CPSIA Updates 10/22/09

I should have been dating these entries all along. Here’s the latest, newest first.

The CPSC is conducting a hearing on November 10th regarding the establishment of a Public Consumer Product Safety Incident Database. Requests to present oral comments are due by November 3rd. On one hand, many are leery of the prospect of a database as it is unclear how whistle blowing will be weighted and processed. On the other, some people will use the resource to report vendors who willfully ignore the CPSIA statute and thus enjoy unfair competitive advantages. Like everything else associated with the law, the database is controversial.

The CPSC has released the latest version (pdf) of the statement of policy governing testing and certification of lead content in children’s products. It is much the same as before but with three differences:

  1. Good: The statement implies we’re closer to a policy of component testing as opposed to the more expensive and destructive unit testing. This is hopeful news.
  2. Bad: The word “untreated” has been inserted before “leather” with respect to materials deemed not requiring testing. This means the majority of people who use leather components are not off the hook for testing anymore. The only exception being users of rawhide.
  3. Mixed: The policy confirms no testing is required of materials (and inaccessible components) listed in the determination. Keep in mind that even if your product is constructed entirely of test exempt materials, you still need to provide a GCC to buyers or have a copy on file if you sell consumer direct.

It has been suggested we can expect the final testing rules in November.

The AAFA is hosting a seminar at FIT in NY on October 29th entitled Moving Beyond the Consumer Product Safety Improvement Act (CPSIA). The is $75 for AAFA and FASA members and $150 for non-members.

Word has it that the Center for Environmental Health (CEH) has expanded its sights to target producers of belts and footwear under California’s Proposition 65 initiative (my previous entry is here). The best source for Prop 65 is the Prop 65 Clearing House. Their September report is here.

Rick Woldenberg continues to lead the charge against the implications and costs of CPSIA. It is imperative that you visit his blog and comment frequently because his site, more than any other, is frequented by powerful decision-makers. If you’ve been frustrated that lawmakers don’t respond to the content of your objections, post a well constructed comment to his site and it’ll have a dramatic impact. It is critical to impress upon decision makers that he’s not a singular nut job who won’t go away; it affects us all. We must demonstrate the strength of our opposition and objections.

Somewhat related: Ironically, the administration announced new small business lending initiatives today. Maybe some of us can pony up for some funding to cover the costs of testing. And then consumers can get stimulus money to offset the increased costs of buying kid’s clothes, shoes, toys and books.

All of the entries regarding CPSIA published on this site can be found here.

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