DILLARD S TEST PROTOCOL FOR DILR US PICTURE FRAME (V6)

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1 Test Date: Reviewed By/Date: DILLARD S TEST PROTOCOL FOR 1 The sample should be reviewed against the requirements of California Proposition 65 to determine if additional testing or labeling is required. Note: Additional cost, sample size & TAT may be required if testing to 1 or more supplemental protocols is necessary. Please refer to the above referenced supplemental protocol(s) for additional information. LABELING One Time Use Products **Fair Packaging and Labeling Act OR All Other Products **Uniform Packaging and Labeling Regulations F.P. & L. Act (16 CFR 500) OR NIST Uniform Laws and Regulations Handbook Manufacturer, Packer, or Distributor s Name & Address (City, State & Zip) Product identification Net quantity of contents shall be expressed in terms of weight or mass, measure, numerical count, or combination so as to give accurate information to facilitate consumer comparison (U.S. and metric units). **Country of Origin Marking 19 CFR Shall indicate country of origin legibly, permanently, and in comparable size and close proximity to any mention of country other than country in which the article was manufactured or produced. Must be visible at point of purchase. Use labeling SCOPE: This protocol is applicable for testing of picture frame. SUPPLEMENTAL PROTOCOLS * CA Prop 65 Applicable Section from Protocol CPSD-AN- PTCL US / Visual 1 Use / care instructions that are clear and understandable shall be provided in language appropriate to destination countries. Page 1 of 10

2 Claim verification - level 2 CPSD-GB All Examine the retail packaging (or submitted artwork). Record each objective (factual) claim which can be substantiated by the testing within the protocols and rate accordingly. Record testing that extend beyond existing net quantity / dimensional testing on this protocol. Record all other objective (factual) and subjective (opinion) claims as NT and rate as DATA. Record information evaluated between the graphic imagery and the product. Record disclaimers on datasheet. Page 2 of 10

3 If wood of any type is present in the sample, submitter shall provide a completed and signed Sample Declaration Form. Sections A, B, and E of the Sample Declaration Form must always be completed. If regulated composite wood is not present in the sample, result is N/A. * EPA TSCA Title VI Composite Wood Sample Declaration Form and Mill Certificate 40 CFR If regulated composite wood is present in the sample: - Section D of the Sample Declaration Form must also be completed - Submitter shall provide a copy of the certificate issued by the Third Party Certifier (TPC) for the mill(s) from which the raw panels were purchased - All information on the certificate shall be consistent with the Sample Declaration Form Notes: Include a copy of the Sample Declaration Form in the report Regulated composite wood includes: - Hardwood plywood (HWPW) - Medium-density fiberboard (MDF) - Thin medium-density fiberboard (Thin MDF) - Particleboard (PB) Mill certificate that denotes compliance with CARB s ATCM for formaldehyde will be accepted in lieu of a certificate denoting compliance with TSCA Title VI until March 22, Rating Schedule: - On or before May 31, 2018: Compliant submission shall be rated as pass Non-compliant submission shall be rated as data - On or after June 1, 2018: Compliant submission shall be rated as pass Non-compliant submission shall be rated as fail Page 3 of 10

4 Finished goods containing regulated composite wood shall comply with the labeling requirements found in 40 CFR (c) unless the finished good qualifies for the de minimis exception found in 40 CFR (e). A finished good does not require labeling per 40 CFR (c) if the finished good does qualify for the de minimis exception in 40 CFR (e). If the finished good does qualify for the de minimis exception, result is N/A. * EPA TSCA Title VI Composite Wood Finished Good Labeling 40 CFR (c) / 40 CFR (e) - A finished good does require labeling per 40 CFR (c) if the finished good does not qualify for the de minimis exeption in 40 CFR (e). - At a minimum, the label must be on the product OR the packaging - The label may be applied as a stamp, tag, or sticker - The label shall include, at a minimum, in legible English text: 1. Fabricator s name 2. Date the finished good was produced (in month/year format) 3. A statement of compliance to denote that the finished good complies with TSCA Title VI Example: XXX Company MM/YYYY EPA TSCA Title VI compliant for formaldehyde Page 4 of 10

5 [Continue from above] * EPA TSCA Title VI Composite Wood Finished Good Labeling 40 CFR (c) / 40 CFR (e) - Notes: A de minimis amount of regulated composite wood is defined as regulated composite wood content not exceeding 144 square inches, based on the surface area of the largest face of the finished good. The de minimis exception is not available to finished goods or component parts that are designed to be used in combination or in multiples to create larger surfaces, finished goods, or component parts. When a statement of compliance is necessary, a statement of compliance that denotes the finished good complies with CARB s ATCM for formaldehyde will be accepted in lieu of a TSCA Title VI compliance statement until March 22, Rating Schedule: - On or before May 31, 2018: Compliant submission shall be rated as pass Non-compliant submission shall be rated as data - On or after June 1, 2018: Compliant submission shall be rated as pass Non-compliant submission shall be rated as fail Page 5 of 10

6 If wood of any type is present in the sample, submitter shall provide a completed and signed Sample Declaration Form. Sections A, C, and E of the Sample Declaration Form must always be completed. If regulated composite wood is not present in the sample, result is N/A. * CARB ATCM for Formaldehyde Composite Wood Sample Declaration Form and Mill Certificate Title 17, California Code of Regulations Section If regulated composite wood is present in the sample: - Section D of the Sample Declaration Form must also be completed - Submitter shall provide a copy of the certificate issued by the Third Party Certifier (TPC) for the mill(s) from which the raw panels were purchased - All information on the certificate shall be consistent with the Sample Declaration Form Notes: Include a copy of the Sample Declaration Form in the report Regulated composite wood includes: - Hardwood plywood (HWPW) - Medium-density fiberboard (MDF) - Thin medium-density fiberboard (Thin MDF) - Particleboard (PB) Page 6 of 10

