John Baymore on sun 12 apr 98
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=3Csnip=3E
You wrote: =3C=2A=2A=2A=2A=2A My glaze was tested by the
government ...some guy showed up and said he was going to test it wether
I approved or not=21 So now I have a signed, government statement on my
wall that my glaze is safe=21=3E
I am interested in how this happened? Where did it happen? Did he show up
at
your studio? What department of the government was he from? State,
Federal,
Local? Did he explain how he found you and why he was testing your glaze?
And what did he test it for?
=3Csnip=3E
Along this line, here in NH this situation happened a few years ago.
The local office of the FDA (who DOES have full jurisdiction over
enforcement of the federal lead and cadmium standards) contacted the NH
Potters Guild and asked to have its mailing list. A form was sent out to
all members on the list that required information on materials and
processes used, types of ware produced, total volume of production and so
on. From this information the FDA obtained, some potters were visited and
ware was obtained by them and tested.
The officers of the Guild who released the mailing list to the FDA took a
LOT of heat from some of the members of the Guild. It became a big
=22brou-ha-ha=22 in some circles, and was a real pain for the officers. =
Seems
that some people felt that the officers had no business giving the list to
the FDA. Go figure?
This situation resulted in changes in how our mailing list is handled......
we now have a =22member listing=22 which is not routinely available for use =
by
anyone except the officers for official business, and a distributable
=22mailing list=22 onto which you can opt to have your name placed. I am =
not
sure how the officers would now treat another =22official request=22 from =
the
FDA again =3Cg=3E.
Personally, I have no problem with the FDA testing potters wares. All
manufacturers of pottery are governed by these laws equally. If the FDA
wants to test your ware, they have every right to do that under federal
law. If you are doing your job, you have nothing to worry about. No big
deal.
If you aren't...... then you do have a problem.
The standards are available for study from the FDA. They are not hard nor
necessarily expensive to comply with. The easiest and no cost way is to
not use lead or cadmium bearing materials. If you do use these materials,
then you'd best have the knowledge to use them safely, for both yourself
and the consumer. One thing that you have to do if you do use them is
routine product testing. That is the intent of the laws.
Also, if you live in California, there are more stringent state laws the
apply to lead. So the State there has jurisdiction also. (Ditto if you
ship your pots into CA.)
BTW.... in answer to another post on this general theme of leaching....
Standard 24 hour leach testing costs about =2420-=2425 per element per test
(depending on the lab and the volume of tests done). So to test one
product sample for both lead and cadmium release (2 elements) would cost
about =2440-=2450. Like most things, if you have a regular relationship =
with
the lab and do a lot of work there the price can go down a bit on the
volume business.
If you do use these two materials, having the long term recorded results of
a regular product testing program available would be a good defence in a
product liability suit or in the case of any FDA investigation into alleged
non-compliance.
If you are in doubt as to the exact content of some of the materials you
use (like commercial products such as glazes, underglazes, overglazes, and
so on) ask your suppliers. Get a Material Safety Data Sheet on the
product. Lead or cadmium content will be indicated there. If either or
both is in there, YOU are responsible for its use on your work in
compliance with the law(s).... not the manufacturer. The manufacturers do
not supply any indemnification on this stuff.
Best,
........................john
John Baymore
River Bend Pottery
22 Riverbend Way
Wilton, NH 03086 USA
603-654-2752
JBaymore=40Compuserve.com
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