section 104 – maybe not

CPSC’s changed their website, making finding the FAQ from earlier very difficult. I was able to finally dig up this old FAQ:

http://www.cpsc.gov/about/cpsia/faq/104faq.html#slings

That says that slings are NOT considered durable nursery goods, which is good news if that’s still their stance…

Me to CPSC

These are the comments I submitted today:

I own a small business making fabric baby carriers. My sales, in terms of number of carriers sold, are in the hundreds each year, not the millions or even the thousands. Because of this, and because of my record-keeping, I can currently already pull up the name and address of anyone who’s ever bought a carrier from me, and I can sort that by type of carrier and date of sale. Soon, with CPSIA rules that go into effect in August, I’ll also be able to sort by date of manufacture.

A requirement to include a postage-paid postcard with every carrier would be overly onerous and costly to my business. I can absolutely see the need for this with major manufacturers, who largely do not have any interaction with their end user. On the other hand, small businesses like mine sell almost exclusively directly to the end user. In fact, I currently have more thorough information for my customers than I could ever hope to receive via registration cards, which do not have a 100% return rate. Each person who buys a Wallypop carrier MUST give me their name and address, at a minimum. Most smaller baby products manufacturers who sell direct to the customer work in a similar fashion.

Please consider, when making the final ruling on this aspect of the CPSIA, making exceptions for businesses that can already provide this information on demand. Perhaps requiring a postage paid registration card only if the manufacturer does not already have this information available to them.

This will fulfill the intent of the law, which is to ensure that manufacturers have the ability to contact their customers in the event that such contact is needed.

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CPSIA and Durable Nursery Products

Durable Nursery Products include baby carriers.

The CPSC posted this gem today.

Section 104(d) of the
Consumer Product Safety Improvement
Act of 2008 (‘‘CPSIA’’) requires the
United States Consumer Product Safety
Commission (‘‘Commission’’) to
promulgate a final consumer product
safety rule requiring each manufacturer
of a durable infant or toddler product to:
Provide with each product a postagepaid
consumer registration form; keep
records of consumers who register such
products with the manufacturer; and
permanently place the manufacturer
name and contact information, model
name and number, and the date of
manufacture on each such product. The
Commission is proposing requirements
that would fulfill this statutory
direction.
DATES: Written comments must be
received by September 14, 2009.
ADDRESSES: Submit your comments at
http://www.regulations.gov.

In the hubub over lead rules, I overlooked this little aspect. Yes, if I continue to sell baby carriers, I’ll need to include postage paid registration cards and then deal with all of THAT paperwork. Never mind that I could, right now, pull up a list for you of everyone who’s ever bought, say, a ring sling from me. From that list, I could tell you exactly which carrier each customer bought. And with the new tracking/labeling requirements, I’ll be able to tell you when each sling was made. I don’t need registration cards in the same way that large manufactuerers do.

I’m off to submit my comments.

All About: Ring Slings

Wallypop Ring Slings

A bit about ring slings in general.

Ring slings are often thought of as a pefect beginning carrier, easy to use, etc. While I wouldn’t say that ring slings are HARD to use, they do have a learning curve, and some people just simply don’t get them. I can honestly say that I’ve seen more people have difficulty with a ring sling than with a wrap – not that ring slings are all that difficult, but they’re not as simple as some want you to believe.

A bit about safety.

The rings used in ring slings are of UTMOST importance. The best ring slings are made with rings manufactured by Sling Rings. Their rings are very safe, tested to 250 lbs, and abused in every way possible. Note that some major brand names of ring slings do not use these rings and have had ring-related recalls. Not good.

Now, about Wallypop ring slings.

We make our ring slings from a variety of midweight cotton fabrics – we try to choose fun or understated prints that look good from both sides (front and back). We also make deluxe slings from silk or other high-end fabrics.  You can make a ring sling out of other weights of fabric, but we’ve found that much lighter weight, and the sling tends to cut in to the wearer’s shoulder and the baby’s legs. Much heavier, and it’s just, well, heavy.

We use nylon rings for our cotton slings. In our experience, the nylon rings grip the fabric better than metal, so they’re less prone to slipping.

For the Deluxe slings, we use aluminum rings. Not because they’re prettier or more deluxe, but because the higher-end fabrics we use (silk, satin, etc) tend to be thinner fabrics, and they are more easily gripped by the aluminum.

Wallypop ring slings are unpadded. In our experience, the padding in padded ring slings tends to just make the slings less adjustable, as the padding gets tangled up in the rings. Most people who start out using a padded ring sling, believing they need the padding for comfort, find that switching to an unpadded ring sling is actually more comfortable – they don’t need the padding, after all, and the lack of padding allows a better fit.

