CPSC (2009) — CPSIA Section 101(b)(2) Inaccessibility Interpretative Rule (16 CFR 1500.87)

A fifty-two-page Consumer Product Safety Commission ballot package dated July 23, 2009 (ballot vote due July 30, 2009; rule effective August 14, 2009) containing the Commission’s draft Federal Register notice promulgating the final interpretative rule on inaccessible component parts of children’s products containing lead under Section 101(b)(2) of the Consumer Product Safety Improvement Act of 2008. The package codifies the rule at a new 16 CFR 1500.87 and consists of: (i) a two-page ballot vote sheet from CPSC Office of General Counsel (Philip Chao, Hyun S. Kim) routed through General Counsel Cheryl A. Falvey and Acting Executive Director Jacqueline Elder to the Commission and Secretary Todd A. Stevenson; (ii) Attachment 1, the thirty-page draft Federal Register notice (16 CFR Part 1500) reproducing the rule preamble (Background, Statutory Authority, Notice of Proposed Rulemaking, Discussion of Comments and Responses, Effective Date, List of Subjects, Conclusion) and the full regulatory text of §1500.87(a) through (j); (iii) Attachment 2, a five-page CPSC staff memorandum “Consumer Product Safety Improvement Act of 2008 (CPSIA) — Guidance for Evaluating Accessibility of Lead-Containing Component Parts” by Robert J. Howell and Kristina M. Hatlelid summarizing the proposed accessibility-assessment framework and the staff’s conclusions and recommendation to the Commission; and (iv) Attachment 3, a ten-page CPSC staff memorandum “Response to Public Comments: Inaccessibility of Lead-Containing Components of Children’s Products” by Kristina M. Hatlelid (through Lori E. Saltzman to Mary Ann Danello) cataloguing the nine public comments received on the January 15, 2009 notice of proposed rulemaking (74 FR 2439) and the staff’s responses, with Appendix A listing the commenters (Office of the Secretary memorandum from Todd A. Stevenson, February 24, 2009). The package contains no primary contamination measurements; it is included in the Heavy Metal Index corpus as the primary-regulatory-record source for the 16 CFR 1500.87 inaccessibility-exclusion framework that any HMTc certification of US children’s products covered by CPSIA must reckon with, and as the canonical citation for the statutory-interpretation reasoning the Commission adopted in distinguishing physical accessibility from leaching or ingestion-based accessibility.

Key numbers

• CPSIA Section 101(a) lead-content limits for children’s products (Attachment 1, §1500.87(a), p. 28–29): products designed or intended primarily for children 12 and younger cannot contain more than 600 ppm of lead effective February 10, 2009; not more than 300 ppm effective August 14, 2009; the limit may be further reduced to 100 ppm on August 14, 2011, “unless the Commission determines that it is not technologically feasible to have this lower limit.”
• “Children’s product” age scope (Attachment 1, p. 2; CPSA §3(a)(16) as amended by CPSIA §235(a)): “a consumer product designed or intended primarily for children 12 years of age or younger.”
• Section 101(b)(2) inaccessibility exclusion (Attachment 1, §1500.87(b), p. 29): “the lead limits do not apply to component parts of a product that are not accessible to a child. This section specifies that a component part is not accessible if it is not physically exposed by reason of a sealed covering or casing and does not become physically exposed through reasonably foreseeable use and abuse of the product including swallowing, mouthing, breaking, or other children’s activities, and the aging of the product, as determined by the Commission.”
• Section 101(b)(3) paint/coating/electroplating barrier prohibition (Attachment 1, p. 1 and §1500.87(b)): “Paint, coatings, or electroplating may not be considered to be a barrier that would render lead in the substrate to be inaccessible to a child.”
• Rule-issuance deadline imposed by CPSIA Section 101(b)(2)(B) (Attachment 1, p. 1, §1500.87(c)): the Commission is required to issue this interpretative rule by August 14, 2009. The final rule was made effective on the deadline date (August 14, 2009).
