Zhu Zhu Pets and Hazardous Substance Process Management

On Dec. 4, a California-based consumer watchdog group announced that testing performed by them on the enormously popular Zhu Zhu Pets showed that levels of the heavy metal antimony were in excess of federal limits. In an announcement picked up by national media, GoodGuide stated that their tests on Mr. Squiggles, performed using a NITON XL3t series X-ray fluorescence (XRF) scanner, had detected antimony levels of 93 to 106 parts per million, way in excess of the federal standard of 60 parts per million.

Two days later GoodGuide had to backtrack on its claims. The problem was that GoodGuide had used a different testing method than that used by the U.S. Consumer Product Safety Commission (CPSC). The method used by GoodGuide measured the actual amount of antimony detected in the scanned area whereas the CPSC test protocol looks for the amount of soluble antimony available if, say, a child were to stick a toy in his mouth.

According to reports, the CPSC itself did not test the toy, but relied on the results of third-party product testing performed by Bureau Veritas and provided to the CPSC by the toy’s manufacturer, St. Louis-based Cepia LLC. The results indicated that there was only trace amounts of soluble antimony.

All of this confusion over testing methodologies and whether a company did or did not use applicable product testing standards could have been avoided, and is being avoided in certain industries, through the use of a hazardous substance process management (HSPM) standard such as IECQ HSPM QC 080000, according to Stan Salot, president of the Electronic Component Certification Board (ECCB), U.S. representatives of the International Electrotechnical Commission. Rather than relying strictly on test results, HSPM looks at the technical aspects of the entire design and manufacturing process, much like ISO 9001 looks at the quality aspects. And the theory is the same, says Salot. In the same way that you can’t test quality into a product, you can’t test hazardous substances out of product. You must control the process, explains Salot.

“The real issue is that product [safety] acceptance is still based on testing and not on process management,” says Salot. “A factory can submit 10 units for testing and every one of them can pass and when the next batch is made they can fail, and chances are that no one would know until they are found to have caused a problem; or some random sampling, such as that done by GoodGuide, was performed. Unless the CPSC took the same units that GoodGuide tested and ran them through the same or equal test you really can not say that either group is right.”

In other words, even though the tests were different, who is to say if either group’s claims are right or wrong; that’s the nature of sampling. If GoodGuide had access to Bureau Veritas' 48 sample units, or vice versa, perhaps the results would have been different for both sides. The only way to truly control the outcome of a process, says Salot, is to control the entire process, which is the goal of HSPM.

“At the end of the day, everything that is made goes through a process and anything less than process certification that is validated with agreed testing methods is subject to failure,” says Salot. “Depending on how strongly you feel about the subject you could say we are playing Russian roulette when we suggest that testing is the answer.”

About The Author

Dirk Dusharme

Dirk Dusharme is Quality Digest’s editor in chief.