On December 18, 2008, The National Association of Manufacturers (NAM) submitted an exhaustively inclusive 15 page document (pdf) in response to the Consumer Protection Safety Commission’s request for comments in response to the Consumer Product Safety Improvement Act (CPSIA). After a careful reading, I heartily endorse this plan. Furthermore, I commend NAM for their proactive stance in this matter.
Other entities supporting the plan:
- American Apparel & Footwear Association
- Association of American Publishers
- Book Manufacturers Institute, Inc.
- Fashion Jewelry Trade Association
- Juvenile Product Manufacturers Association
- National Association of Manufacturers
- National Association of Printing Ink Manufacturers
- National Retail Federation
- Retail Industry Leaders Association
- Printing Industries of America
- Specialty Graphic Imaging Association
- Toy Industry Association
Feel free to comment if you’re not represented by one of these groups. For the greatest impact, consider printing the plan and mailing it to the address included in the header. Be sure to include your contact information with your statement that you support it.
I absolutely support this position. I work in a regulatory agency for my day job and I can tell you that science and policy often become disconnected. These comments reconnect them in the case of the CPSIA and proposes a policy solution that is supported by the science and still affords children the additional safety that our Congress intended (even though they grossly overshot their mark). Please support this position if you can. I plan to send a copy to CPSC AND to my congressional representatives….they need to read this, too, because I think many of them likely remain blissfully ignorant of their idiocy. We need to remind them.
Oh yes…
If you are a small manufacturer and wish to copy and send your comments, be sure to cite the online petitions in your statement of support that you attach to the NAM plan.
The online petitions provide real evidence to support the statement in the NAM plan that 1000s of small and medium sized businesses will be put out of business if common sense does not prevail.
Keep in mind that Congress probably had no real concept of the number of small businesses that this would effect, in part, because our businesses are not really accurately represented in Census Bureau stats (a primary source of information). And, Congress also conveniently by-passed the Regulatory Flexibility Act, which would have required an analysis of the CPSIA’s impact on small business. So, it’s up to us to let them know we exist and that we matter.
Citing petition statistics in your support letter will help us to do that.
Our petition (based on the concerns of small DEs) has almost 5,000 signatures since Nov 22, and the Handmade Toy Alliance petition has more than 5000. and, they just put theirs up on Dec 9. These petitions have the support of both manufacturers and consumers alike. (There’s another one just posted but it hasn’t gotten a head of steam yet.)
http://www.ipetitions.com/ and enter “CPSIA” in the search box. Click on the petition you’re interested in and then click on the signatures tab to get the numbers.
Please support the NAM plan. It addresses the concerns of all our businesses, large and small. And, based on my experience in regulatory work in which I routinely review and respond to public comments, I can tell you that the CPSC will take these comments seriously because they are well written, well supported and thus hard to dismiss.
This is right on! The only thing I haven’t done to date is to respond to the comments request from Congess on the CPSIA. I am 100% behind the NAM petition and will just send in a “ditto.” This sure sounds better than the 4 page letter I sent my congressman. The only thing I was wondering about is the phalates in plastic – there was no mention of this. My understanding from the latest CPSIA update was that everything manufactured BEFORE Feb 9, 2009 was exempt, but this hardly addresses the issue. I don’t even understand if and how they occur in buttons- is it the dye? Or did I miss something obvious and this has already been digested?
No body wants to sell products dangerous to children, most childrenswear manufacturers have children of their own. The problem with the law as it is written is it is unclear, and it does not give companies enough time to comply. Forcing companies to go out of business doesn’t make our kids safer.Moreover, the process for tesing is too cumbersome, not well thought out and very, very costly.!!!! The domino effect that this will have is going to be devastating in this economic climate. Some manufacturers have been producing lines to be delivered for spring for months now- what will happen when goods get delayed because certifications weren’t available in time. The nightmare with this is just beginning.