• Notice of Proposed Rulemaking citation (Attachment 1, p. 3): the proposed interpretative rule was published in the Federal Register of January 15, 2009 at 74 FR 2439. Public-comment period closed February 17, 2009; nine comments were received and addressed in Attachment 3.
• Accessibility-probe regulations adopted (Attachment 1, §1500.87(d), p. 29–30): the accessibility probes specified for sharp points or edges under the Commission’s existing regulations at 16 CFR 1500.48–1500.49 will be used to assess accessibility of lead-containing component parts. “A lead-containing component part would be considered accessible if it contacts any portion of the specified segment of the accessibility probe.”
• Use-and-abuse test regulations adopted, by age band (Attachment 1, §1500.87(e)–(h), p. 30–31):
  • 18 months of age or less → 16 CFR 1500.51 (excluding the bite test of 1500.51(c))
  • over 18 months but not over 36 months of age → 16 CFR 1500.52 (excluding the bite test of 1500.52(c))
  • over 36 months but not over 96 months of age → 16 CFR 1500.53 (excluding the bite test of 1500.53(c))
  • over 96 months through 12 years of age → 16 CFR 1500.53 intended for children aged 37–96 months (excluding the bite test of 1500.53(c))
• Bite-test exclusion rationale (Attachment 1, §D.7, p. 19–20): the Commission “does not use the bite test specified in the three CFR sections, as a result of a court case (Clever Idea Co., Inc. v. Consumer Products Safety Commission, 385 F. Supp. 688 (E.D. N.Y. 1974)) that questioned the appropriateness of this test. This requirement may be modified in a future proceeding.”
• Fabric-covering rule (Attachment 1, §1500.87(i), p. 31): “A children’s product that is or contains a lead-containing part which is enclosed, encased, or covered by fabric and passes the appropriate use and abuse tests on such covers, is inaccessible to a child unless the product or part of the product in one dimension is smaller than 5 centimeters.” The 5-cm threshold is imported from CPSIA Section 108(e)(2)(B) (“if a toy or part of toy in one dimension is smaller than 5 centimeters, it can be placed in the mouth”), applied here by analogy to children’s products beyond toys.
• Intentional disassembly carve-out (Attachment 1, §1500.87(j), p. 31): “The intentional disassembly or destruction of products by children older than age 8 years by means or knowledge not generally available to younger children, including use of tools, will not be considered in evaluating products for accessibility of lead-containing components.”
• Companion CPSIA Section 101 rules cited in the preamble (Attachment 1, p. 11–12, 15, 26–27):
  • 74 FR 6990 (February 12, 2009): interim final rule providing exemptions for certain electronic devices for which it is not technologically feasible to comply with the lead content limits.
  • 74 FR 10475 (March 11, 2009): final rule establishing procedures for a Commission determination that a specific material or product does not exceed the lead content limits specified under Section 101(a) of the CPSIA.
  • 74 FR 2433 (January 15, 2009): notice of proposed rulemaking on lead-content limits for certain materials or products preliminarily determined to fall below the lead content limits.
• Statutory authority cited (Attachment 1, p. 28): the authority for 16 CFR Part 1500 as amended reads “15 U.S.C. 1261–1278, 122 Stat. 3016.” The 122 Stat. 3016 citation is Public Law 110-314 (CPSIA, 2008).
• List of Subjects in 16 CFR Part 1500 (Attachment 1, p. 28): “Consumer protection, Hazardous materials, Hazardous substances, Imports, Infants and children, Labeling, Law enforcement, and Toys.”
• Compact-disk/DVD interpretation (Attachment 1, §D.11, p. 26–27; Attachment 3, p. 7): “Acrylic polymer layers of a compact disk or DVD are not considered to be a coating. If the internal metallic layer of a disk is not accessible to a child, testing and certification would not be required.” The staff explicitly distinguishes the acrylic polymer layer of a CD/DVD from “paint, coatings, or electroplating” within the meaning of CPSIA §101(b)(3).
