Author Topic: Interesting situation - I think I'll be OK  (Read 2512 times)

Offline Ripcord

  • Sr. Member
  • ****
  • Posts: 283
Interesting situation - I think I'll be OK
« on: January 28, 2012, 11:22:32 AM »
I have a customer that is having a baby shower and came up with the idea of printing the invitations on bibs and mailing them to her friends. We all know the pthalate restrictions and contact label requirements for children under 3 (bibs are used for eating so are subject to the law).

I decided to do the job since these are not intended for actual use by babies, rather as a novelty for adults. I plan to print a disclaimer on the back making it clear that these are for the purpose of an invitation and are not intended for use by children under 3.

While the law is vague in some areas, it is clear that the regulation applies to products intended for use by children under 3. These clearly are not. I believe under the circumstances, and especially with the printed disclaimer, that this is OK to print. What do you guys think?
« Last Edit: January 28, 2012, 11:33:40 AM by Ripcord »
Raster to vector conversion


Offline ScreenFoo

  • Gonzo Member
  • ******
  • Posts: 1296
  • Semper Fidelis Tyrannosaurus
Re: Interesting situation - I think I'll be OK
« Reply #1 on: January 28, 2012, 11:30:41 AM »
I makes me think of the guy on TSF who said he doesn't print for children, only adults and adult leprachauns....   :)

Offline Frog

  • Administrator
  • Ludicrous Speed Member
  • *****
  • Posts: 13980
  • Docendo discimus
Re: Interesting situation - I think I'll be OK
« Reply #2 on: January 28, 2012, 11:46:04 AM »
With the time and effort taken to print the disclaimer, myself, I'd rather opt to use acceptable inks and add a tracking label instead, even without the small user exemption or any other newly developed red tape, I feel that it shows an intent to comply that hopefully will count for something.
Pierre recently posted the information and his own experience on the exemption, so that is on my "to do" list.

Otherwise, your disclaimer might cover you in the end, and/or in fact, could serve as a lesson to us all if not ;D
That rug really tied the room together, did it not?

Offline Evo

  • Hero Member
  • *****
  • Posts: 953
  • Anything is possible.
Re: Interesting situation - I think I'll be OK
« Reply #3 on: January 28, 2012, 05:01:42 PM »
Print with wb inks? Better for bibs anyway.
There is scarcely anything in the world that some man cannot make a little worse, and sell a little more cheaply. The person who buys on price alone is this man's lawful prey.
John Ruskin (1819 - 1900)

Offline RICK STEFANICK

  • Gonzo Member
  • ******
  • Posts: 1925
  • INDUSTRY CONSULTANT-OPERATIONS SPECIALIST
Re: Interesting situation - I think I'll be OK
« Reply #4 on: January 28, 2012, 06:12:50 PM »
I was thinking the same thing. or use that new rutland HSA.
Specializing in shop assessment's, flow and efficiency

Offline Ripcord

  • Sr. Member
  • ****
  • Posts: 283
Re: Interesting situation - I think I'll be OK
« Reply #5 on: January 28, 2012, 07:53:39 PM »
Yeah, but this is one order of 35 bibs. I don't wanna buy special ink....
Raster to vector conversion

Offline Frog

  • Administrator
  • Ludicrous Speed Member
  • *****
  • Posts: 13980
  • Docendo discimus
Re: Interesting situation - I think I'll be OK
« Reply #6 on: January 28, 2012, 08:15:38 PM »
"Special" Ink doesn't relieve one of any of the other obligations under the law. It merely meets the requirements.
That rug really tied the room together, did it not?

Offline blue moon

  • Administrator
  • Ludicrous Speed Member
  • *****
  • Posts: 6366
Re: Interesting situation - I think I'll be OK
« Reply #7 on: January 28, 2012, 11:23:44 PM »
as far as I understand, you do not have to print the disclaimer(the text of the invite will indicate the purpose). I would advise against printing the tracking info as it might be interpreted as child care article which it clearly isn't. Using phthalate free inks will not make you compliant. Using phthalate free ink in a shop that uses phthalates on regular bases might not pass the testing anyway (due to cross contamination from the squeegees, dryer fumes and other similar issues).

The yardstick for judging is the intent. This has nothing to do with kids so no CPSIA regulation applies.

Now, I am not a lawyer, but damn, if I haven't spent about a hundred hours researching this I have not spent a min. . .

pierre
« Last Edit: January 29, 2012, 04:11:10 PM by blue moon »
Yes, we've won our share of awards, and yes, I've tested stuff and read the scientific papers, but ultimately take everything I say with more than just a grain of salt! So if you are looking for trouble, just do as I say or even better, do something I said years ago!

Offline dsh

  • Full Member
  • ***
  • Posts: 158
Re: Interesting situation - I think I'll be OK
« Reply #8 on: January 29, 2012, 04:07:32 PM »
Pierre,
Would sublimation avoid issues?  It would be pricey (amount of ink used) is they wanted a background color other than white, but you would bypass the whole phthalate issue.

Offline blue moon

  • Administrator
  • Ludicrous Speed Member
  • *****
  • Posts: 6366
Re: Interesting situation - I think I'll be OK
« Reply #9 on: January 29, 2012, 04:13:57 PM »
Pierre,
Would sublimation avoid issues?  It would be pricey (amount of ink used) is they wanted a background color other than white, but you would bypass the whole phthalate issue.

two issues we are talking about here, tracking and conformity. Both of those only apply to products for kids 12 and under so neither of them are in play in this particular case.

no need for special ink  or what not . . .

pierre
Yes, we've won our share of awards, and yes, I've tested stuff and read the scientific papers, but ultimately take everything I say with more than just a grain of salt! So if you are looking for trouble, just do as I say or even better, do something I said years ago!