Commission to Consider Staff Proposals Related to Lead Limit Exemptions

In December, the CPSC staff submitted four proposals to the Commission regarding potential exemptions to the lead limits set forth in Section 101 of the CPSIA.  The Commission was scheduled to vote on the proposals January 5th.  Although there has not been an official CPSC announcement regarding the vote, passing would not yet establish the rules, but simply approve publishing them as Notices of Proposed Rulemaking in the Federal Register.  After publishing, interested parties will have the opportunity to comment before final rules are determined.

The four issues related to lead that we may see as proposed rulemakings later this month include:

1. What products or materials, if any, should be excluded from the lead ban,
2. What the procedures shall be by which a party can seek formal determination that a product or material is exempt from the lead limits,
3. What product components, or classes of components, will be considered to be inaccessible to a child and, therefore, exempt from the new lead limits, and
4. Whether it is technically infeasible for electronic and battery-operated devices to adhere to the new lead limits and, if so – a) what the requirements for such products will be with regard to preventing lead exposure, and b) the timeline for compliance with such requirements.

Over the next couple days, I will post summaries of each of the above proposals and will add links here as I do.  Please bookmark this post for quick access to those summaries.

CPSC Staff Proposal Summaries:

Products or Materials Exempted from Lead Limits

Procedures for Seeking Exemption to Lead Limits

Inaccessibility Rules for Exemption to Lead Limits

Requirements for Electronic and Battery Operated Devices with Regard to Lead Limits

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