• Component-within-component example (Attachment 1, §D.5, p. 15; Attachment 3, p. 3–4): the Commission interprets “a lead-containing component part” to mean that the material used to construct the part includes lead in its formulation, not that the part contains smaller parts that contain lead. Worked example: a sealed plastic ball compliant with the CPSIA lead limits that contains internal metal beads with lead is itself not a lead-containing component part; the metal beads are. If the ball does not provide access to the beads (through a hole, crevice, or after use-and-abuse testing), the beads are deemed inaccessible.
• Public-comment count and commenter categories (Attachment 3 and Appendix A, p. 48–52): nine substantive public comments were received on the proposed rule. Commenter categories, summarised without naming individual firms (per the Part 12 brand-firewall strict reading): one international sleep-products trade association; one toy-testing services firm; one consumer-groups coalition (seven consumer and public-interest organisations submitting jointly); one electronic-products-association coalition (three industry associations submitting jointly); one consumer-product manufacturers coalition (represented by counsel); one apparel-and-footwear trade-association coalition (one association plus a coalition of thirty trade associations); one motorized-recreational-vehicle-firms coalition (seven motorised-recreational-vehicle manufacturers represented by counsel); one footwear-distributors-and-retailers trade association; and one individual commenter whose submission did not address the proposed accessibility rule.
• All-terrain-vehicle exposure finding (Attachment 1, §D.5, p. 14): in the context of an exclusion request for motorised recreational vehicles, the Commission found that “the normal and reasonably foreseeable contact with lead-containing parts by children using motorized recreational vehicles would not be extensive but would occur,” citing the brake and clutch levers and the throttle controls as components users (6–12 year olds) are required to touch in regular use of the product. “It is reasonable to assume that children will not be washing their hands immediately after touching these parts.” Cross-reference: CPSC “Human Factors Response to Request for Motorized Recreational Vehicles Group Request for Exclusion from Lead Limits under Section 101(b)(1) of the Consumer Product Safety Improvement Act,” April 2009.

Methods (brief)

A CPSC Office of the Secretary ballot package dated July 23, 2009 transmitting to the Commission, for a ballot vote due July 30, 2009, three documents pertaining to the final interpretative rule on CPSIA Section 101(b)(2) inaccessibility of lead-containing component parts of children’s products: (i) the draft Federal Register notice promulgating the rule and codifying it at 16 CFR 1500.87 (Attachment 1, thirty pages including the rule preamble — Background, Statutory Authority, Notice of Proposed Rulemaking, Discussion of Comments and Responses 1 through 11, Effective Date, List of Subjects, and Conclusion — and the regulatory text of §1500.87(a) through (j) added to 16 CFR Part 1500 under authority 15 U.S.C. 1261–1278, 122 Stat. 3016); (ii) Attachment 2, a five-page staff memorandum by Robert J. Howell (Assistant Executive Director, Office of Hazard Identification and Reduction) and Kristina M. Hatlelid (Toxicologist, Directorate for Health Sciences) summarising the proposed accessibility-assessment framework (use of the §1500.48–1500.49 accessibility probes and the §1500.50–1500.53 use-and-abuse tests, excluding the §1500.51(c)/1500.52(c)/1500.53(c) bite tests), the key issues raised in public comment, and the staff’s conclusions and recommendation that the Commission issue the final rule with revisions to specify the criteria for the inaccessibility exclusion and to correct the inadvertent omission of the §1500.53 bite-test exclusion; and (iii) Attachment 3, a ten-page staff memorandum by Kristina M. Hatlelid (through Lori E. Saltzman to Mary Ann Danello) responding to the nine public comments received on the January 15, 2009 notice of proposed rulemaking (74 FR 2439), organised under six comment headings (accessibility does not mean only physical contact; testing and certification requirements; use of accessibility probes; use of use-and-abuse tests; explanation of the bite-test exclusion; fabric coverings as a barrier; aging and wear and tear; compact disks and DVDs), each followed by the CPSC staff response that became the basis for the relevant section of the Discussion of Comments in the Federal Register preamble; with Appendix A reproducing the February 24, 2009 Office of the Secretary memorandum from Todd A. Stevenson listing the nine commenters by comment number, date received, signatory, and affiliation. No primary contamination measurements, analytical chemistry, or statistical analysis are reported; the document’s contribution is the integrated primary-regulatory-record account of how the Commission resolved the eleven substantive interpretive questions that determined the operational meaning of the CPSIA Section 101(b)(2) inaccessibility exclusion — particularly the rejection of leaching-based and mouthing/swallowing-restricted readings of accessibility in favour of a physical-contact reading based on the accessibility probes and use-and-abuse tests already in force for sharp-point and sharp-edge evaluation.

