 Panels can introduce topics, raise questions, answer questions, and anyone from the audience that would like to ask questions, we highly encourage that. Just come right up to the podium. You can stand here and interject, and we hope it goes from there. So we'll start. Dave, why don't you introduce yourself and we'll go down the line. Hi, I'm Dave Owen. I'm a technical service specialist with BASF, Industrial Petrochemicals, Plasticizer Group. I'm also the task group chair for ASTM D207002, the low-level phthalate determination and vinyl task group. Hi, good afternoon. My name is Marcy Kinter. I'm the vice president of government and business information for the Specialty Graphic Imaging Association, or SGIA. I'm here representing those that pay for the tests. I'm that customer base that has to send you the samples and get the test results and to talk a little bit about some of the problems that we're seeing from the test labs as we are getting the phthalate test results back. I'm Bob Altcorn. I'm a senior technical advisor with InterTech. My background is in physical and analytical chemistry, and I brought some data regarding our phthalate testing results. If anyone's interested, I originally thought we were going to be giving presentations. Hi, my name is Sanjeev Gandhi. I'm technical director for SGS, Consumer Testing Services, based in New Jersey. I'm a technical team lead for a group of about eight people who are product sectors experts in different areas that we are involved in. What does that mean? I spend all day in meetings. All right, I'll give you guys some seed questions and try and get the ball rolling. We're very curious. Our method allows for a number of different methods. As we've seen today, there's constantly new technologies and methods coming out. We're curious as far as method comparisons. Why do you like one method over another? Do you see certain advantages over ways you do it versus the way you see other people do it? Anything along those lines, I can give people more perspective of what advantages and disadvantages we have to look for in different methods. Yeah, I think somebody mentioned earlier today, GCMS, which is the existing method widely used, is the benchmark against which we are going forward. Both in terms of the level of speciation we need to really segregate those band, phthalates, and whether they are within the regulatory, below the regulatory limits. That's what needs to be confirmed or validated through the testing. A lot of the technologies that we heard about today, certainly very exciting. We haven't really heard about those technologies in a forum like this before. I don't happen to go to Pitcon every year, so maybe that's my limitation. But it looks very exciting. I think one thing that surprised me during the sessions earlier today was nobody asked after those exciting technologies. And as they were being described, nobody asked, are we there yet? So I think that's the question we need to answer. Certainly that's the question that I'm hearing because I just came from Orlando at the Expo conference that was taking place. I met a lot of customers that work with test labs. And the cost is a concern to them, and they are looking for a solution. I think once you will talk more about that, and perhaps more forcefully than I would. But basically that's where the plastic meets the road. So hopefully we'll get to hear about that through the rest of the discussion today. We're primarily, again, using GCMS back. We also certainly are sensitive to the cost of this. We have a number of concerns about some of the methods that are proposed. Certainly, for example, FTIR has been used in plastics additives analysis for quite a long time. One of the most sensitive analysis is through transmission, typically through thinner thick films. We tried to see in preparation for this meeting, where are we seeing failures? And hopefully this provides some guidance on ways to move forward. So we did a kind of a long, large sample survey of failures and then a more recent, smaller scale survey of extent of, I shouldn't say failure, non-compliances. So over several years we're seeing a non-compliance rate on the order of 4%. And in many cases, I would say in most cases these involve plastics that are not identified to us by the customer. So in some cases you can tell what the plastic is easily, certainly if it's PVC. In some cases it's more difficult, but one of our, I'd say one of our goals would be to make sure that screening techniques or improved quantification techniques are compatible with the types of materials that are actually showing up as non-compliances. And based on a shorter survey of non-compliances, we found about half in recent months were in the 0.1 to 1% range. So if you look at earlier data, including published data, it indicates a much higher level of phthalates. But based on our recent data, getting to low levels is more important. DEHP was the phthalate that was present the most and DINP second. I guess some general concerns we had about screening methods in particular. One that was already addressed, the general lack of certified reference materials or standard reference materials, like how do you know your analytical technique is performing as it should be. Dr. Dreyfus pointed out that there is I guess a vinyl, sorry, polyethylene SRM in preparation. Other concerns are certainly with the spectroscopic methods. In practice pretty much all polymers contain additives. So in addition to plasticizers, they might be fillers, colorants, flame retardants, stabilizers, lubricants. So can you identify those? Do they cause interference problems with the phthalates? Some of our customers