MY VERY OWN® Rattle, manufactured in Morrisville, Vermont, USA,  is exempt from all 3rd party testing requirements under CPSC regulation.
As a Small Batch product (CPSC Small Batch Registration Number 018102-022019), it is exempt from annual testing for mechanical and toxic hazard.
     MY VERY OWN® Rattle greatly exceeds CPSC standards for resistance to breakage and deformation resistance.
See mechanical safety requirements below  

Small Batch Manufacturer Registration Number: 018102-032023
Reference: Small Batch Manufacturers and Third Party Testing (CPSC page)
Current Batch Number: 2301

     MY VERY OWN® Rattle is not subject to the mandatory requirements for testing for Lead and Phthalates required by CPSIA2008, because the product to be used by a child is unfinished, untreated, natural wood, unaltered from its natural state.  This statement has been confirmed by the CPSC Ombudsman, Will Cusey.  

     MY VERY OWN® Rattle was tested for CE (European Union) compliance in 1995 and is CE Certified, demonstrating absence of Lead, Phthalates, and other toxins above specified limits. The standards are essentially similar to that of CPSIA 2008, and also include testing of the packaging.

    The following paragraphs regarding testing for chemical hazard  were excerpted in 2008 from “Frequently Asked Questions” on the website of STR Testing Laboratories, a CPSC accredited laboratory.  STR is now part of Underwriters Laboratories, Inc. These statements are essentially equivalent to the current CPSC language.

   “…(T)he CPSC exemption for wood applies to both natural and treated wood. However, accessible surface coatings on wood do require testing for lead.

   “The CPSC’s Final Rule regarding lead content limits of certain materials or products exempts from lead testing include paper and similar materials made from wood. The exempted materials include, but are not limited to, paperboard and linerboard and coatings on such materials which become part of the substrate, provided that no materials have been added that could result in the introduction of lead in the product. Note that while these materials are exempt from testing, they still must comply with the lead limits.

    “The CPSC has determined that certain natural materials do not typically exceed the lead content limits and, while compliance is required, testing of these identified materials is not. These natural materials include wood, precious gemstones (diamond, ruby, sapphire, emerald) and certain semiprecious gemstones, natural fibers, such as cotton, silk, and wool, and other natural materials such as coral, amber, feathers, and fur.

 “Are there any materials that are exempt from phthalates testing?
   "The CPSC said in its Statement of Policy regarding testing of component parts for phthalates (August 7, 2009) that the following materials do not normally contain phthalates and, therefore, might not require testing or certification: unfinished metal; natural wood; textiles made from natural fibers, such as cotton or wool; textiles made from common synthetic fibers, such as polyester, acrylic and nylon; polyethylene and polypropylene (polyolefins); silicone rubber and natural latex; and mineral products, such as play sand, glass and crystal. However, if these materials are treated with coatings, adhesives, printed decorations, elastic materials or any other surface treatments, an exemption would not apply." 

For the complete text of Regulation 16 Part 1510,  visit Full Regulatory Text of 16 CFR 1510 

CPSC Business Guidance for Rattles: http://www.cpsc.gov/en/Business--Manufacturing/Business-Education/Business-Guidance/Rattles/ 

Read more about choosing a safe toy at http://loewenton.org/lead-hazard/Toy-Hazard_20080320.htm 

Top Of Page

   
     We have noted around the internet that some rattles are offered for sale that may not be in compliance with Consumer Product Safety Commission regulations intended to minimize the risk of choking caused by products intended for infant teething.

     Below is the relevant excerpt regarding rattle end sizes allowed or banned by CPSC regulation 16 CFR (Code of Federal Regulations) Part 1510

Section 1510.3 No portion of a rattle, when tested in accordance with Sec. 1510 below, shall be capable of entering and penetrating to the full depth of a cavity in a test fixture with dimensions shown in fig. 1.
There is a general misunderstanding among consumers, and even some of the smaller toy producers and retailers, that the "small parts test cylinder" is the appropriate test device for all products intended for use by children under 36 months of age.       Note that the the test cylinder shown at right is not intended for testing teethers, pacifiers, and other products whose main use is sucking, chewing, or mouthing by infants.       The standard cited above for rattles, and the fixture for testing compliance with that standard, are more stringent than for other children's products.	The Small Parts Test Cylinder  (1.25" diameter) is not intended for testing teething toys

     Reducing this requirement to simple dimensions, a rattle end must be at least 1 11/16" (1.688") in diameter. The actual combination of largest diameter and shape will determine the compliance of the product with this regulation, and for certainty it is best to use the test fixture. 
MY VERY OWN® Rattle complies with this regulation, while keeping the weight of the toy within limits suitable for handling by a small infant. Spherical ends, for example, might be in compliance, but would be significantly heavier.

     We have seen some very attractive wooden rattles offered for sale, one end of which was a long, thin handle intended for grasping by the infant. This shape would almost certainly be non-compliant.

**************************************
  

Top Of Page