Implications

• Certification (HMTc): This source establishes the operational framework that determines which component parts of a US children’s product are exempt from the CPSIA Section 101 lead-content limits as “inaccessible.” For any HMTc category covering children’s articles subject to CPSIA Section 101, the certification scope-of-test rules must align with this framework: (i) the 16 CFR 1500.48–1500.49 accessibility probes are the binding test for whether a part is accessible, applied both before and after the §1500.50–1500.53 use-and-abuse tests appropriate to the child-age band the product is intended for; (ii) the bite tests are not used to evaluate accessibility; (iii) paint, coatings, and electroplating are never a barrier rendering substrate lead inaccessible (Section 101(b)(3), reaffirmed in §1500.87(b)); (iv) fabric coverings may render an underlying lead-containing part inaccessible provided the covering passes the appropriate use-and-abuse tests and the fabric-covered part exceeds the 5-cm one-dimension threshold imported from CPSIA Section 108; (v) acrylic polymer layers of compact disks and DVDs are not “coatings” within the meaning of Section 101(b)(3); and (vi) intentional disassembly by children older than age 8 using tools is not considered. HMTc thresholds for any children’s-product category should label deviations from these CPSIA Section 101 floors with the Part 19 rationale tags (regulatory-alignment when matching, precautionary when tighter, market-ratcheting or feasibility-driven where applicable). The rule’s age-banding logic (≤18 mo / 18–36 mo / 36–96 mo / 96 mo–12 yr) is also directly relevant to HMTc scope decisions for any certification covering products marketed across multiple child-age bands, because the use-and-abuse-test regime that applies is determined by the band the product is intended for, not by the broader CPSIA 12-and-under scope.
• Courses: Useful as the primary-source explainer of the CPSIA Section 101 inaccessibility exclusion for students who need the agency’s own reasoning on the eleven interpretive questions that determined the rule’s operational meaning. The Discussion of Comments and Responses section (Attachment 1, §D.1 through §D.11) is the canonical citation for the Commission’s adoption of a physical-contact reading of accessibility over the leaching-based and mouthing/swallowing-restricted readings advanced by various commenters. The staff memorandum response to public comments (Attachment 3) provides the staff-level reasoning that underlies the Federal Register preamble’s terser narrative.
• App: Not directly relevant to ingredient contamination_profile data. The CPSIA Section 101 scope (“a consumer product designed or intended primarily for children 12 years of age or younger”) and the §1500.87 inaccessibility framework would gate any future app surface that conditions risk advisories on whether a given children’s-product SKU is covered by CPSIA Section 101 and on whether the lead-containing components of that SKU are physically accessible to a child within the meaning of the rule.

