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Mattel QSOP-phthalates

QUALITY AND SAFETY

?Polystyrene (PS) including HIPS, SHIPS, etc.

?Styrene Butadiene Copolymer (SBC)

1External laboratories may use alternate means to determine if a plastic part qualifies for

this exemption.

1.2.6 Inaccessible portions of Power Wheels batteries

1.3 Definitions (Words that are defined are italicized and bolded once per section)

Accessible: Any area of the product that can be contacted by any portion forward of the collar

of the accessibility probes when inserted to the depth determined in QSOP 0006-3010,

Accessibility.

Novelty Books: Books that include internal and/or external play features involving interaction

more than simply reading. The book may incorporate plastic, metal or electronic components

and may contain play features, take along toy activities or crafts.

Ordinary Books: Books published on cardboard or paper through conventional publishing

methods solely intended to be read. Novelty books are not considered ordinary books.

Promotional Items: Items provided to the consumer to promote a product or brand. These

items may or may not be included in, or with, a product. Examples include items such as

booklets, catalogs, bookmarks, growth charts, and posters. In some instances, a promotional

item may be an actual product in package that is given away.

Surface coating: All layers of materials such as paint or similar, that dries to a solid film when it is applied to a surface and that can be scraped off with a sharp blade or washed off with a

solvent such as acetone or ethanol, without removing substrate (base) material. NOTE: For the purpose of phthalate testing, inks which are not absorbed into the substrate, should be removed and tested separately. Inks which are absorbed into the substrate should be tested along with

the substrate (if the substrate is within the scope of this QSOP). Glitter coatings, including those applied to fabric, should be tested as a surface coating.

1.4 Purpose

To evaluate products for compliance to worldwide safety standards for plasticizer content

2 PERFORMANCE REQUIREMENTS

Performance requirements must be met both before and after all applicable Use and Abuse testing.

2.1 Accessible Materials in Products, Accessories or Peripherals Intended to be Used

Exclusively by Adults

Must contain less than 0.1% (1000 ppm) by weight of each of the following plasticizers:

?Di (2-Ethylhexyl) Phthalate (DEHP) CAS No. 117-81-7

?Benzyl butyl Phthalate (BBP) CAS No. 85-68-7

?Dibutyl Phthalate (DBP) CAS No. 84-74-2

?di-“isodecyl” phthalate (DIDP) CAS Nos. 26761-40-0 and 68515-49-1

?di-n-hexyl phthalate (DnHP) CAS No. 84-75-3

?di-“isononyl” phthalate (DINP) CAS Nos. 28553-12-0 and 68515-48-0

2.2 All Other Accessible Materials

Must contain less than 0.1% (1000 ppm) by weight cumulatively (added together) of the

following plasticizers:

QSOP 0006-3610 AC Page 2 of 8

?Di (2-Ethylhexyl) Phthalate (DEHP) CAS No. 117-81-7

?Benzyl butyl Phthalate (BBP) CAS No. 85-68-7

?Dibutyl Phthalate (DBP) CAS No. 84-74-2

?Diisobutyl phthalate (DiBP) CAS No. 84-69-5

And less than 0.1% (1000 ppm) by weight cumulatively (added together) of the following

plasticizers:

?di-“isononyl” phthalate (DINP) CAS Nos. 28553-12-0 and 68515-48-0

?di-“isodecyl” phthalate (DIDP) CAS Nos. 26761-40-0 and 68515-49-1

?di-n-octyl phthalate (DNOP) CAS No. 117-84-0

And less than 0.1% (1000 ppm) by weight of di-n-hexyl phthalate (DnHP) CAS No. 84-75-3

2.3 All other Inaccessible Materials1

Must contain less than 0.1% (1000 ppm) by weight cumulatively (added together) of the

following plasticizers:

?Di (2-Ethylhexyl) Phthalate (DEHP) CAS No. 117-81-7

?Benzyl butyl Phthalate (BBP) CAS No. 85-68-7

?Dibutyl Phthalate (DBP) CAS No. 84-74-2

?Diisobutyl phthalate (DiBP) CAS No. 84-69-5

1Additional abuse testing should not be performed on inaccessible materials

2.4 Modeling Clay

The requirements for modeling clay are the same as those of §2.2 except that modeling clay

must contain less 0.01% (100 ppm) by weight of di-n-hexyl phthalate (DnHP) CAS No. 84-75-3

2.5 Additional Information

Only the following plasticizers may be used in accessible materials, except for insulation on

current carrying wires that are accessible before and after use and abuse testing:

?Citroflex A-4 available from Vertellus (Morflex)

?Citrofol B-2 available from Jungbunzlauer GmbH.