7 Finished goods containing regulated composite wood shall comply with the labeling requirements for fabricators found in (d). * CARB ATCM for Formaldehyde Composite Wood Finished Good Labeling Title 17, California Code of Regulations Section (d) - A finished good containing regulated composite wood requires the following: - At a minimum, the label must be on the product OR the packaging - The label shall be applied as a stamp, tag, sticker, or bar code - The label shall include, at a minimum: 1. Fabricator s name 2. Date the finished good was produced (in month/year format) 3. A statement of compliance to denote that the finished good complies with the ATCM Example: XXX Company MM/YYYY California phase 2 compliant for formaldehyde Accuracy or adequacy of instructions Notes: If a finished good is labeled with the EPA compliance statement, a separate statement of compliance to the CARB ATCM is not required. It is not required for the label to state the level of emissions (Phase 2, NAF, ULEF). Labels for finished goods should not include the number of the TPC associated with the composite wood products contained in the finished good. 1 Shall be accurate and easy to follow Page 7 of 10

8 ANALYTICAL *Total lead content in surface coatings AOAC (modified) / CPSD-AN All accessible surface coatings in the as received state on items outside of the scope of 16 CFR 1303 shall not contain lead or lead components in which the lead content is in excess of 0.009% (90ppm) of the weight of the total content. Report actual results or include data table within report. Component testing is allowed. Compositing up to 3 like materials is allowed. FLAMMABILITY Solids - Flammability PHYSICAL CHARACTERISTICS *Plating thickness by optical microscope Dimensions - length x width Dimensions - thickness Dimensions - length x width Weight Parts inventory Hardware provided 16 CFR (c)(6)(vi) / 16 CFR *Metal composition verification ASTM E / ASTM E / CPSD- GB / CPSD-AN ASTM B (R2013) section 7 CPSD-GB CPSD-GB CPSD-GB CPSD-GB Client Requirement 1 Verify the metal composition as per claim. Must conform to specifications. Note: Vendor shall provide documentation specifying type of metal and/or plating for verification 1 Shall meet requirements < 0.1 inch per second horizontal burning. 1 [Applicable to metal and oxide coatings] Report actual as data only. 1 Report overall dimensions; shall meet label claims. 1 Report overall thickness. Shall meet label claims. 1 [Picture area] Report overall dimensions; Shall meet label claims. 1 Report overall weight; shall meet label claims (-0% / +5%) 1 Shall meet label claims. All listed hardware must be provided. All All listed hardware shall be provided Page 8 of 10

9 WORKMANSHIP Sharp point and sharp edge 16 CFR & 49 All (Mod) Defects and workmanship PERFORMANCE Actual use - functionality Tilt resistance Static loading Type of support Hanging strength CPSD-HL All Shall have no sharp points / edges, other than those required for function. Modification: Expanded scope to other products. Shall have no discernible surface degradation, including crazing, shivering, denting, bubbles, cracks, stains, deformations, chips, fractures, heavy lines, waves, shear marks, scratches, scuff marks, indentations, or blisters. Shall have no components missing, malformed, and/or fractured. All Shall function as intended as received. Report details of evaluation (features tested / methods used / materials used / etc.) Report any features not evaluated. 1 [For free standing] Shall not tip over at 8 incline plane in the direction of least stability. 1 [Free standing] Apply 2x the weight of the frame to top of frame, greater than 1/4" movement of either frame or stabilizing leg is to be considered unacceptable. All [Free standing picture frame support arm] The preferred method of attachment of the support arm on table type picture frames is the use of a rivet-through design, where the rivet holds the support arm in place to the backing. Is this method of attachment present or not on the sample submitted for testing? (Yes / No) Please include a photo showing attachment method. 1 [Wall mount] Able to support 2 times actual product (or 2 times claimed) weight supported by attachment system - Apply force that is equal to 2 times the weight. Hold for 24 hours. Shall have no breakage. Page 9 of 10

10 Balance All Wall mounting device or hardware Fit properties Durability Drop test Effects of extreme temperature change CPSD-HL CPSD-HL (Mod) Resistance to corrosion ASTM B (mod) / CPSD-HL Key: * Additional Charge For This Test ** Mandatory Requirement Results Key: Rating Key: M Meets NM Does Not Meet Good Good NA Not Applicable NT Not Tested Fail Fail C Claimed R Recorded [Wall mounted] Evaluate after humidity testing. For wall mounted frames, mount on rack, measure distance of edges parallel to floor line. Will not tilt, or appear off balance. 1 Note if mounting instructions are included and appropriate. Note if mounting hardware and hanger/d-ring/keyhole placement is appropriate. Note if keyhole depth is appropriate. 1 Shall provide good fit of photo with no damage to photo edges while inserting into frame times cycling of moving components, no failure. 3 No breakage after 3 drops from a height of 3 ft 1 24 hours at 0 F and 120 F - No failure or visual change Modification: Exposure time changed from 4 hours to 24 hours 1 [Applicable to samples or sample components constructed of metal or samples with metallic coatings that can be exposed to the environment] Shall withstand 24 hours in 1% salt spray (fog) with no noticeable oxidation / corrosion / visual changes. Modification: 1% salt spray (fog). No. Of Required For Complete Testing: 5 No. Of (Fully Packed) Cartons For Transit Testing: 1 (Only Upon Dillard s Request) Creation Date: June 29,2002 No. Of Working Days For Complete Testing: 7 Editorial Revision Date: APRIL 26, 2018 Pricing Review Date: Technical Review Date: Page 10 of 10

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