Wiki pages this source may touch

• lead
• toys-painted
• toys-substrate-materials
• toys-battery-electronic
• children-personal-care
• childrens-jewelry

Verification notes

• Document identity and date. The package is a CPSC Office of the Secretary ballot package dated July 23, 2009 (ballot vote due July 30, 2009). The draft Federal Register notice it transmits is the final interpretative rule promulgating 16 CFR 1500.87 under CPSIA Section 101(b)(2)(B), made effective August 14, 2009. The package corresponds to the Hatlelid 2009 December presentation’s slide-6 entry: “Federal Register notice 74 FR 39535; codified at 16 CFR 1500.87; effective August 14, 2009” (see hatlelid2009-cpsc-cpsia-lead-childrens-products).
• Cite-key rationale. cpsc2009-cpsia-101b-inaccessibility-rule follows the corpus pattern established by cpsc2012-cpsia-101b-functional-purpose-exception (CPSC, CPSIA Section 101(b) topic, year, brief slug). The institutional author is the U.S. Consumer Product Safety Commission (the ballot package is signed out by the Office of the Secretary on behalf of the Commission); individual staff are credited in the attached memoranda as memorandum authors, not as authors of the rule itself.
• Filename and provenance. The PDF was received via the Kimi May 21 corruption-issue re-extraction batch and lives at raw/Manual Fetch Kimi /May 21 Kimi_Agent_Download Corruption Issue/_extracted_infantcontact_05_Regulatory/05_Regulatory_CPSIA_CPSC_FDA/22_blk_pdf_leadinaccessguide_2009.pdf. The filename suffix “leadinaccessguide_2009” reflects the document’s status as the Commission’s 2009 lead-inaccessibility guidance ballot package; raw_handle: MFK_22-blk-pdf-leadinaccessguide-2009 preserves the Kimi handle. SHA-256: 759487de1437a23abb1da871084cfe86e0cf1183f3aea402d17d6d67de68a9ba.
• Source-tier rationale. evidence_tier: A: per Part 13, the A tier covers “agency regulations, agency reports, agency guidance documents.” This is the Commission’s own ballot package and draft Federal Register notice promulgating a final interpretative rule (16 CFR 1500.87), accompanied by the staff guidance memorandum and the staff response-to-comments memorandum that informed the rule. The “DRAFT” watermark on Attachment 1 reflects the package’s pre-Commission-ballot status as of July 23, 2009; the rule was approved and made effective on August 14, 2009 as drafted (with the staff-recommended revisions detailed in Attachment 2). Treated as A-tier as a primary-record agency regulation.
• source_type: gov-guidance. The package is hybrid: it is the formal Commission ballot vehicle for a final interpretative rule (Attachment 1), accompanied by two staff guidance memoranda (Attachments 2 and 3). It is filed under gov-guidance rather than gov-regulation to match the corpus pattern established for cpsc2012-cpsia-101b-functional-purpose-exception and hatlelid2009-cpsc-cpsia-lead-childrens-products and to keep the routing layer fanning the source out to the relevant product pages; the routing-audit script treats source_type: gov-regulation as out-of-scope for product-page routing on the (correct) assumption that such sources will route through wiki/regulations/ instead. When a CPSIA-Section-101-specific regulation page is created in wiki/regulations/ (proposed in the Related corpus pages note below), this source can be re-typed to gov-regulation and its routing handled through that page.
• No primary measurements. sample_n: null, matrices: [], ingredients: [] are correct — the package reports no measurements of contamination in any product matrix. It enumerates a regulatory framework for determining whether lead-containing component parts of children’s products are accessible to a child within the meaning of CPSIA Section 101(b)(2), not measured occurrence data.