have raised issues of how do you test small area? Samples or say a design on a product that's very small. Can you get the spatial resolution? Right now you can do compositing to at least in some cases reduce cost. Is that a possibility with the screening methods? Is it needed as a possibility? I think a lot of the potential solutions presented here today are very specific to individual pieces of equipment. We certainly don't have any problem with that, but based on what we read in preparation for this meeting, when you have something like FTIR, there are a lot of different sampling techniques, there are a lot of different qualities of FTIR instruments. It's been commercially available since, say, 1979, 1978. Is everyone, you know, is my old FTIR going to be as good as your new FTIR? To what extent does the technique depend on operator experience? And I think that was also addressed by some of the presenters today. Anyway, those were our potential, at least, questions. So, yeah, I mean, those are the issues that we're most concerned about going forward. And I would say that, you know, if anybody here is interested in working with us, then, you know, please let me know because we're looking for a solution and we would like to work with you on these and other issues. Well, to qualify, I'm not a chemist and do not have a chemical background. But I will say, based on the feedback, and I'm talking primarily about ink manufacturers that have to get their products tested because they contain phthalates. And obviously, the goal is to get the banned phthalates out of the products and you have to replace them with something. There has to be some functionality that's still in that product in order for it to perform as everyone expects it to. And we've really seen that's been one of the bigger issues. We've also seen that there's a little stability between testing labs in the results. We have one company that indicates that they just don't even have a confidence rate in their lab. They don't see that the test results are coming back verifiable. And that, to us, is very troubling. We see that false positives are an ongoing problem. We also see that some of our alternatives that we're using are coming back and failing. Because, and I will be honest with you, that whole portable technology that just goes red and green scares me to death because we're not looking to ban anything more than those six phthalates. And that's my policy issue right now, is that we're really looking to only take out those six. And I believe, quite honestly, when I was listening to the chap that went on a week ago, was it a week ago? They were also discussing whether or not they could issue or recommend interim bans on other phthalates that were not of the six and they were told that, no, that was really not an option. So I want to be very clear that when you start talking about portable technology that just does a red or a green based on total phthalate concentration, you're really talking about a disruption in the market chain. And that truly, truly is an issue. We have one company that estimates that on an annual basis they may pay up to $5.5 million in testing a year. $5.5 million and they took the phthalates out of their products. So they are now testing products that have none of the six banned phthalates in them. So that's just a whole other issue. So when you start looking at some of the resolutions, I agree with my colleague here on the panel, rather than rushing forward and looking at alternative testing techniques such as the portable handheld, I'd really like to see some of the issues that we're seeing with the test method resolved before moving forward. Specifically looking at and making sure that some of the, I guess, replaced phthalates are not seen as those that are banned. So that when we start looking at reformulation, we're actually doing what the legislation asked us to do, which is to take the six banned phthalates out and to reformulate. We've also found within the testing labs that there does seem to be a requirement that when you are looking at the introduction of an alternative phthalate that there has to be some sort of manual integration done. And there has to be extra steps taken that not all labs, testing labs, are willing or able to do. So there has to be that extra step so that rather than just going past fail, they're actually taking a look at the product and making sure that with the knowledge and understanding of what's in that actual sample, they're able to differentiate and hopefully to pass a product that does not contain any of the six banned phthalates above the limit. We also find that the tests differ based on the labs. We will send one sample to one lab and it will pass and we will send the identical sample to another lab and it will fail. So that also is very, very concerning to us as a customer base because we're looking at $375 a test and when you go up to your final customer and then they require you to continue to test and one lab fails and one lab passes, it gets to be a very expensive proposition. And again, this is one of the elements that we really haven't touched upon here today is the whole element of the cost of the testing and the fact that if you do not have a test method that adequately looks at the product and adequately delineates whether or not you have a good, as I say a good or a bad phthalate, then you continue to have to test and it does get extremely costly. And we are not talking about multi-million dollar companies that have that kind of money to continue to use. So those are just some of the issues that we're seeing when we've sent out samples to the testing community. We did see