It was one of our hottest selling bags and we were flat out-of-stock.  At least a dozen backorders had already piled up by the time the container with 150,000 new pieces finally arrived at our receiving dock.

The product, a polyester backpack with a zippered pocket, came in four colors, each with a matching coated zipper pull.  The arriving pieces should have gone into production as fast as the container was unloaded.  Instead, I received a chilling email from my in-house testing lab:

Product failed XRF test upon receipt. Lead: 4,600 ppm in surface coating of zipper pull. Shipment quarantined.

4,600!  The legal limit was 600 ppm if those bags were decorated for children.  How could it be?  Didn’t we have a pristine test report from a major third party lab just weeks earlier?

Yes, it was true.  This shipment failed but weeks earlier we had received a current test report in which the same product from the same factory passed every test with flying colors, and from one of the most respected CPSC-certified labs in the world.   What could have gone wrong?

A lot went wrong, we learned.  To begin with, the sample that was sent to the testing lab was made from a different batch of material than the production pieces.   That’s not unusual.  As long as the product spec, bill of materials and factory doesn’t change you shouldn’t have to send every batch to be third party tested.

But that’s the point.  Something obviously did change but no one knew about it.   Maybe not even the factory.  It’s the same thing that happened to all those Barbie Dolls® back in 2007.  In this case it was the zipper pull.  The production pieces were sprayed with a different coating than the sample.

So what can we learn from this incident?   Does it mean you can’t rely on third party test reports?

No, the report was fine.   The sample that passed the test was fine.  The problem was the factory, not the testing lab.

Factories assemble products from raw materials and components that they buy from other suppliers.  A bag factory will buy fabric, lining, metal, paint, grommets, thread, handles, wheel assemblies, binding, and whatever else they need from a a variety of sources.   If they are required to make a product that complies with 100 ppm lead, that’s what they’ll specify to their suppliers.  But how many factories are equipped as we are to scan every incoming shipment to verify that it complies with the spec?  Very few, if any, in my experience.  They rely on the integrity of their supply chain and sometimes that supply chain lets them down.

The problem could be with just a portion of an order.  Maybe the factory runs out of a particular material and needs a little extra to complete the order.  But their main supplier is out of stock, or won’t accept orders for small quantities.  So the factory goes elsewhere to fill the need.  Maybe the extra material complies, maybe not.

It’s why Prime and other quality suppliers who buy from dozens of factories in China and elsewhere can’t rely on a once per year third party test report.  In our case, we’ve had our testing lab in-house since October 2007 – to check every incoming shipment, no matter what the previous test report says.   Other quality oriented suppliers in the industry do the same, either in China or in the US.

The most important lesson is to understand that compliance is not a destination.  It’s not something that you do once or periodically.  It’s a journey, day in and day out.  The process never stops.  Whatever you did yesterday means little for the product that is produced tomorrow unless you work as hard at being vigilant tomorrow as you did yesterday.

For distributors the lesson is to know your supplier well.  Understand that test reports are only one indication of a good compliance program.  There are many suppliers in the industry with rock solid compliance programs that you can rely on.   Visit with your suppliers whenever you can, either in person or at trade shows, ask to meet or speak with their compliance officer.  Ask what kinds of checks and balances the supplier uses to guarantee consistent, safe and compliant product.

Remember:  In a great compliance program third party test reports are just the tip of the iceberg.

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