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Safety Information

We consider the safety of our products and being in compliance with all government safety legislation to be a top priority! We are meeting all requirements, but please read on for more information.

This safety information page has three important divisions:

UPDATE, February 2, 2009: On January 30, 2009 the CPSC issued a one year stay of enforcement for certain testing and certification requirements. This provides much needed time for the commission to clarify requirements and exempt certain materials from excessive testing. This does not effect the ban on lead in paint or other surface coatings, or small parts testing. Despite this stay, Mudpuppy will continue to test and certify our products using third-party labs. We will continue to post test results and certificates of conformity on our website.

1) AN UPDATE ON PRODUCT SAFETY AND FAQs:

As many of you are aware, in August 2008, President Bush signed into law the Consumer Product Safety Improvement Act (CPSIA), which requires manufacturers of children’s products to test and certify their products to ensure they meet specific safety standards. The CPSIA requires manufacturers to comply with all CPSC regulations, employ third-party testing to ensure products have no harmful components, and label items with place of origin and batch numbers.

The new regulations have caused much confusion as the various elements of the legislation are implemented on a rolling basis. Please be assured that we consider the safety of our products as well as compliance with all governmental regulations to be a top priority.

Below we have outlined the new requirements as they relate to Mudpuppy products. If you have any additional concerns, please contact us at sales@galison.com and we will be happy to discuss any questions with you.

Important CPSIA Dates

November 12, 2008:
A Certificate of Conformity (COC) will accompany each batch of product as it leaves the factory. This certificate certifies that the product is compliant with all CPSIA standards, including for small parts, lead, and phthalates. By law, these certificates must be accessible to all customers.

It is not necessary for customers to retain a paper copy of each certificate. As these certificates are generated, they are be posted on our website and available as a link from this Safety Information page. Products manufactured and imported before November 12, 2008 will not have a Certificate of Conformity. (This is a shipping document and cannot be created retroactively.)

However, we have tests for all products in our warehouse showing that they meet CE and ASTM standards, including for lead content. We can provide these to customers upon request. The only standard that has changed and applies retroactively is for lead content. We have been testing for lead for several years, and can assure our customers that we are compliant with the new regulations.

December 21, 2008: All children’s products must be tested for lead content by a third party laboratory. Printing inks are not considered “paint” by the CPSC and thus are not subject to the lead paint testing requirements. As noted above, Mudpuppy has tested each product for CE and ASTM safety standards, including lead content, beginning in 2004. We also periodically test ink supplies to ensure their safety.

February 10, 2009: Products that contain more than 600 ppm of lead are banned. This ban is retroactive, so no existing inventory of children’s products can exceed this standard. The acceptable lead content is reduced on a rolling basis until the limit becomes 90 ppm as of August 14, 2009.

Mudpuppy products are currently compliant with the Under 90 ppm standard.

Products containing concentrations of more than 0.1 percent of specified phthalates are banned. Mudpuppy products have been phthalate free since 2007.



FREQUENTLY ASKED QUESTIONS REGARDING THE CPSIA


Mudpuppy has received many requests for additional information and clarification of the new safety regulations stipulated by the CPSIA. Please see below for asnwers to some of our most frequently asked questions.

Certificates of Conformity

Should Certificates of Conformity (COC) accompany my shipment from Mudpuppy?

COCs are shipping documents that are created when Mudpuppy imports product through US customs. These documents cannot be generated retroactively, and therefore only apply to product manufactured or imported after November 12, 2008. COCs are not generated for shipments from our warehouse to customers, and will not accompany these shipments.

Is the importer or U.S. manufacturer required to supply the certificate to its distributors and retailers? Yes. The importer or U.S. manufacturer is required to provide its distributors and retailers a reasonable means to access the certificate. You can access COCs at any time at http://wholesale.galison.com/Safety-Documentation-W73C0.aspx. We are in the process of also posting all test reports to make additional information available to our customers.