• products: field. Five product slugs are populated: toys-painted (CPSIA Section 101(b)(3) and §1500.87(b) explicitly address paint/coatings/electroplating on lead-containing substrates); toys-substrate-materials (the inaccessibility framework applies directly to toy substrate materials, including the explicit rule that paint/coating/electroplating may not be treated as a barrier making substrate lead inaccessible); toys-battery-electronic (electronic-products-association commenters specifically engaged the §1500.88 interim final rule cross-reference and the staff’s component-within-component reasoning, and the package addresses electronic-component accessibility at §D.5); children-personal-care (the umbrella slug for the broader “children’s products designed for children 12 and under” scope to which the rule applies); and childrens-jewelry (children’s jewelry is one of the children’s-product categories CPSIA Section 101 explicitly regulates as substrate material under the 100 ppm content limit, and is one of the most CPSIA-Section-101-relevant categories in the current product taxonomy not covered by the toy-specific slugs). CPSIA Section 101’s statutory scope is broader than these five slugs (it covers all “children’s products” including durable infant products, bicycles, motorised recreational vehicles, mattresses, footwear, and apparel); the routing here reflects the current-taxonomy slugs most directly addressed by the rule’s text and its Discussion of Comments. The motorised-recreational-vehicles example discussed at §D.5 and the textile/apparel/mattress/footwear discussion at §D.8 are not currently represented as standalone product pages and so are not routed; the rule’s applicability to those categories is preserved here in the body and in the Implications section rather than in products: slugs.
• matrices: [] is correct: this is a regulatory rule package, not a measurement study; there is no analytical matrix in which lead was measured.
• ingredients: [] is correct: ingredients are not the relevant taxonomy axis for a children’s-products lead-accessibility rule. CPSIA Section 101 regulates lead in the product substrate and in surface coatings, not in food ingredients.
• jurisdictions: [US] is correct: CPSIA (Public Law 110-314), 16 CFR Part 1500, and Federal Register notices are US federal law and rulemaking.
• Brand-firewall (Part 12, strict reading locked 2026-05-17). The package names the seven motorised recreational vehicle firms that submitted joint comments as Comment 8 (Honda, Arctic Cat, Kawasaki, Yamaha, Suzuki, Bombardier, Polaris — Attachment 3 introduction and Appendix A, p. 51–52; note that the parenthetical “(8)” appearing after the firm enumeration in the Hatlelid memorandum introduction is the comment-index number, not the firm count, and the firm count is seven) and several other industry-firm commenters by name and affiliation (Wiz Chan of Modern Testing Services; the Consumer Federation of America, Consumers Union, Kids in Danger, National Center for Women & Families, Public Citizen’s Congress Watch, and the U.S. Public Interest Research Group; the Consumer Electronics Association, Information Technology Industry Council, and IPC; the International Sleep Products Association; the American Apparel and Footwear Association; the Footwear Distributors and Retailers of America; and the United States Association of Importers of Textile and Apparel). These are commenters on a public-record rulemaking, not brands attached to contamination measurements. The Part 12 brand-firewall concern is brand-name attribution to CONTAMINATION VALUES; these commenters are not contamination subjects. The conservative reading is nonetheless to refer to commenter groupings (“the motorised recreational vehicle firms,” “the consumer groups coalition,” “the electronic-products associations,” “the apparel-and-footwear trade associations,” “the sleep-products trade association,” “the toy-testing-services commenter”) in Key numbers and the body rather than listing each name — which is what the Key numbers section above does. The full commenter list is preserved in the source PDF (Appendix A) and is a matter of public record; the wiki page does not republish it.
• Wiki/HMTc firewall (Part 2). The source proposes no HMTc thresholds and is not compared to existing HMTc certification levels in the body. The Implications section flags that the 16 CFR 1500.87 framework determines which component parts of US children’s products are exempt from the CPSIA Section 101 lead-content limits, and that any HMTc certification covering children’s articles must align its scope-of-test rules with this framework or label deviations with the Part 19 rationale tags. This is a procedural pointer to the threshold-setting workflow, not an HMTc threshold proposal.
• Speciation flag. Not applicable; lead is reported as content (ppm in product substrate or as a categorical accessibility judgement on substrate or coating) without speciation. The 16 CFR 1500.87 rule is concerned with physical accessibility of any lead-containing part, not with lead speciation in or leaching from the part.
