Playing By the Rules
While phthalates also are a concern for writing instruments, John mentioned another priority is to ensure lead levels are below federal standards of 90 ppm for surface coatings and 100 ppm for substrates. "When lead is being tested, you have to test it to the substrate, which is the actual blank product, and then you have to test it for the surface coating, which would be the logo," she said. "Testing should always cover both standards."
Sun Coast uses its X-ray fluorescence (XRF) equipment that screens for heavy metals to ensure sample products' lead levels fall below CPSIA regulations. "Before sending it to a lab for third-party testing, one of the approaches we have adopted is to screen all approval samples or incoming samples for heavy metals using a XRF, so we can communicate the results to our supplier before it goes into lab testing," John said. "It helps us eliminate numerous rounds of testing and it helps us create greater accountability for our suppliers. […] If I'm finding high-levels of lead at the sample level, I can stop that right away before the unit goes into mass production."
John suggested keeping your end-user and their location in mind when determining the right product. If a product will end up in a school or other setting where children may get their hands on it, the supplier tests it to CPSIA standards as a precaution. "You have to think of your end-user, and [where a product will be used is] a common question we ask whenever we get any orders," John said. "We ask for the age grade. We ask where the distribution location is. As promo items, you never know where it's going to end up at, so we try to gather as much information as possible to help us classify that product as either general use or children's product."