even create a brand new label,
they mean make a note (such as on the copyright page) about where the book was
manufactured (name of printer, date and location), as well as the batch # of
the book. Some printers may be able to just put their job# discreetly in the
book. Basically, just make sure you can identify when the book was produced in
the unlikely event of a recall.
Note: As of now, there is no official
standard for “labeling”, so just make sure the information is there. We see the
copyright page as the easiest way to add this information.
Directly from the presentation, here’s a
list of what no longer requires testing:
Paper
Any product printed with four color process inks (CMYK)
Any product coated with varnish, water-based, or UVcured coatings
Threads used for book binding
Animal based glues
Adhesives that are not accessible
Binding materials that are not accessible
These items still require testing:
Spot or PMS inks
Saddle stitching wire
Non-animal based glues that are accessible
Metal coils both coated and uncoated for coil bound
materials
Plastic coils for coil bound materials
Foils used in foil stamping
Laminates
If you have any questions or thoughts
then let us know.