Interesting and Discouraging

greitz · Post by **greitz** » Thu Nov 17, 2011 5:46 pm

Untreated wood is exempted. If you put any kind of finish on it at all, my understanding is that you either need to test the finished unit or have a certificate from the manufacturer that the finish has been tested and complies with the regs. (I suppose if Big Brother really wants to be picky, you'd also have to have a notarized certificate that paint brand xxxx, lot # xxxx, was applied to the item, and that no other finishes were used....)

This is a very popular topic on some of the scroll saw forums, as well.

I noticed that some of the paint manufacturers are putting their compliance certificates on the web, so maybe this whole thing will be a non-issue for us, as "hobby manufacturers", soon.

Gary

beeg · Post by **beeg** » Thu Nov 17, 2011 6:03 pm

Use shellac, it's FDA approved.

swampgator · Post by **swampgator** » Thu Nov 17, 2011 8:55 pm

This is not an advertisement, but something that I use when I use paints on toys that I give away or send to missions. It is sold at Michael's, Craftmarts acrylic paint is ASTM D-4236 compliant. It's not very expensive, but I don't have to worry that I have hurt a child through what I've done or used. Just saying.

foxtrapper · Post by **foxtrapper** » Fri Nov 18, 2011 6:31 am

For the record, leaded paints are still very readily available, and are sold in art stores and hardware stores nation wide. Lead was only banned in house paints, not other paints. It's not even banned in food grade paints.

You are not a manufacturer if you are giving the toys to your family. Only when you go outside of that lineage do you become a manufacturer.

dusty · Post by **dusty** » Fri Nov 18, 2011 7:27 am

swampgator wrote:This is not an advertisement, but something that I use when I use paints on toys that I give away or send to missions. It is sold at Michael's, Craftmarts acrylic paint is ASTM D-4236 compliant. It's not very expensive, but I don't have to worry that I have hurt a child through what I've done or used. Just saying.

Thank you for the reference.

swampgator · Post by **swampgator** » Fri Nov 18, 2011 12:03 pm

Absolutely welcome. You do the same all the time.

beeg · Post by **beeg** » Fri Nov 18, 2011 12:48 pm

foxtrapper wrote:You are not a manufacturer if you are giving the toys to your family. Only when you go outside of that lineage do you become a manufacturer.

WHERE in the following statement is this exception?

"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 or donated, something as simple as adding ribbons to hair clips, knitting hats, or stringing beads into necklaces makes you a manufacturer. Under the law, importers are also considered to be manufacturers and must meet the same requirements."

foxtrapper · Post by **foxtrapper** » Fri Nov 18, 2011 1:32 pm

Read further, it's in both the definitions section and the applicability section of the Code of Federal Registers. You need both sections to fully understand it. Manufacturer is defined in the definitions section, an then the bit about making things for yourself or your family is fleshed out in the applicability and exemption section that follows definitions.

Just because you made something does not automatically make you a manufacturer, or subject to this regulation.

JPG · Post by **JPG** » Fri Nov 18, 2011 3:31 pm

beeg wrote:WHERE in the following statement is this exception?

"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 or donated, something as simple as adding ribbons to hair clips, knitting hats, or stringing beads into necklaces makes you a manufacturer. Under the law, importers are also considered to be manufacturers and must meet the same requirements."

Well why in the world did 'they' make this statement, then redefine it later and create 'exceptions'.

Wonder if different folks created different 'sections' with no oversight.

Oh I forgot! Bureaucratic obfuscation.

dusty · Post by **dusty** » Fri Nov 18, 2011 3:49 pm

I once worked in an organization where that was referred to as "removing your foot". The unspoken words were "without getting any on yourself".

We often found it necessary to "revise requirements" but were pressed hard not to change anything that we had already released. With a bit of practice, you can get pretty good at extricating yourself.