California 65 testing process for child care pads
Date：2025-10-20 10:24:43 Classification
：【question】 Visits：
California Proposition 65 (Proposition 65) requires the California government to update its list of hazardous substances at least annually. Currently, nearly a thousand chemicals are listed. The standardized process and key points for Proposition 65 testing of childcare pads are as follows:
I. Core Testing Items and Limits
1. Flame Retardants (Key Testing Item)
- Limit Requirement: The content of each of the three flame retardants TDCPP, TDBPP, and TCEP must be ≤ 25 ppm (25 parts per million).
- Prohibited Substances: Foam fillings must not contain flame retardants such as TCPP, TBB, TBPH, and DecaBDE.
2. Phthalates (Plasticizers)
- Plasticizer content of DEHP, DBP, and BBP must be ≤ 1000 ppm (exceeding this limit requires a warning label).
3. Heavy Metals
- Lead (Pb) Content: ≤ 200 ppm for PVC materials, ≤ 600 ppm for non-PVC materials.
II. Detailed Explanation of the Full Testing Process
Step 1: Confirm the Testing Scope and Items
- Material Analysis: Provide a list of the materials used in the nursing pad (e.g., polyurethane foam, surface coating, adhesive), and identify high-risk ingredients (flame retardants, phthalates, lead).
Step 2: Sample Preparation and Submission
- Sample Requirements:
- 2-3 complete finished products (including all filling layers and surface materials).
- Attach a detailed Bill of Materials (BOM), specifying the materials and suppliers of each component.
- Testing Methods:
- Flame Retardants: GC-MS (Gas Chromatography-Mass Spectrometry);
- Heavy Metals: EPA 3050B or ASTM F963.
Step 3: Laboratory Testing Cycle
- Standard Cycle: 5-7 business days (expedited testing available for an additional fee).
Step 4: Report Review and Compliance Determination
- Acceptable Results: Obtain a test report confirming that no excessive substances were detected.
- Handling of Exceeding Standards:
- Adjust the formulation (e.g., replace flame retardants or plasticizers);
- Add a warning label to the packaging, for example:
"Warning: This product contains TDCPP (a carcinogen) that may cause birth defects or reproductive harm."*
III. Non-Compliance Risks and Mitigation Recommendations
1. Legal Risks:
- Facing class action lawsuits, with fines potentially reaching millions of dollars per case;
- California retailers banning products that fail testing.
2. Optimization Strategies:
- Pre-screening of materials: Use an XRF scanner to screen for lead content before testing to reduce costs;
- Utilizing exemptions: If chemical exposure can be proven to be extremely low (e.g., a sealant isolates contact), labeling may be waived;
- Regularly update testing: The California 65 list is updated quarterly (with an eye toward new substances such as PFAS).
IV. Frequently Asked Questions
- Q: Is testing required to cover all 900+ chemicals?
→ No! Prioritize testing for flame retardants, phthalates, and heavy metals related to nursing pads.
- Q: Does silicone coating require additional testing?
→ Yes! Silicone coatings require additional bisphenol A (BPA) migration testing.
Shen Gongwang Security: 44030602006947