ROHS-HEAVYELEMENTS-3600.doc

QSOP 0006 3600 IPage 1 of 9 PI CONFIDENTIAL MATTEL INC PROPRIETARY INFORMATION TITLE HEAVY ELEMENTS QUALITY AND SAFETY NUMBER 0006 3600 REVISION I DATE 08 30 06 OPERATING PROCEDURE AUTHOR D Taylor REVISED BY F Gibbs 1SCOPE 1 1Products and Components Covered All products including packaging intended to remain with the product 1 2Exemptions 1 2 1Children s Jewelry Items test per QSOP 0006 3604 Heavy Elements Children s Jewelry 1 2 2Components that are not accessible to the consumer at any point during assembly use and foreseeable abuse Inaccessible components of electrical electronic products are tested per QSOP 0006 3602 RoHS 1 2 3Soluble method 1 if sample material is 10 mg 1 3Definitions Words that are defined are italicized and bolded once per section Accessible Any area of the toy that can be contacted by any portion forward of the collar of the accessibility probes when inserted to the depth determined in QSOP 0006 3010 Accessibility Composite Sample A sample made from combining more than one material or color e g paint red yellow and blue vacuum metalized coating silver and gold Jewelry Items Ornamental items that are intended to be worn in the hair or on the body Examples would include rings necklaces bracelets etc This definition also includes jewelry kits that are intended to create jewelry items Paints solid or liquid intended for use by the consumer Substrate The base material beneath a surface coating Suitable Suitability of a toy for a child of a particular age Reference data compiled by the Consumer Product Safety Commission CPSC in Guidelines for Relating Children s Ages to Toy Characteristics This guideline describes mental physical and motor skill development of children from birth to 14 years See United States regulations 16 CFR 1501 2 and 1501 3 for additional reference to suitability of small parts Surface Coating All layers of materials such as paint or similar that dries to a solid film when it is applied to a surface and it can be scraped off with a sharp blade without removing substrate base material 1 4Purpose Evaluate product for compliance to worldwide safety standards for heavy metals content QSOP 0006 3600 IPage 2 of 9 PI CONFIDENTIAL MATTEL INC PROPRIETARY INFORMATION 2PERFORMANCE REQUIREMENTS 2 1Pliable Modeling Clay and Finger Paints Must be the following limits ELEMENT TOTAL ppm SOLUBLE METHOD1 ppm Antimony Sb 60 Arsenic As 25 Barium Ba 250 Cadmium Cd 50 Chromium Cr 25 Lead Pb 20090 Mercury Hg 25 Selenium Se 500 2 2Surface Coatings Must be the following limits ELEMENT TOTAL ppm SOLUBLE METHOD 1 ppm SOLUBLE METHOD 2 ppm Antimony Sb 601000 Arsenic As 251000 Barium Ba 5001000 Cadmium Cd 751000 Chromium Cr 60 Lead Pb 60090 Mercury Hg 10 Selenium Se 3001000 ADDITIONAL REQUIREMENTS ELECTRICAL ELECTRONIC PRODUCTS ONLY Cadmium Cd 100 Hexavalent Chromium CrVI 1000 QSOP 0006 3600 IPage 3 of 9 PI CONFIDENTIAL MATTEL INC PROPRIETARY INFORMATION 2 3Metal that is not a small part and not likely to be mouthed Must be the following limits ELEMENT TOTAL ppm Lead Pb 3500 ADDITIONAL REQUIREMENTS ELECTRICAL ELECTRONIC PRODUCTS ONLY Mercury Hg 1000 Cadmium Cd 100 Hexavalent Chromium CrVI 1000 2 4Metal that is a small part or likely to be mouthed e g mouthpieces of musical instruments pen tips metal on products suitable for 1 0 gram If total lead exceeds 600 ppm a positive risk assessment by a certified toxicologist is required QSOP 0006 3600 IPage 5 of 9 PI CONFIDENTIAL MATTEL INC PROPRIETARY INFORMATION 2 7Textiles and Articles of Clothing intended to be Worn on the Body including e g shirts pants rain wear coats and accessories such as safety goggles gloves scarves hats socks neckties decals patches and trims If the item contains Polyvinyl Chloride PVC the lead content in the PVC must be the following limit ELEMENTTOTAL ppm Lead Pb 30 2 8All Other Materials Must be the following limits ELEMENT TOTAL ppm SOLUBLE METHOD 1 ppm Antimony Sb 60 Arsenic As 25 Barium Ba 500 Cadmium Cd 75 Chromium Cr 60 Lead Pb 20090 Mercury Hg 60 Selenium Se 300 ADDITIONAL REQUIREMENTS ELECTRICAL ELECTRONIC PRODUCTS ONLY Cadmium Cd 100 Hexavalent Chromium CrVI 1000 Mercury1000 QSOP 0006 3600 IPage 6 of 9 PI CONFIDENTIAL MATTEL INC PROPRIETARY