The Problem with Test Reports
So what can we learn from this incident? Does it mean you can't rely on third party test reports?
No, the report was fine. The sample that passed the test was fine. The problem was the factory, not the testing lab.
Factories assemble products from raw materials and components that they buy from other suppliers. A bag factory will buy fabric, lining, metal, paint, grommets, thread, handles, wheel assemblies, binding, and whatever else they need from a a variety of sources. If they are required to make a product that complies with 100 ppm lead, that's what they'll specify to their suppliers. But how many factories are equipped as we are to scan every incoming shipment to verify that it complies with the spec? Very few, if any, in my experience. They rely on the integrity of their supply chain and sometimes that supply chain lets them down.
The problem could be with just a portion of an order. Maybe the factory runs out of a particular material and needs a little extra to complete the order. But their main supplier is out of stock, or won't accept orders for small quantities. So the factory goes elsewhere to fill the need. Maybe the extra material complies, maybe not.
It's why Prime and other quality suppliers who buy from dozens of factories in China and elsewhere can't rely on a once per year third party test report. In our case, we've had our testing lab in-house since October 2007—to check every incoming shipment, no matter what the previous test report says. Other quality oriented suppliers in the industry do the same, either in China or in the US.
The most important lesson is to understand that compliance is not a destination. It's not something that you do once or periodically. It's a journey, day in and day out. The process never stops. Whatever you did yesterday means little for the product that is produced tomorrow unless you work as hard at being vigilant tomorrow as you did yesterday.