Certificates of Conformity (COCs) are only available on shipments into the US after November 12, 2008. How do I know that older product from your warehouse is safe and compliant with the new laws? Mudpuppy has CE and ASTM tests for all products in our warehouse. Prior to the new legislation, ASTM was the US voluntary safety standard. Our products have been tested by third-party labs for CE Certification since 2004, and for ASTM since 2007. For example, the US lead standard is 600 ppm, and will be reduced to 300 ppm on August 14, 2009. We can provide tests to show that all Mudpuppy products currently have less than 90 ppm lead content, well below current US regulations.

Lead

If you have a children’s product with possible lead content, do you have to have a certificate on November 12, 2008, even though the lead rule is not effective?

No. The lead content limits for children’s products go into effect February 10, 2009. Children’s products manufactured after February 10, 2009 will need a general conformity certification based on a test of the product.

What if the product was manufactured prior to February 10, 2009?

The lead content limits are retroactive, and will apply to stock in inventory. Mudpuppy has been testing for lead since 2004, and can provide testing to assure you that all stock is compliant with the new lead limits.

Phthalates

What phthalates have been banned?

DEHP, DBP, and BBP, have been permanently prohibited in concentration of more than 0.1% in children’s toys and child care articles. Three additional phthalates, DINP, DIDP, and DnOP, have been prohibited pending further study and review.

When does the phthalates ban go into effect for children’s toys and child care articles and does it apply to inventory in existence on February 10, 2009?

The ban on the six specified phthalates becomes effective February 10, 2009. This ban IS retroactive and applies to existing inventory. Mudpuppy products have been phthalate free since 2007.

For a full list of CPSC FAQ provided by the government, click here to visit: http://www.cpsc.gov/about/cpsia/faq/faq.html .

The full CPSIA legislation as well as general counsel letters of interpretation are available at: http://www.cpsc.gov/about/cpsia/cpsia.html .


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2) SMALL PARTS LABELING: IF YOU ARE SELLING ANY OF THESE MUDPUPPY FORMATS, PLEASE READ ON:

Sticker Set Play Scenes
Advent Calendars
Learning Wheels
Magnetic Figures
Mini Sticker Set Play Scenes
As of December 12, 2008, any advertising for these products must show an ASTM Small Parts Logo:

You may Download this image by right clicking on the image and select "save as."

Please use this image on your promotional material. This includes flyers, websites, catalogs, brochures, etc.

As you may know, the Consumer Product Safety Improvement Act of 2008 (CPSIA) set out new Labeling Requirements for products with safety warnings. In the case of Mudpuppy products, only the formats listed above require that a safety warning be shown in any advertisement for the product. This includes flyers, websites, catalogs, brochures, etc.---anything that is intended for direct-to-consumer sales.

  • Printed advertising that is printed after Feb 10, 2009 must be compliant. Retailers may continue to distribute advertising that was printed prior to this date through August 9, 2009.

  • The requirements as to size of the logo are complicated and vary according to the size of the advertisement. However, as a rule of thumb,the ASTM Small Parts Logo must be at least equal to the size of the largest text in the advertisement that describes the function, use, or characteristics of the toy or game advertised.

  • For the Internet, the logo must be located immediately before any other statements in the advertisement that describes the function, use, or characteristics of the toy or game being advertised. This avoids the logo being placed below a scroll bar.

    Here is the link to the Consumer Products Safety Commission website, which has the complete legislation as well as summaries of the various sections. For full details regarding advertising requirements, see section 105 (page 16) of the full pdf of the legislation available on this page.


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    3) CERTIFICATES OF CONFORMITY

    In addition, we are now required to provide all distributors and retailers access to a Certificate of Conformity for each product.

    This certificate contains details about the safety testing that each print run of each product has passed, and certifies that it is in compliance with CPSC and ASTM requirements. These COC are required only for products manufactured or imported since November 12, 2008. Existing stock will not have a Certificate of Conformity, but we are in the process of posting additional test information.
    Click here to access PDF versions of these documents. pdf logo links to safety documentation


    Thank you.


    ---Cynthia Matthews, Creative Director for Mudpuppy
    ---Janice Ostendorf, Production Manager


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