obviously January 1, the testing cost just about doubled as we expected they would for both lead and phthalate. So we are concerned because we would like to see that before we move forward with other sorts of testing opportunities like handheld that we would actually take a look at the current testing methodology and make sure that it is accurate and that we are not penalized for doing what quite honestly Congress asked us to do which is to remove the ban phthalates from our products. Well, I'm going to talk from the ASTM perspective. I agree with you. Some labs had very different results and that's why I volunteered to start to develop a method within ASTM. We're not focused solely on GC mass spec type methods, but that's the one that comes out with the best results. We basically have, we've done two round robins with basically four different techniques and when we looked at variability, we found the thermal desorption method came out with the least amount of variability, so that's the one we decided to write a method on. We will probably also write a method based on solvent extraction and then, you know, again, we're not limited to just GC mass spec. I would like to also mention we do have a meeting, a task group meeting, April 16th which everyone is invited to participate in. You can go to astm.org and look up D20 meetings and see where that is and the timing. Just following up on some of those ideas, first of all I did want to clarify to Bob what in terms of the SRMs that are available, there is a polyethylene certified reference material that's available currently and what we're working with NIST for is to develop the PVC SRM, so that's in development. But one of the questions that I have is in dealing with impurities or contamination within the manufacturing process. I think in one of our first talks this morning somebody brought this up. Certainly it can be an issue in the laboratory and in the labs we're fairly familiar with how to deal with contamination issues. In the manufacturer, and I think maybe Dave and Marcy may have some insight into this as well as maybe some of the attendees. It seems to me that using perhaps some of these screening methods that we've been talking about could be a valuable tool in your shops whether the master batch and concentrate beads that are used to add color or add other additives to a product might have phthalates in them. If you're adding a 1% drop rate of a master batch that's got 30% phthalates in it, you're going to get the sort of low levels that Bob was talking about. Or similarly in an ink vehicle like Marcy was talking about, if there's an additive to that ink that contains a phthalate or something, what experience do you have in either the existence of that problem or in quality assurance methods within your shops to deal with that? We're seeing that the ink manufacturers are taking steps to develop their own reasonable testing programs. So that similar to what you're asking the children's product manufacturers to do, which is to develop a reasonable testing program with periodic testing, they are looking to develop their own reasonable testing programs based on the supplies coming in. So we start to see that they are now testing the raw materials and taking a look at what's coming in so that they can adequately determine whether or not there's any contaminants in that product. We're also starting to see that some of the ink manufacturers are totally, totally segregating the manufacturing of their phthalate versus non-phthalate ink systems. And oftentimes if they decide to go non-phthalate, which is, and that's a whole big controversial issue is what is phthalate free and how do you advertise it. When we look at those that have opted to take the six phthalates out, and we're only talking about the six phthalates right now, they oftentimes will take it out of all their products eventually so that they don't have any of that material in their facility whatsoever. We see that they are doing extensive QA, QC programs. We see that they are establishing their own reasonable testing programs to ensure the integrity of their raw materials. And this gets into a whole big issue when we start talking policy-side-wise, which I know we're not here to do today, when we start looking at how far can we extend the term batch manufacturing. Because when they start to look at the QC, QA of their raw materials, they really want to make sure that they don't have to keep testing every time they make a batch of ink. So we are looking at what we can do to ensure that the ink does have that integrity from the testing point of view, but it's not overly burdensome for the ink manufacturer because it does have that ripple effect within the marketplace. Does that answer a little bit about what you were looking at? I'm just talking from the ink manufacturer's point of view. From the end user, now the ink I'm talking about is that ink that goes on your t-shirts. We are talking about the Plastisol-based ink that goes on your t-shirts. So you are talking about textile or garment decorators. What we are finding in some of the garment decorators that I've been dealing with only print children's products. And even though it doesn't apply, it only applies in the textile world to child care articles, under three, facilitate eating and sleeping. A lot of them are opting to take it up to that next level and go all the way up to 12 and that is purely their own personal desire because it's easier for them to have one ink system within their operation rather than running two. I have talked to some textile manufacturers, some textile houses that will purchase and test ink and will put it on the shelf and say