LAS VEGAS—In response to the recently passed Consumer Product Safety Improvement Act of 2008, The Vision Council released voluntary lead guidelines to its members during Vision Expo West. The guidelines, noted James Shyer, COO, Zyloware and head of the Vision Council’s Eyewear and Accessories’ division, “were developed as an informative document to help optical manufacturers understand and comply with federal regulations on lead.”

The law significantly reduces the amount of lead allowable in toys and products manufactured for children age 12 and under; the guide provides optical manufacturers with information to help them assess the appropriate course of action to comply with the law.

The result of a task force of the eyewear division established last year, the Vision Council’s lobbying efforts in Washington and other technical and legal input, the guidelines are the result of a desire for The Vision Council “to be proactive on this issue,” said Shyer, who pointed out that ANSI standards and regulations already in place under the Federal Hazardous Substances Act have long applied standards for toxic and hazardous substances for frames and sunwear, which meet the federal regulation standard for minimum lead thresholds of 600 parts per million (PPM) by weight.

However, as a result of the recently enacted Consumer Product Safety Improvement Act (CPSIA) of 2008, the new maximum limit of lead in toys and children’s products is to be reduced to 300 PPM beginning one year after the enactment of CPSIA (Aug. 14, 2009) and then to 100 PPM in three years from enactment (Aug. 14, 2011).

In its statement The Vision Council said, “eyeglass frames and sunglasses, even if sold into the children’s market, are outside the scope of the CPSIA’s new restrictions on lead and testing requirements. VC’s members’ products are considered medical devices and regulated by the Food and Drug Administration.”

Therefore, the CPSIA rules do not require optical manufacturers to test their products. However, suppliers could be subject to recalls and monetary penalties if products were found to exceed established levels. As a result, testing is an option for suppliers.

There are options for recommended third-party testing facilities that The Vision Council can advise its members about within the new issued guidelines document. Further, The Vision Council notes that care should be exercised in regard to written and verbal claims since false or misleading claims are prohibited by federal regulation. It’s recommended, the guidelines document noted, that companies use accurate language in labeling regarding lead content and avoid use of such terms as: “lead free,” “lead safe,” and others.

“We are very confident that The Vision Council members are operating well within the current lead content guidelines, but we have done a lot of work and research to monitor the situation,” Shyer said.

Ed Greene, CEO of the The Vision Council, added, “This guide is only the starting point and our legislative, regulatory and technical standards staff remains ready to help continue to navigate through the process.” ■