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In 1988, Congress enacted the Labeling of Hazardous Art Materials Act ("LHAMA"), 15 U.S.C. 1277. LHAMA mandated the ASTM D 4236 standard as a mandatory Commission rule under section 3(b) of the Federal Hazardous Substances Act ("FHSA"). The requirements of the LHAMA became effective on November 18, 1990.