Oh, the joys of reading government lingo early in the morning. I found a link to the act after my publisher spread the word about some of the changes called for by this legislation.
Concerns are about testing and how the publishers are held accountable for books that may or may not have lead in them, when the printers are the ones who have control over that aspect.
This reminds me of working in the automotive industry! I worked with quality for over five years, and I learned quite a bit from the stringent regulations.
1. The highest order corporation leans on everyone who supplies them. (In automotive, that meant Ford, GM, Toyota, etc.)
2. Tier 1 suppliers lean on their suppliers. (Names get less recognizable, but Visteon and Delphi are among them.)
3. Down the line, the people who actually make the individual pieces implement all kinds of quality measures to show they’re doing what they’re supposed to be doing.
This is how QS-9000 and TS-16949 became the quality intiatives (at different times) in the industry. We needed a way to show we’d followed everything we needed to, and though it isn’t always the most efficient way, it did make everyone follow a procedure.
Our publishers need to lean on the printers to certify that they’ve tested for lead in the paper, ink, and other materials. They’d need to do this for all books that might come in contact with children, and their batches could be by paper batch or ink batch rather than by book title. Book title, especially in the smaller presses, seems cost prohibitive. If it is distributed over paper (or other material) batches, which you’d think would contain entirely the same amount of lead throughout, would make it possible to follow.
What happens if someone screws up? That’s where you keep the proof. Printer certifies it, and the publisher keeps the documentation. Printer keeps the documentation they have, as well as copies of their batch tests. They’d also need to keep records which batches did which titles.
Definitely something to watch.