this is only for children's products. So they clearly label it that this is done and tested for children's products. And then they obviously clean everything that they have a dedicated print line just for that sort of technology. So we are starting to see that the manufacturers are also taking steps to put some QAQC into their operation based on not only their customer base but also based on their incoming materials. Well, depending on how you're making your diesters, there's a couple of techniques that we would use. If it's a non-thalate and we're sensitive about it, we would use UV-Viz because the benzene ring is very absorbent and you pick it up rather quickly and a lot of the other non-thalates don't have a benzene ring. Then we would use GC and then GC mass spec. I think for finished articles the FTIR is a screening tool is very good because thalates are very distinctive with FTIR. It's just that it's a general test and it's not overly as quantitative as GC mass spec. I just wanted to follow up one more thing from Dave. In your alternative thalates that are out there, and I know you've worked in the manufacturer, to what extent might there be an issue of contamination, and I'm saying with BASF in particular but with the industry, of having some of one of the banned thalates in one of the other thalates due to the manufacturer. Thank you. It depends on what you're making in your plant. If you're making thalates along with the non-thalates, you're going to run the risk of some cross-contamination. I think you can get cross-contamination from tank trucks as well, customers piping. So there's a whole chain of events or shipping events that can cause you to get contamination from just the plasticizer. Just to add to that in manufacturing process, other than the raw material quality check, material handling equipment, even just the liner in a drum that is used for your pallets and stuff like that resin, so that plastic liner in that drum can also introduce contamination. I'm Seth Hansen. I'm a consultant in the consumer products industry doing quality systems and so on. Everything I'm hearing here is about contained systems. Take it into the manufacturing area. I'm involved in a project right now with 400,000 units of wallets, inserts in wallets, BVC insert. They mixed when it came in and we were able to figure this out with some testing that when the product came in, came in from two different sources, one had phthalates at about 20%. The other was clean. They're put on the shelf together in the heat of Asia. All of a sudden now and to your point, what is happening now is you have products in the system that have 20% and you have some products in the system that have 1,000 ppm, 1,200 ppm. You set it together for a day. You set it together for a week. You have a problem. Part of this whole thing on phthalates, because of the migration issue, you need to look at the whole manufacturing process and set up that's what my clients are asking me to do. Give me a process from beginning to end of isolation. And it goes as far as I have a situation, screen prints. Lead was found. Same thing as phthalates, but lead was found in it. I traced it back. The screen print was done in Vietnam. They cleaned the screens with gas. There was lead in the gas. We have the same situation with phthalates. There is mixing of chemicals. You have BASF, good chemicals. Chinese, and they mix them. Dollars and cents. So I think we need to look at the whole process and to the point of using the portable, and that's what I'm involved in because I'm using that, by using the portable I'm able to save a $4 million project that was going to have to be burned, literally burned. Through the analysis of, instead of doing one, I've done over 300 analysis in three days and able to sort and sort things out. So we have to work together, the labs and the quality systems out in the field. And I would agree, but what I don't want to see is that the portable system becomes the be-all and end-all. Because if you have a portable system at a retail operation and it comes back that there's phthalates in there, however they've taken all the phthalates out and they can show through their component part testing and they can show through their General Conformity Certificate that they meet all the requirements, then you're sending that manufacturer through hoops that don't necessarily need to be sent through. So I agree it is a melding of all aspects that have to come together, but first and foremost, we need to take a look at the testing methodologies to determine why some of the phthalates that are not banned are showing up within the tests and what can be done. And is there something else, some other policies, some other steps that need to be put out there so that these phthalates that they are using because we need some plasticizers in these inks. I'm sorry, but we need them in the inks to make them work. We somehow have to have a testing methodology that does reward those manufacturers who have taken the step to get the six-band phthalates out and are using alternative phthalates. And that's really the crux of the issue because when it comes back as a failed test we have low limits and because we're not, we have not adopted a risk-based standard and they continually have to test even if they no longer have those materials in their products. So it's an underlying problem that needs to be addressed and if it can be addressed through an ASTM test method that looks at alternative methodologies to get to the result, that's great. But the underlying concern is the manufacturers that have taken the step to really reformulate their products and they still have that stick