Congratulations to Mike Rainville, the 2017 SBA Small Business Person of the Year for Vermont

Toy Safety Information

This content assumes you have some knowledge of the Consumer Product Safety Improvement Act of 2008 (CPSIA).

For more information please see http://www.cpsc.gov/en/Regulations-Laws--Standards/Statutes/The-Consumer-Product-Safety-Improvement-Act/. This is based on our best current knowledge and it should be noted that, even within the CPSC, interpretations are evolving.

Our Compliance Efforts
We are working to be in compliance with the law. This is no simple feat as we have 884 products that fall under the act. Being a small company, with such a broad line, it is challenging. As one testing lab suggested, we are the perfect example of a worst case. Nevertheless, our chemical tests have been completed and we are working on other aspects of the act.

Testing Results Past and Present
Our latest tests have matched the results of any previous third-party test we have ever conducted. There is no lead or heavy metal problems with any of our products—not to current standards or to future standards. For example, all recent lead tests were <10 ppm (600 ppm is the current standard). Since we produce our product ourselves and source our finishes locally, most coming from within Vermont we are confident in our ongoing compliance. We have worked with our main finish supplier for over 20 years, we do not jump to the lowest bidder. We have never added lead to our coatings.

Existing Product
Due to our ongoing compliance with lead standards, we expect there to be no problems with any of our products that are on the market, no matter when they were produced. We are not issuing certificates to this fact as there is no established format for doing so. Certificates of Conformity are product/batch/date specific in nature. We do have the linked statement (PDF) you may print for your records.

Warnings
Not only are we required to post appropriate warnings on our product, if you are advertising our product for direct sale (e-commerce, catalog, or direct response), you must include the same warnings with the product description. A simple text warning is understood to be NOT acceptable. Please see the CPSC web site to stay up to date. For our latest list of products requiring warnings, please download this PDF.

Commentary
Our first reaction to the first big China/lead recall (Thomas on 6/14/07) was concern for the inevitable new regulations that would follow. As the problem deepened that summer and our sales sky-rocketed, there was always the sense of the other shoe that was soon to drop. Therefore, we have been following the development of "quality assurance" programs ever since. As such we are not as shocked about what is happening as some other domestic producers. Even so, the time line has been very short and the rules are entirely too much in flux. We have commissioned some tests that have now been ruled unnecessary.

The costs are huge and some of the rules are, frankly, stupid. After the dust settles and sanity takes a part in the process, the need to be sure toys are safe is still the issue. This process is no guarantee and the costs fall heavily on the smaller, domestic companies that have been doing correctly right along. However, we see no way around it. Some small crafters want to be exempted, which may happen, but we've seen toys from small local producers who are obviously blissfully unaware of the most basic design-safety rules. If, as our society likes to say, even one injury is one too many, how do we balance? We don't know.

Speaking of being blissfully unaware, as this whole saga has played out, we at Maple Landmark were under the impression that lead was a banned substance with regard to coatings and paints. We knew the legal limit of 600 ppm but figured that was in place as a trace background, "just in case," threshold. After all, lead is a natural element that is sprinkled throughout our environment.

Certainly we never thought to use 600 ppm as a legal loophole to add lead to our paints and never gave any consideration to anyone else doing so. However, the clues started to mount. General questions about our lead levels (shouldn't they be nearly zero?). Legislative aids calling and asking how much it would cost us of the legal limit were lowered (why would it cost anything?). Finally, we see all of the hubbub around deadlines and lowered thresholds. Why? To us it made no sense. The only explanation is that it has been common for companies to use small amounts of lead. What is the advantage? Brighter colors, easier and smoother application, etc. No wonder we've had a difficult time achieving comparable finishes, we never used lead! Now, companies are pulling their product for all sorts of stated reasons, it leaves us to wonder...

Mike Rainville and the folks at Maple Landmark

© Maple Landmark, Inc.