?Di-isononyl-cyclohexane (DINCH) from BASF

?Eastman 168 available from Eastman

?TXIB ( 2,2,4-trimethyl-1,3-pentanediol diisobutyrate)

?GLOBINEX W-230-S from DIC

3 PROCEDURE

3.1 Environment (Not Applicable)

3.2 Equipment

Reference GLOP 0006-7420, Determination of Phthalates for equipment

3.3 General Requirements

3.3.1 If feasible, samples are to be tested in the same form they appear on the finished

product, e.g. paint is tested in the dry state

QSOP 0006-3610 AC Page 3 of 8

3.3.2 Colors or materials can be combined if they cannot be physically separated. This is not

considered composite testing. For example, glues or adhesives that can not be

physically separated from the substrate (e.g. adhesive on a paper label) should be tested

together with the substrate.

3.3.3 For surface coatings, a composite sample (of no more than 3 materials) is also allowed

3.3.4 Composite testing, when permitted, must meet the following criteria:

?No more than 3 samples may be used

?Equal weights of each sample should be used

?Compositing must be done using similar materials with similar properties

?Data must be evaluated to ensure that a failing result is not masked. Evaluate as though the entire concentration of the composite sample is coming individually from a

single sample. Evaluate each sample in the composite in this fashion. Internal labs

should use GLOP 0006-7420, Determination of Phthalates as guidance

3.3.5 Test frequency is per the following:

?GQMP 0006-2116, Phthalates Control for Mattel Owned Operated Plants

?GQMP 0006-2117, Phthalates Control for Mattel OEM and Specialty Vendors

3.3.6 For books, follow Appendix 2 to determine which components are subject to testing.

3.4 Method

3.4.1 Mattel Internal Labs

Must follow GLOP 0006-7420, Determination of Phthalates

3.4.2 External Labs

Perform extraction and analysis of phthalates using any validated method described in

the US Consumer Products Safety Commission (CPSC) document CPSC-CH-C1001-

09.2

3.4.3 Follow Appendix 1 if sufficient sample to conduct the testing cannot be collected from 12

samples.

4 HISTORY

4.1 Significance

Documents Mattel policy for phthalate content

4.2 Reason For Revision

4.3 Referenced Documents

The following documents contain requirements related to this procedure:

?TMA Voluntary Standard for the reduction of DEHP.

?ASTM D3421-75, Extraction and Analysis of Plasticizer Mixtures from Vinyl Chloride Plastics.

?2005/84/EC

?BS EN 14372:2004, Child use and care articles – Cutlery and feeding utensils – Safety requirements and tests

?Directive 2005/84/EC, the 22nd amendment of European Directive EN 76/769/EEC relating to restrictions on the marketing and use of certain dangerous preparations ?European Commission Directive 2004/93/EEC, amendment to Cosmetic Directive 76/768/EEC.

?Japanese Food Sanitation Law, Section 4 - Toys

?California Safe Drinking Water and Toxic Act of 1986 (Prop 65)

?California AB 1108

?Consumer Product Safety Improvement Act (CPSIA) of 2008

?Canadian Hazardous Products Act –Phthalates Regulations December 9, 2010

5 FREQUENTLY ASKED QUESTIONS

Q. Are all chargers considered “Accessories, peripherals, and products that are intended to be used exclusively by adults” exemption?

A. No. Some chargers are intended to be used by children. Others, such as chargers for Power

Wheels, are intended to be used exclusively by an adult. These chargers would be tested

according to §2.1.

Q:Please provide some examples for footnote of section 2.3 --“Additional abuse testing should not be performed on inaccessible materials”

A. Inaccessible materials within the scope of the procedure must be tested for the 4 phthalates listed

in this section. The footnote was intended to prevent someone from performing additional abuse testing on parts that become accessible after initial abuse testing. Here are two examples that

should clarify things:

Example 1) A toy car contains a speaker that is inaccessible. The car is subjected to abuse

testing and there is no damage or breakage of the car. The materials that are accessible and

within the scope of the QSOP (e.g. PVC windshield, tires made of synthetic rubber, etc.) are

tested for eight phthalates per section 2.2. All inaccessible materials that are within the scope of the QSOP (e.g. adhesive holding a speaker wire, the wire insulation, etc.) are tested to section

2.3 for the four phthalates listed in that section.

Example 2) A toy car contains a speaker that is inaccessible. The car is subjected to abuse

testing and a piece of the car chassis breaks off. The insulation on the speaker wire can now be contacted by the accessibility probe. This insulation is now subjected to the requirements of QSOP 0006-3610 AC Page 5 of 8

section 2.2. The speaker can now be contacted by the accessibility probe, but the adhesive on

the speaker cannot be touched by the accessibility probe. The adhesive on the speaker must

meet the requirements of section 2.3 only (DEHP, DBP, BBP, DiBP). No further abuse testing is done on the speaker simply because it is now accessible.

6 ATTACHMENTS

QSOP 0006-3610 AC Page 6 of 8

Appendix 1

Phthalates Sample Size Requirements

Considerations:

?When testing a surface coating together with the substrate, select a portion of the sample which maximizes the amount of surface coating to be tested

?Applicable for surface coatings and substrates

QSOP 0006-3610 AC Page 7 of 8

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