INFORMATION 3TEST METHODS 3 1Test Environment not applicable 3 2Equipment Use equipment specified in procedures referenced in 3 4 3 3General Test Requirements 3 3 1Analyze materials separately whenever possible 3 3 2Use of a composite sample is allowed where one type of material or color cannot be physically separated 3 3 3Samples are to be tested in the same form they appear on the finished product e g paint is tested in its dry state 3 3 4Coated surfaces require testing of both the surface coating and the base material with the coating removed 3 4Procedure 2 0 3 4 1Total Test Method 3 4 1 1Total Hexavalent Chromium Cr VI Use one of the following methods as applicable ISO 3613 Chromate Conversion Coatings on Zinc Cadmium Aluminum zinc Alloys Zinc aluminum Test Methods or equivalent EPA Test Method 3060 Alkaline Digestion for Hexavalent Chromium or equivalent Variations of these extraction and analysis methods and or use of an alternate method are acceptable if in the expert opinion of the test laboratory they are declared to be equivalent or better 3 4 1 2Total All Other Elements 3 4 1 2 1Thoroughly digest the sample utilizing any suitable method for the sample material such as using a concentrated nitric acid per AOAC 974 02 Conventional ashing microwave or hot plate digestions can also be used 3 4 1 2 2Analyze the digestion utilizing any suitable method based on the equipment used AA or ICP and the element content to be determined 3 4 2Soluble Method 1 3 4 2 1Test and evaluate surface coating material per the latest revision ASTM F963 3 4 2 2Test and evaluate non surface coating material per the latest revision EN 71 3 3 4 2 3Analyze the solution for heavy elements content using either atomic absorption spectroscopy AA or inductively coupled plasma spectrophotometry ICP QSOP 0006 3600 IPage 7 of 9 PI CONFIDENTIAL MATTEL INC PROPRIETARY INFORMATION 3 4 3Soluble Method 2 3 4 3 1Test and evaluate for soluble lead per the latest revision of Health Canada Book 5 Laboratory Policies and Procedures Part B test method C 08 Determination of Leachable Lead in Metallic Consumer Products which pose a Hazard from Ingestion 3 4 3 2Test and evaluate for soluble cadmium barium antimony selenium and Arsenic per the latest revision of Health Canada Book 5 Laboratory Policies and Procedures Part B test method C03 1 Determination of Leachable Cadmium Barium Antimony Selenium and Arsenic in Applied Coatings 4HISTORY 4 1 Significance Compliance can be assured by using a testing and compliance system that will reduce the risk of finished products having an excessive amount of heavy elements Soluble test method 1 is required per EN 71 3 ISO 8124 Mexico s NOM s and India s IS 9873 3 Soluble test method 2 is required per Canada s Hazardous Products Act The Canadian HPA does not allow mercury to be intentionally added to the surface coating materials SCM A test result of 10 mg kg ppm total mercury is considered the most reliable way to determine that no mercury has been introduced 4 2 Reason for Revision SectionRevision H Implementation date AllEditorially revised for clarity Tables 1 from 200 ppm to 600 ppm and requirements for specific materials have been added based on Burlington Coat Factory Proposition 65 settlement and California AB 1681 The requirements for children s jewelry have been removed placed in a separate QSOP 0006 3604 Heavy Elements Children s Jewelry 2 7Adds the requirement for wearing apparel that contains PVC the PVC portion of the apparel must not contain more than 30 ppm lead based on Ca Proposition 65 litigation QSOP 0006 3600 IPage 9 of 9 PI CONFIDENTIAL MATTEL INC PROPRIETARY INFORMATION 4 3 The following documents contain requirements related to this procedure 16 CFR 1303 EN71 3 1994 with amendment A1 2000 ASTM F963 03 California Proposition 65 Canadian Hazardous Products Act and Health Canada s Guideline for Lead in Children s Products ISO 8124 3 1997 Mexico NOM s EU Council Directive 91 338 EEC U S CPSC Policy on Lead in Certain Art Materials U S CPSC Standard Operating Procedure for Determining Lead Pb and Its Availability in Children s Metal Jewelry 2 3 2005 Q A publication from the Consumer Product Safety Commission entitled Lead Testing for Children s Met