over them where they continually need to confirm that they have met the standard, but they're being penalized because the testing methodology erroneously identifies the phthalate. What I would like to add to that point is that for the ink application industry, if you test the right description, you'll have the choice based on what they've described under the ASTM initiative, you'll have options of the methods and that one solution won't fit all. So you'll have the choice of applying the solution that works for the ink industry applications provided CPSC blesses that method and approves it. Right, as long as it attacks the underlying problem that we're seeing, that's the crux of the issue. If the testing methodology, even as it's developed by ASTM, does not attack that underlying issue, then we haven't gained anything, regardless of the testing methodology that we choose. I would just like to point out that we had, I think, three or four different presentations today talking about the quality assurance within the existing testing mechanisms to properly identify those chemicals. We've seen it in our lab. It's very easy to do when it's done the way that Dr. Dreyfuss described that our friends from the other manufacturers described. But it's not being done consistently within the testing community and that's what we're seeing. It might be there's a lack of direction by CPSC or something, but we're seeing a lack of consistent failed results on products that should not be failing. And that is getting to be a very costly issue within the industry. Do you have any statistics about the... Yeah, just a question. Do you have any statistics about the numbers of failures that occur and all these all-foss positives or are they just misidentification? I don't think in the ones that are coming back failed and I'd have to go back and see, I would imagine that my members are keeping statistics only because it's a ROI issue and I can provide that for the record if people would like to see that. I don't think it's a misidentification because they've taken the banned ones out. So it's not like they say, oh, I don't have this in and then it's coming back saying it does. If it does, it might be, as we've mentioned here, an impurity. But I've had manufacturers that tell me they now will ship their products in tinfoil. They do not let any plastic touch their product. I mean, they really do take steps now to ensure that there's no migration between any sort of plastic and that sample before it gets to the lab. I mean, these are the steps that are being taken. However, they're not being taken by the garment decoration community. So now we're starting to develop some, I guess, recommendations for printers that want to send their products off because if the ink manufacturer's test comes back and it passes and then it fails on the part of the screen printer, then we have to look at the manufacturing process, obviously. And then we're also looking at the way that they ship the product off to be tested because we're seeing the migration. As we've mentioned here, even in the buckets that we know in the developing. But I'd be happy to pull together some statistics and let everyone know. So I was going to pose this. So now that we have you here and you have a forum directly to us, I guess the question I'd ask is, ideally, what does the testing community need for a lot of these issues that we brought up today? What would it take to either cut costs, get better results, make things more consistent? Whether it's practical or way down the road, what do you want from CPSC or from the manufacturers of different analytical technologies or instruments? What would you like to see in the future to make everyone's life easier? Well, from the standpoint of consistency, I mean, interlaboratory studies are the proven way to do this. It would certainly help to have reference materials with different additives or different matrices based on where the satellites are actually being detected and the quantities in which they're actually being detected. There are some voluntary interlaboratory studies that are being run in Europe, for example. But that, I think, is the most, you know, the standard way to address that issue. Yeah, we all came to an agreement that sample preparation is the area where there's an opportunity for making better economy of this method. So this is something we realized as well maybe two, three years ago when we started looking into these alternate methods. We have our own R&D team within SCS and we worked on thermal desorption technique. We have had some contact with Bob who presented his work in this area and how far it has progressed now under the ASTM D20 committee. So I think we recognize that as a positive move forward. I'm really glad to hear that that's one of the methods that you found to have least amount of variability. And just to give you some perspective, you know, in our studies, you know, we were able to analyze within 15 minutes the total runtime using that technique with little sample prep. Another advantage is, especially with coatings, you know, very small sample sizes needed. So some of the practical issues that come up when you have products with very small coverage area and you need, you heard the proverb, real example of 200 Barbie dolls. So in case of lead testing, but basically it's the same issue that when you have very small coverage in certain products, you know, that disadvantage goes away with the use of this method. You can use it for solid as well as liquid samples. And the recovery values were very high, you know, within the norms of the analytical world. So we are very excited about that and obviously ASTM