CPSC Grants Exception to Lead Limit for Kid’s Ride-on Tractor
The Consumer Product Safety Commission (CPSC) said it is granting an exception to the 100 ppm lead content limit for certain aluminum alloy components of children’s die-cast, ride-on pedal tractors, and similar component parts made of aluminum alloy on similar ride-on children’s products for children ages 3 years and older. Such products may include other children’s ride-on tractors, children’s ride-on cars, and other ride-on toys, the CPSC said. These aluminum alloy components must meet a lead content limit of 300 ppm. The exception will take effect on or around June 5.
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The agency was acting on a September, 2011 petition by Scale Models and Dyersville Die Cast requesting an exception from the 100 ppm lead content limit under section 101(b) of the CPSIA for its die-cast, ride-on pedal tractors, scaled for children ages 3--10 years. Under section 101(a) of the CPSIA, consumer products designed or intended primarily for children 12 years old and younger that contain lead content in excess of 100 ppm are considered to be banned hazardous substances under the Federal Hazardous Substances Act (“FHSA”). But Section 101(b)(1) of the CPSIA provides for a functional purpose exception from the lead content limits, under certain circumstances, the CPSC said.
The petitioner said that obtaining aluminum alloys at 100 ppm or other substitute alloys was not practicable. The use of another metal alloy, such as steel, or using plastic molded component parts was not practicable either because it would result in completely retooling the manufacturing process and result in products that appeared different from the current product, which uses die-cast component parts.
Agreeing with the petitioner, the CPSC said it was it granting the petitioner’s children’s ride-on pedal tractors made with aluminum alloys an exception from the 100 ppm lead content limit, and allowed to have a lead limit of 300 ppm instead, because “it is not practicable to impose the lower lead limit on such aluminum alloys.” Also, those aluminum components including body castings (right and left sides), rear wheel hubs, wide front axle yokes, wide front-end adaptor brackets, and other component parts that are similar to these parts are “not likely be placed in the mouth or ingested or extensively contacted by children because of their function and location on the product,” the agency said.
(See ITT’s Online Archive 12032239 for a summary of the proposed CPSC vote on the lead exception petition.)