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Materials and CPSIA

What Makes a Spool Dollie?

I have always made Spool Dollies from simple materials that were/are manufactured and purchased in the USA, except for a few vintage spools that were made in Canada and Europe. I created Spool Dollies for adults and children, and safe products have always been a priority for me as I have a three year old son who plays with these dolls. The following is a list of the items that go into making a doll as well as a photo showing all of the items listed below:

Spools: vintage wood spools that were manufactured in the United States, Canada, and Europe over the past century.
Thread: I leave the original thread on some of the spools.
Paint: Delta Ceramcoat paint that is non-toxic, lead free, phthalate free, and made in the USA following ASTM D guidelines. It is a typical water based acrylic craft paint used by millions of home crafters. (see below for more safety information).
Royal Coat decoupage medium that is non-toxic, lead free, phthalate free, and made in the USA following ASTM D guidelines.
Scrapbooking paper made in the USA.
Unfinished wood balls for head and hair made in the USA.

There are new guidelines (CPSIA Regulations) that affect my ability to market Spool Dollies to children under the age of 12 years starting February 10, 2009. These guidelines are intended to protect children from toys that have been produced using toxic materials that could cause illness or even death if ingested. As a mother I believe regulations are important, especially for mass produced toys manufactured outside the United States that may not meet current regulations already set in place for US manufactures of materials like paint. The fact is ALL of the paint, decoupage, and varnish I use are made in the USA and meet strict safety regulations already in place, but I am being forced to test my product at an expense that would put me out of business. This is especially difficult for me because my dolls are not mass produced and each vintage spool is unique, so each completed spool dollie would need to be tested, which would destroy the dollie.

I feel these regulations, though well intended, do not consider the real issues in toy safety or the scope of their effects on toymakers and the economy. They punish small toy makers who cannot afford testing and reward large non US manufacturers who can test one batch out of a million toys they produce daily. As a parent I want the freedom to choose what toys my child plays with, and I want the option to purchase hand made items from cottage industries on a buyer beware level as I have always done.

I will continue to offer my Spool Dollies to the public as I have a small customer base, in the US and abroad,  that knows my products are made with the highest consideration to safety and craftsmanship. BUT, I have to officially and legally recommend my toys to children over the age of twelve or to adult collectors. Thank you for supporting my craft and for you patronage!

The Following is a Materials Safety Data Sheet from Delta Ceramcoat

Material Safety Data Sheet

Product : All Ceramcoat

SECTION 1 - Company Identification

Delta Creative, Inc.

Telephone number: 562-692-7523

2690 Pellissier Place

City of Industry, CA 90601

MSDS Date Prepared: 10/11/06

SECTION 2 - Composition/Information on Ingredients

Ingredient name

CAS #

Wt %

Emulsion co-polymer

Proprietary

30-45%

Water

7732-18-5

35-40%

Pigment

Proprietary

0.1-20%

SECTION 3 -Health Hazard Data

Carcinogenicity:

NTP

IARC Mongraphs

OSHA Regulated

No

No

No

Route(s) of entry: Skin contact, ingestion.

Health Hazards (Acute and Chronic): Will cause eye irritation if eye contact occurs.

Signs and Symptoms of exposure: Inhalation: No known signs or symptoms associated with exposure to product. Skin and eye contact: No known signs or symptoms associated with exposure to this product on the skin. Eye contact may cause reddening and tearing. Ingestion: No known signs or symptoms associated with exposure to this product.

Medical Conditions Generally Aggravated by Exposure: None known.

SECTION 4 - First Aid Measures

Eye contact: Flush eyes with a large amount of water for at least 15 minutes. Skin Contact: Wash affected areas thoroughly with soap and water. Ingestion: If swallowed, give two glasses of water to drink. Consult a physician.

SECTION 5 -Fire and Explosion Hazard Data

Flash point method used

Flammable limits

LEL

UEL

Not applicable

None

None

None

Extinguishing Media: Dry chemical, CO2, water fog. This aqueous product by itself will not burn.

Special Fire Fighting Procedures: The dried product, if burning, will produce carbon oxides and smoke.

Unusual Fire and Explosion Hazards: None

SECTION 6 - Accidental Release Measures

For large spills, use appropriate containment to avoid environmental contamination. Prevent from spreading or entering into drains, ditches, or rivers by using sand, earth, or other appropriate barriers. Use absorbent material to soak up spill. Spill areas can be slippery to walk on. Dried refuse may be disposed of according to local, state and federal regulations.

SECTION 7 -Precautions for Safe Handling and Use

Precautions to Be Taken in Handling and Storing: Avoid storing in areas exposed to direct sunlight. Keep from freezing temperatures. Store in a cool dry place. Keep container tightly closed when not in use.

SECTION 8 -Control Measures

Respiratory protection is not required. Product should be used in a room with general ventilation. Special ventilation is not required. Gloves and protective glasses may be worn, but not required. Long sleeve garments may be worn to minimize contact with skin.

Work/Hygienic Practices: Wash hands with soap and water after use. Close container tightly.

CPSC is currently working to determine exemptions to the lead content limits and the requirement to test. In the interim, until the Commission issues final rules in these areas, certain materials can be used in making products or be sold as children’s products without risk of sanction or penalties by the Commission provided the manufacturer, distributor or seller does not have actual knowledge that the products have more than the acceptable lead limit. The Commission generally will not prosecute someone for making, selling or distributing items in these categories (see Table B) even if it turns out that such an item actually contains more than 600 ppm lead.

Sellers will not be immune from prosecution if CPSC’s Office of Compliance finds that someone had actual knowledge that one of these children’s products contained more than 600 ppm lead or continued to make, import, distribute or sell such a product after being put on notice. Agency staff will seek recalls of violative children’s products or other corrective actions, where appropriate.