January 14, 2009
While I was writing this response to those who did not believe books for children 12 and under were required to be tested, the HSLDA response to the CPSIA concern came thru. Here is my reply to their response.
Okay ladies, here is info on books - which affects all of us whether our children are homeschooled or in public school. Here is the link I will be discussing:
This is a response to a letter sent to the CPSC about excluding books from testing (pg 5 and onward) and the reply (pg 1-4) from the CPSC.
Note page 2, paragraphs 2 and 3 specifically.
“Second, with regard to those books that are intended or designed
primarily for children 12 years of age or younger, ordinary books are not subject to the ban on lead-in-paint. As has always been the case, printing ink is not considered a surface coating under the lead-in-paint ban because ink by its nature soaks into paper or cardboard and becomes part of the subtrate. (My emphasis for the following:) HOWEVER, A BOOK INTENDED OR DESIGNED PRIMARILY FOR CHILDREN WOULD NEED TO MEET THE NEW LEAD CONTENT LIMIT OF 600 PPM AND SUBSEQUENTLY 300 PPM ESTABLISHED BY THE CPSIA. Printing ink becomes part of the subtrate of the book for purposes of evaluating its lead content.
It appears that the levels of lead in the test data you provided are well below the lead limits established in section 101 of the CPSIA; however, some of the tests were not for total lead content as the CPSIA requires but rather for soluable lead, ie, the test looked at the amount of lead that could be extracted from those products or materials. In order to provide blanket exemptions for paper, paperboard, linerboard, printing inks, laminates, adhesives and binding materials used in books, the Commission needs total lead test data to support the determination that those materials do not contain lead at levels that exceed the CPSIA lead content limits. While the Commission staff has been diligently searching for such data from publicly available sources, it does not at this time have sufficient data on the total lead content of those materials to issue an exemption. Moreover, the staff has raised concerns about issuing exemptions on a commodity or class of materials basis without some data that the test results are representative of such materials as a class based on technical specification or other defined, objective criteria.”
This is written plainly, from the CPSC to Mr. Adler specifically about their stance on printed books. ALL PRINTED BOOKS FOR AGES 12 AND UNDER.
To date, nothing has been amended in the law to exempt books.
HSLDA has sent out a letter today replying to the new law, ( http://www.hslda.org/docs/news/20091130.asp ) however, I do not believe they have done adequate research because they too go in circles without saying anything specific. They do not seem to realize that a publisher is also a manufacturer and thereby is required to do the testing - the printing company is NOT required to do the testing (even if they did, they would pass on the cost to the publisher so the problem of excess cost is still the same). HSLDA does not consider publishers ‘manufacturers’ and this is HSLDAs basis for why this new law will not affect curriculum and other homeschool printed materials - they need to speak to the CPSC and to publishers (big or small!!!) and get more informed about publishing before they send out an annoucement that the new law is not going to hurt homeschool publishers.
If they would read the link above or speak directly to the CPSC, they would KNOW this law is going to force every book publisher who publishes books for ages 12 and under to test their books at government approved testing facilities… HSLDA seems to be several weeks behind and do not fully understand how the publishing business works. Otherwise, they would see the dangers.
If anyone on here personally knows someone at HSLDA, please ask them to contact PUBLISHERS and to read the link I provided above and the specific page and paragraphs I wrote about. They don’t even seem to be aware of how this is affecting Random House and other HUGE publishers, let alone the smaller homeschool publishers.
I am very disappointed in HSLDA’s reply to this situation - I realize this is not their area of expertise and I do highly respect the work they do for the homeschool community - however, as a self publisher I am upset they did not research more fully or speak to publishing companies (both large and small) before they wrote their response to CPSIA concerns. I expected a much more detailed and understandable reply with actual, factual information and that hasn’t come thru yet.