Malcolm Denniss serves as Technical Director for SGS Consumer Testing Services

As you no doubt already know, the CPSIA mandated third-party lead testing on a phased-in schedule that began on December 22, 2008, as part of new limits imposed on lead content in toys and other goods. Those regulations will reduce the permissible lead content in paint and surface coatings from the current 600 parts per million (ppm) to 90 ppm on August 14, 2009. They also cap lead content in the product itself at 600 ppm—effective this month— with lower 300 and 100 ppm limits taking effect on August 14, 2009, and August 14, 2011, respectively.

Knowing how to interpret safety test reports can help ensure compliance with these more stringent thresholds, as well as with the long-standing regulations on soluble heavy metals under the ASTM F963 Standard Consumer Safety Specification on Toy Safety designed to prevent children from ingesting toxic metals from sucking on a toy.

Retailers should receive test reports on a given toy or other children's product on initial shipments and at regular intervals. The reports typically will include a basic pass/fail summary on each substance evaluated. In addition, they should include detail sections listing the specific findings for each substance. These numbers may reveal a potential problem even if the test result is acceptable.

Consider this scenario: You receive a test report that shows a lead content of 400 ppm in purple paint on a plastic dollhouse. As of today, that result falls within the 600 ppm limit. But as of August 14 when the lower 90 ppm cap takes hold, that toy will be nowhere near making the grade. If it's still on your shelf and you sell it to your customers, you will be in violation of the law based on recent opinions concerning responsibility for existing inventory by general counsel for the Consumer Product Safety Commission.

Conscientious review of test reports can help ward off trouble, both in the short and long term. Here are a few simple guidelines for use in protecting yourself.

1. Read the fine print. A pass/fail mark doesn't tell you everything you need to know. Your testing organization should also list the specific levels of lead in each paint color in the specimens tested as well as the measured amounts of all soluble heavy metals covered under ASTM F963, including antimony, arsenic, barium, cadmium, chromium, lead, mercury and selenium. These detail reports clearly show the allowable limits of each substance, making it easy to see whether the item in question passed with flying colors or barely squeaked by.

2. If a test report does not have a detail section, demand one. Without getting into the nitty-gritty of the test results, you're going to get only limited value out of the report. A reputable third-party testing organization should be willing to provide full disclosure.

3. Question any substance that clocks in at more than half the allowable limit. Most of the metals tested should be barely detectable under ordinary circumstances. Trace amounts may show up, but anything that hits the halfway mark typically indicates some kind of contamination in the manufacturing process. For lead in paint, for example, a typical result even at today's 600 ppm limit would be 10-30 ppm. Higher levels should sound an alarm.

4. Ask for a prompt explanation. While there is no need to panic if a particular finding looks suspicious, immediately notify your supplier or vendor. Indicate that you have noticed a test result that is higher than you would expect, and ask for a review of processes and incoming materials that might have caused contamination in the lot. Then be sure to follow up to ensure that potential sources of contamination have been investigated, identified and corrected.

5. Think in terms of tomorrow's lead regulations, not today's. As previously mentioned, one of the virtues of vetting test reports now is the potential for nipping future problems in the bud. If a certain item passes today's lead limits by only a slim margin, it's a signal that there's trouble ahead when the new lower ceilings take hold. Flagging the problem now gives the manufacturer time to fix it before both you and the vendor run afoul of the regulators.

6. Get ready for phthalates. As of Feb. 10, 2009, six phthalates used to soften plastics and cosmetics are banned either on a permanent or interim basis for toys or child care articles that can be placed in a child's mouth for activities like teething and sucking. Third-party testing for these substances is mandated as of September 2009. At that point, vigilance will be required for this data set on the reports as well.

Think of it this way: A questionable test finding is like a canary in a coalmine. It can alert you to problems before they turn into disasters, regulatorily speaking. With basic oversight, retailers may be able to detect lead and soluble heavy metal levels that are acceptable today but will be out of bounds in a just a few months.

The same principle applies after the revised safety standards go into effect. Any higher-than-normal heavy metal result could signal contamination caused by a change in the manufacturing process. The sooner this is recognized, the faster the problem can be resolved and the lower the risk of product recalls due to heavy metal contamination.

It's the old story: An ounce of prevention is worth a pound of cure. Take a few minutes to drill down to the details on your test reports; you may prevent months of trauma down the road.