approval of that method would also give further impetus to the use of that technology. There are a couple of other areas that we have looked into. IAMS is something that wasn't, I know it was on your list, but it wasn't discussed by any of the presenters today. We have looked at IAM, Iron Attachment Mass Spectroscopy. We have worked under the IEC group which has been looking at it from the raw side of the testing requirement in Europe. We have R&D team working in Germany closely with the IEC team. And we found some issues that really don't address the kind of problems, the practical problems in regulatory compliance needs for toys and children's products. The chromatic graphic separation of, you know, molecules with identical masses, definitely one problem. Sample homogeneity is a problem. We also looked at that and same sample homogeneity could be a problem, you know. So those are some of the issues that are still need to be resolved. And there's another much bigger practical problem that really does not solve the cost of the methodology. It's very expensive. We looked at systems from different vendors, you know, front-up capital cost of $450,000. So I'm really glad to hear some of the developments in handheld portable technology that was discussed today. This is something that needs to be validated in the real world. There was some limited data presented today. It may not be a solution for everybody, but it could be something to look at in different environments for screening purposes as intended. Yeah, sample homogeneity is always a big problem. I think the newer technologies have heightened the awareness of this when it comes to lead. So one of the things you want to watch out for, you know, these technologies that are surface sensitive like, you know, the FTIR, ATR techniques and the DAR techniques, you know, is your sample homogenous on a depth, through a depth profile? Certainly if you're looking, for example, at pellets, sometimes pellets have lubricants on them, so what's on the surface is not necessarily the same thing as what's in the interior. I mean, these are problems that can certainly be solved, but I think it's important to be aware of them. I have a question for Dave about the developing ASTM method. Bob spoke, of course, about the technology from the point of view of Frontier, but he alluded to the other instrument manufacturers out there, CDS, Gerstle, et cetera, and that they're being slight differences in temperatures and things like that for that. Is your method addressing that to make it universal across thermal desorption equipment? Well, the method hasn't been approved, but yes, we will address that. We're nearing three o'clock, so there's anyone else I'd like to ask a question, now's the time. So I guess my first question would be to Bob. In your preparation for the GCMS spec analysis, what is your biggest consuming problem? I mean, do you ever encounter problems where you would like to screen before you do that to avoid a costly problem? Yeah, I mean, I think certainly a technique that could identify, if you have a really quick technique, that could identify those materials that are failing by a large margin that would potentially eliminate some necessity to do testing. All of the GCMS spec methods are much more time-consuming than the FTIR or ambient mass spec techniques that were here. So, yes, that would be helpful potentially by eliminating testing on materials that failed by a large margin. But I mean, we would potentially have to look at the actual numbers of products by material class to see to what extent that would save testing time and cost. Right, right. So from our FTIR perspective, the way I see it is we have two different routes. We can go for the screening, but we also have the potential to do a liquid-solid extraction using a solvent. And there's ASTM methods already out there for doing that in other materials. Is that a potential route, or is it going to be a barrier for that? Can I? Well, I mean, people discuss the extraction processes here, and they can be time-consuming. They rain typically. The sonication processes are running in the half-hour range, but depending on the specified extraction procedure from identified in the test method, the extraction might be the time-consuming step or the time-eliminating step, and it might not be. And it probably depends on what you're looking at. If you're looking at raw material that's a plastisol, that's already a liquid. Potentially, that's a lot easier than something that is difficult to extract. Okay. That is for my question. Thank you. Thank you. Actually, I'd like to just follow up on that with Marcy. Do you see where perhaps some in your industry might use a technique like one of these screening devices to look at the incoming, you know, they've specified a phthalate alternative in their plastisol and to check that, you know, are the scope and size of these companies big enough to do that sort of thing? I guess it would depend on the cost of the handheld. I mean, I'm not sure what the cost of the handheld is for the lead, and they're not using one of those. Primarily in the industry sector, a typical size is 25 employees, so you're not looking at huge companies. So quite honestly, what they're looking at and what they want is they want the ink manufacturers to certify through component part testing that their inks are compliant. And that is really not occurring right now because of the costs associated with the tests from the ink manufacturer's point of view. The definition or lack of clarity of definition as to what is batch manufacturing and also with the fact that we're seeing so many false positives come back on the