CPSC issues new guidance document for CPSIA compliance. There is nothing new in this document, but it DOES explain things in regular English. Of note: they promise a future rule on component testing. Component testing, combined with the exemptions they’ve made so far for fabric, will make my life SO MUCH easier. The record-keeping part is still a pain in the tukus, but I think I’m slowly getting the hang of it.

This one about books. My favorite line:

A further question is what to do about public libraries, which daily expose children under 12 to pre-1985 editions of Anne of Green Gables, Beatrix Potter, Baden-Powell’s scouting guides, and other deadly hazards.

The New Book Banning.

One CPSC commissioner, Thomas Moore, has already called for libraries to “sequester” some undefinedly large fraction of pre-1985 books until more is known about their risks.

…almost no one has cared to consider the law’s broad array of unintended consequences, let alone ask what went wrong in the near-unanimous rush to passage of this feel-good law.

Whatever the future of new media may hold, ours will be a poorer world if we begin to lose (or “sequester” from children) the millions of books published before our own era. They serve as a path into history, literature, and imagination for kids everywhere. They link the generations by enabling parents to pass on the stories and discoveries in which they delighted as children. Their illustrations open up worlds far removed from what kids are likely to see on the video or TV screen. Could we really be on the verge of losing all of this? And if this is what government protection of our kids means, shouldn’t we be thinking instead about protecting our kids from the government?

This last paragraph is, for me, the most heart-wrenching one. Wally’s and my FAVORITE books are those from my childhood – or my dad’s childhood. Yes, I expose my children daily to the hazards of old books. I think we’re more likely to suffer problems from the mildew-y smell on some of them than from the lead in the paint.

I can’t imagine losing all of those.

And, I’ll be honest, we have a hard time finding MODERN children’s books that are as good. We find some that are OK. But a lot of them are crap. The illustrations are confusing or just too dang much. The writing is terrible. The characters are hardly memorable – some are outright annoying.

Sigh. I do not like the world we’re headed into.

Read her blog post about it – she raises many of the issues I’m struggling with.

http://organicbabyfarm.blogspot.com/2009/08/decision-to-close.html

Seriously, though, couldn’t they have done this a few months ago??

http://www.cpsc.gov/about/cpsia/sect103policy.pdf

Good news: They have defined “location of manufacture” to mean city and state.

Good news: They have noted that they recognize that “date of production” is a little undefinable, since MOST products are manufactured over the course of several days. “date” can be a range. For me, I’m assuming that then means “date” can mean Month and Year.

Also, regarding Cohort information:

Although Section 103(a) does not require manufacturers that do not use lot, batch or run numbers to create such a system, the Commission believes that compliance with this Section generally will require that manufacturers have in place a reasonable means to ascertain detailed production information, including the means to distinguish products made from different factories, made with different components, at different times or have other material differences that make the product non-identical from previous products. The business and recordkeeping practices of peer manufacturers should be considered.
Small volume manufacturers and crafters may be unlikely to use lot, batch or run numbers, and, again, the Commission does not interpret Section 103(a) to require them to create such a system. Nevertheless, reasonable practices should be in place by such manufacturers to keep records of components used in their products.

So, you know, you don’t HAVE to, but you have to. Which is fine. I’m not totally on board with the whole Fashion Incubator coding system thing yet, but I think I have a system worked out (in my head anyway) that will accomplish this goal of tracking every time something changes. Should not be hard, actually.

But it will be time consuming, yet another piece of paperwork cluttering up my time and sucking the joy out of what I do.

But, I am SUPER GLAD to read these clarified expectations from the CPSC. Let me state again that I think they’re doing a good job with the mess they were handed.

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…

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.

809e69df

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.

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.

Contact your Congressmen and women and ask them to support HR1815, the Consumer Product Safety Solutions Act of 2009. The bill was introduced by Energy and Commerce Committee Ranking Member Joe Barton, R-Texas, and could extend certain deadlines, provide more flexibility to the Consumer Product Safety Commission to grant exemptions and adjust testing and labeling requirements to allow alternate methods.

The PPAI (promotional products something something) has a good sample letter that you could customize. The link to the letter on their post opens to a MS Word document, just a warming there. (Obviously, remove the statement that you’re a member of PPAI.)

Additionally, Rick W has another great post on the CPSIA, framing it as economic incentive rather than a safety issue.

I don’t have the energy to respond to the Consumer Reports blog post about the CPSIA, but I didn’t realize until now how full of lies those publications must be.

Here is some good CPSIA Myth Busting.

Part One

Part Two