Although I totally appreciate the need to be concerned about lead and appreciate the CPSIA regulations, I believe that these regs came about because of off-shore products.
As US manufacturers we already have a laundry list of regulations to insure safety...from clean air to material handling. The CPSIA requirement for additional testing is yet another layer of expense, time and paper trails.
As a US manufacturer I have to comply with CPSIA to satisfy 'global' manufacturers. Shouldn't off-shore manufacturers have to comply with a quasi-Clean Air Act as part of consumer advocacy?
Our MSDS information should suffice with respect to lead content. If not, then perhaps a simple modification to this report should do the trick...not another layer.