alternatives. So it's a mixed bag. I really don't see that they would, unless it was a really large garment decoration house, that they would invest in handheld. They really are just going to look to their suppliers to certify, or they're going to send out to a lab themselves because quite honestly, eventually, because they're providing a children's product, they're going to have to test anyway or at least provide some sort of testing documentation through component part testing that their product complies with all the lead and phthalate content limits. So I don't really see handheld as being... I see that happening more at the retail level, to be honest with you. My name's Pat Sells. I've got 30 years experience selling X-ray to include portable X-ray. And I'm no longer in the X-ray business. I'm in the ramen business now, the portable. But one of my clients down in North Carolina, they were spending $100,000 a month on testing, sending samples out just for lead. And they did buy portable X-ray from me at the time when I worked for another outfit. They spent $40,000 for that piece of equipment. But they reduced their monthly output of samples they were sending out as a result of screening down to about $10,000 a month. If they found any indication of lead at all in screening, they did not attempt to put a number on it. That went out to be tested by the holy grail methods of ICP and AA and everything else, which we don't compete with. We readily admit that those techniques are superior. But in an attempt to limit the volume of samples that you're sending out, there is a role for the screening. And while we're not here today to talk about lead, I think the screening for the phthalates will play a similar type of role. And it is a way for manufacturers to reduce cost. This was a particular site where the lead was showing up in inks. It was showing up in zippers. There were a lot of cases where there was conflicts in analysis where the commercial lab was coming back saying there wasn't any lead. We were saying there was lead. It wasn't a fact that the commercial lab did anything wrong. We analyzed two different pieces of metal. They were taking the zipper pull and dissolving it in acid. We were looking at the zipper pull, but we were looking at the base of the zipper, which is leaded brass, and we were seeing the lead. We were not seeing the lead in the zipper in the pull. So it's really not a question that we're wrong and they're right, they're right, and we're wrong. It's a question of the sampling. Are you looking at the same piece of material? And so on. I know I would agree that there is a role. It depends on how large the operation is and their volume. Because if you're looking at a traditional garment decorator, especially in the area of phthalates, and again, the unwritten definition is under three, facilitating eating and sleeping, there's not a lot of that actually being printed, believe it or not. A lot of it's embroidered, which is exempt, because it's not a plasticized component. But when you start looking at zippers and things of that nature, then yes, it does make sense to have some sort of a handheld technology. But it does depend on the size of the facility. But if you're looking at your average facility that you're going to go to to buy t-shirts for your local soccer team, no, they're not going to have any sort of handheld. But potentially you're spending as much in one month as what one of these analyzers cost. But they're not going to send out every product. They're going to look at their ink systems and they'll send out their ink systems. And as long as they don't change their ink systems, then they're fine. They don't have to get it retested. So you're not, you know, it is a fine line. But quite honestly, the size of the facility does dictate what they're going to do. And we also don't, SGIA does not say you have to send every product out to get tested. You have to make sure that product complies. If you can use component part testing and send out a sample of your ink, then that test stands until you use up that ink. So it really is, it's very much a cost issue. But again, the industry is looking to their ink manufacturers to provide them with that assurance. And I would still argue that screening techniques are one of the best methods to reduce your cost. I wouldn't disagree, it depends on the size of the facility and the amount of volume that they do. If you're doing a million dollars, I'm not sure. One more thing. All of this, this is CPSC meeting. I have not heard anything about Prop 65. And Prop 65 is the big gorilla in the room. And Prop 65 does not dispensiate between children and others. And if you look at what is going on right now with the number of 16 notices that have been filed and it's only an indicator of what's going on. So phalates, we have to come up with some ways in the whole process of taking care of the phalates and making sure they're not in there. We've been dealing with Prop 65 for years. That's a California regulation by the way. Do we have any last questions? I just have a question about the work done now. Are there any plans for doing some kind of interlaboratory study to try and possibly develop a correction factor that would be applied? A correction factor for what? Well, if you look in the ASTM F963, which is the toy standard, there is testing that's specified for heavy metals in the coatings. And I guess they must have done an interlaboratory study to determine what kind of variability there is between labs. And for each of the heavy elements, there's a certain correction factor that's to be applied. I think it's anywhere between 5 and 30%. Well, I'm going to talk