The shoulder of our ring slings are made with an inverse double pleat. Um, what? All that means is that it’s SUPER COMFORTABLE! Just wide enough on your shoulder to be comfortable without unduly restricting arm movement, but readily spreads out across your back with minimal bulk. I’ve also found that this type of pleat seems less likely to twist up than others I’ve tried.

Wearing

When you wear your ring sling, always make sure to keep the rings near your armpit. If you find the rings tend to travel down as you adjust the sling, first – start with the sling adjusted a bit shorter to start with, and second, pull OUT not DOWN.

Always keep fabric between you and baby, so that the baby has a secure place to sit. You never want to rely on friction to keep your baby in the sling!

Bacteria in food Ok with Congress?

Got to thinking about this today.

There have been several food recalls in recent memory. Today, cookie dough.

If, in the wake of these food recalls, Congress passed a law requiring all food manufacturers to test EVERY batch of food, once completed, and before sale to the consumer, for bacteria, and if those tests were really expensive and most of the labs to do them were in China, then we might be coming close to the insanity of CPSIA.

Except, wait!

With children’s products that are UNPAINTED, there’s no chance of lead entering the product accidentally. If one tests their supplies pre-manufacture, there’s no way that lead could accidentally enter the product during manufacture or storage. (I mean, provided one is not storing their inventory in, for example, a battery factory.)

Lead doesn’t just grow on things, you know?

But bacteria DOES. I can make potato salad that’s perfectly good, and would test as just fine, free of disease. Then I can leave it out on the counter, or drip chicken juice on it, and voila – it becomes a bowl of diseased nastiness.

It’s so much easier to get bacteria in/growing in food than it is to get lead in a textile.

But yet it’s textiles that have to test post-manufacture, and food that does not. Sigh.

Somebody Asked… about free samples.

Got this email today.

I’ve been wanting to start CD my 1 yr old! But don’t know where to start. I don’t know what kind to try Or what will work for her! I don’t want to buy diapers to find out they don’t work and So I was wondering if you’d be generous enough to send us a sample? We want to try an AIO, pocket, or fitted with cover! Just something So I can get the feel of cloth diapering. We will be buying if they work for her! Thank you for understanding.

Hmmmm. No. I mean, wouldn’t we ALL love that? I’ll take one sample of EVERY type of diaper out there, K? And then I’ll decide which I like best, and buy more. (though if I had gotten enough free samples, I wouldn’t need to buy anything, right?)

My response:

Hello, Heather! No, we don’t send out free diapers, but good luck finding someone who will. I understand your not wanting to experiment, but it’s like anything else in life, and sometimes involves trial and error. Your best bet is to buy high-quality diapers, and stick with something simple like prefolds and covers or fitteds and covers. AIOs and pockets are much more prone to problems.

I’m sure when you started buying clothes for your child, you also didn’t want to buy a brand only to find out it didn’t fit quite right, but I’m sure you also had to learn the hard way that some brands fit better than others, right? Same with food – when our family first switched to natural peanut butter, we hated to spend the money on it only to find out it tasted like butt, however, that’s exactly what we had to do, and eventually we found a great local producer whose product tastes great. I’m sure you’ve experienced the same thing. It’s no different with diapers, or anything else.

We don’t need special jackets!

Out for a walk on a breezy, chilly day.

More babywearing while building pictures

and I promise a return to the All About series in a week or so.

She was NOT asleep, which is bizarrely why I’m holding her head. If she were asleep, I could’ve tucked it into the wrap, but she was awake and having NOTHING to do with that. But every time I leaned over to use the screwdriver, she leaned her head waaaaay back to see what I was doing, and I was afraid I’d drip sawdust in her eyes.

And she is asleep here but still wouldn’t cope with tucking in her head. Whatever.

Narrow Body Podegi

I made myself a narrow body Pod while I was pregnant. The body’s only about 20 or so inches wide, but as long as my usual podegi pattern. The straps are more wrap-like, they’re very wide, and they’re made of twill.

I’m not sure yet what I think of it. Some people at The Babywearer have reported they find a narrow body pod to be easier and faster than a wrap, but just as supportive. I’m not sure I think that’s true for me. I have definitely LIKED the carrier – it’s comfortable and easy to use. I’m just not certain that it’s any better than a wrap.

Babywearing and Construction

Thought I’d share a few pictures of wearing Genna while constructing our chicken coop. Genna was fussy and tired and just wanted to be held, but I needed to work on the coop while it was still light out, so the MT really saved the day.

Note, doing construction with a baby on your front is not easy, but it is doable. If you decide to do any sort of construction while wearing your baby, please take reasonable safety precautions. I didn’t, for example, use the table saw while wearing Genna, or anything else that might cause sawdust or small pieces of wood to come flying at her face.

More here: http://wallypop.wordpress.com/2009/06/02/more-babywearing-while-building-pictures/