• Funding and conflicts. Not applicable: government rule promulgation; no funding disclosure or conflict-of-interest statement applies. The standard CPSC staff caveat (“These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views of, the Commission”) appears as a footnote on Attachment 3 only; Attachment 1 is the Commission’s own (draft, then approved) rule and is not subject to the staff caveat. The cover-page CPSA §6(b)(1) public-release stamp (“CPSA 6(b)(1) CLEARED for PUBLIC: NO MFRS PRV’TLBLRS or PRODUCTS IDENTIFIED, EXCEPTED BY: PETITION RULEMAKING ADMIN. PRCDG”) confirms public release with the rulemaking-administrative-procedure carve-out under CPSA §6(b)(1).
• License. public-reference-only: CPSC rule packages and Federal Register notices are US government work in the public domain (17 USC 105), so re-hosting and quotation are unrestricted under US law; the conservative public-reference-only label is used to match the corpus pattern for primary regulatory documents (cf. cpsc2012-cpsia-101b-functional-purpose-exception, hatlelid2009-cpsc-cpsia-lead-childrens-products).
• Federal Register citation completeness. Attachment 1 cites three companion CPSIA Section 101 Federal Register notices by FR volume and page: 74 FR 2433 (Jan 15, 2009; NPR on materials determined below the lead limits); 74 FR 6990 (Feb 12, 2009; interim final rule for certain electronic devices); and 74 FR 10475 (Mar 11, 2009; Section 101 procedures rule). The package itself, when published, became the 74 FR 39535 notice cited on slide 6 of hatlelid2009-cpsc-cpsia-lead-childrens-products; the draft package does not bear its own as-published FR cite (Federal Register page numbers are assigned at publication).
• Audit subagent (2026-06-01) flagged Key numbers and brand-firewall paragraph stating “eight motorised-recreational-vehicle manufacturers” for Comment 8 in the Hatlelid response-to-comments memo; verified against PDF Appendix A pp. 51–52, which lists exactly seven Comment 8 signatories (Honda, Arctic Cat, Kawasaki, Yamaha, Suzuki, Bombardier, Polaris) — corrected to “seven.” The “(8)” appearing after the enumerated firm list in the Hatlelid memo introduction (PDF p. 41) is the comment-index number, not the firm count. The same audit also noted that Comment 9 (Footwear Distributors and Retailers of America) is date-stamped February 18, 2009 in Appendix A while the comment-period close is February 17, 2009 — that one-day delta is left as-noted (the page records “nine comments were received and addressed in Attachment 3,” which is accurate; the comment-period-close date is the deadline as published, not a guarantee that every commenter met it).
• Related corpus pages. hatlelid2009-cpsc-cpsia-lead-childrens-products is the same staff author’s December 2009 fourteen-slide presentation summarising the broader CPSIA Section 101 regime (statutory limits, definitional scope, exclusions framework, determinations rule, paint rule, and testing-methods study); this current source is the primary-regulatory-record document for the specific 16 CFR 1500.87 inaccessibility rule that the December 2009 deck’s slide 6 summarises. cpsc2012-cpsia-101b-functional-purpose-exception is the same series of Section 101(b) interpretive rules (the §1500.91 functional-purpose exception) approached three years later under the same statutory authority; this current source is the older sibling. cfa2012-cpsia-lead-fact-sheet is a 2012 consumer-advocacy summary of the same CPSIA Section 101 regime, written several years after this 2009 ballot package, that references but does not reproduce the §1500.87 inaccessibility framework. No CPSIA-Section-101-specific regulation page yet exists in wiki/regulations/; the natural next-step regulation page would be the routing target for this source, the cpsc2012 source, the cfa2012 source, the hatlelid2009 presentation, and any later Section 101 sources. Per Part 10 and the manual-fetch skill, that regulation page is a Karen-curated new-page proposal rather than something created during this ingest.

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.