in a slightly different terminology. Once a method is developed and approved, you do have to do a statistical analysis. And we've basically done two interlab studies already with vinyl that was compounded, but it was not, I'll say, made to all the ASTM requirements. It was just to see how the different techniques would work. So the next iteration, once a method is approved, is to do an interlaboratory study with a sample and then provide the statistical analysis. Okay. And one other question. Asenji, you just wanted to bring in on that. I want to speak to that correction factor question you just asked. I think you're referring to the correction factor that is applied for the weighing error that could occur when you're compositing different materials. I think you might have 963 heavy metals as a subtraction. Right. I mean, there is a... I'm sorry. Let me just point out. ASTM F963 is the toy standard. And in its section 4.3, I think it is, on six heavy metals and paints, and now in the new 2011 version in substrates as well. It applies a correction factor that essentially subtracts off a percentage from the result. This was a consensus standard that is, you know, giving a discount, if you will, to the measured values as part of the standard. The standard, in this case, of 0.1% of the six, the three permanently banned phthalates and the three temporarily banned phthalates was set by Congress. And it's not... It only gets ASTM's purview to set that standard. Right. Thank you. And one other question. We've heard a lot of talk about, because of the phthalate regulation, essentially phthalates as a plasticizer will, within a few years, are going to be totally absent from the marketplace. Is there any truth to that, or is that just mythology? I think what I would say is most of the vinyl is not compounded in the United States. And, you know, about 50% is in Asia. And in Asia, the predominant plasticizers are phthalates. In the U.S., the predominant plasticizers are phthalates. And in Europe, I think the predominant plasticizers are phthalates. There are new plasticizers coming out. It's pretty much been an explosion. But I would not say it's years. It might be decades, if it happens at all. Thank you. I'd like to just clarify a few of the things about the ASTM method. There is a section in there that requires the user to use evolved gas analysis. Evolved gas analysis basically will define the temperature range over which that particular piece of equipment works best. So if the frontier system is 100 to 320, it may be with manufacturer B, they may be going from 120 to 340. So there's a section in there that discusses using evolved gas analysis and extracted ions to identify the temperature range over which that piece of equipment operates to extract the phthalates. And I should mention that one of the round robins that Dave mentioned was done by a series of laboratories that had nothing to do at all with our committee. So I just went out in the free world and found five people, five laboratories, willing to take these samples and see what they could get. And the percent difference for all the laboratories, for all the numbers. We looked at six phthalates, three different injections, a large number of data. The percent difference or percent error, I'm sorry, for all the numbers, from all the laboratories, for all the repercussions, was about 12%. So we are proceeding down the path that Dave mentioned. We've got one more round to do. What we have to do is train that analyst a little bit more before she gets the samples. But it brings up a good point that one guy out of six failed the test. See, I don't know if she failed. She's 30% higher than every number. There's something in there that I can't find. I was curious, the other gentleman started this question. Earlier I heard the mention of non-phthalate plasticizers and I was curious, is there a list of non-phthalate plasticizers on the market right now that are like available and affordable? Or is that not really the case? Just out of curiosity on my part. I don't know too much about the plasticizer. I'll refer that question back to the EPA Design for the Environment Committee that I mentioned in my first talk. That's one of their target goals is to bring up the different phthalates where their possible repercussions could be. Short cost is going to be a factor that comes into that. There was a study done by Institute, I don't remember the full name, STURI in Massachusetts. It was done almost 10, 15 years ago, which looked at non-phthalate plasticizers and also looked at the cost implications going back 15 years ago. I can forward you that research paper if you want. One part of the ASTM task group is to compile all the plasticizers that are used in vinyl and also provide mass spectra on that. I'm also going to mention something as an aside because the Society of Plastics Engineers has a vinyl division and they're going to have a regional technical conference in October and there will be a bunch of presentations on non-phthalate plasticizers there. That's in the middle of October. You can go to SPE. I think it's SPE4U.org or something like that. Thank you. I think this has been a really good seminar. This was our first chemistry symposium that we've had here at our new lab. I understand some of you are interested in seeing our chemistry lab and so those who have time to stay for a brief tour, we can meet out in the hallway here. Actually, we've got safety glasses right over there and if you could grab a pair of safety glasses and come on out, we can do that. I'd like to have a round of applause for all of our presenters today and thanks to Matt for hosting us. Thank you.