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ACTIVISM: Consumer Product Safety Improvement Act
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Heather
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Joined: 21 Aug 2008
Posts: 202
Location: NY Manhasset

PostPosted: Fri Nov 21, 2008 6:55 pm    Post subject: Reply with quote

Hi Kathleen
I sent $50 to start to offset your AAFA costs. I know it's not alot, but if everyone kicks in a little something....it all adds up. Thank you for stepping up and going to the meeting in December. I am contacting all my friends from previous jobs and spreading the word. I've also been trying with WWD. Usually this time of year is quiet in the garment center-you'd think they would be all over this. Heather
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Valerie Burner
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PostPosted: Fri Nov 21, 2008 7:04 pm    Post subject: Reply with quote

I wonder if there is any way to be heard and get the regs changed by this route.... We still have 60 days...

http://news.yahoo.com/s/ynews/20081121/pl_ynews/ynews_pl158
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Jody
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PostPosted: Sat Nov 22, 2008 12:55 pm    Post subject: Reply with quote

Hello all,
I’ve seen a whole lot of good ideas on this thread on how to fight this thing. But, I’m finding it increasingly difficult to follow everyone’s efforts. Waging an effective battle requires strategy. To that end, I’d like to recommend that we get a little more organized to increase our effectiveness.

From all the comments posted here, at least five good approaches have emerged. What I would like to do, with Kathleen’s help, is to post a separate thread for each. What I’m suggesting is to use separate threads on this forum much like you would create subcommittees under a Board. This way, when any of us completes a task such as contacting a specific media outlet, posting on a specific blog, etc., we can post to the appropriate thread. Likewise, when each of us is working on something, we can go straight to that thread to find out what’s been done so far so that no one ends up spinning their wheels. We have lots of energy and connections here – we need to use both very wisely to avoid burn out.

1. Distribution of materials through the Internet to get our message out there for the purpose of generating support at the grassroots level (through blogs, listservers, discussion groups on Etsy, eBay, posting iPetitions, etc.)
2. Flooding our Congressional representatives with comments
3. Flooding CPSC with comments
4. Generating media interest in our concerns
5. Working through and alongside professional trade organizations to get our message heard
6. Any others?


Kathleen, I'll leave it to you to decide if you want to post these topics under separate threads. I don’t know how much extra work this is (I’m no techie). And, I may be the only one having difficulty following our work (I've been pretty puny lately). I'm just thinking it may help us to stay more organized. Your call...

Regarding the revisions to the letter, I’ve gathered this group's comments and have begun the editing process. It occurs to me that we really need to target our concerns about this legislation to the audience we are appealing to. To that end, I am drafting different responses for us to send to different audiences. I’ve set aside the entire weekend for this work so be advised that it may take me until tomorrow to get them all done. The CPSC letter will be done today as promised.

Our letter to send to Congressional representatives:
This is feel-good legislation, both among Congress and consumers, both of which are uneducated about its real cost to them and our economy as a whole. We have to be mindful that because this law was intended to provide greater protection for children, we must be very careful in our efforts to avoid the appearance that we care more about our pocketbooks than child safety. If this happens, we will lose any credibility we might be able to gain as we move forward in this thing.

Given this, I’m going to rewrite our letter to emphasize that greater protections for children are a good thing, but Congress wrote this law in such a way as to impose unintended and very negative consequences in numerous industry sectors while resulting in very little gains in child safety. The draft letter needs some balance.

Our letter to the media:
I’m going to write an appeal to the media that plays on the insatiable desire to get the scoop on everyone else. Right now, all the coverage we find focuses on toys and essentially congratulates Congress on providing greater protection for children. This is why we are getting an underwhelming response to concerns. But, the good news is, it’s getting coverage.

So, I think a good strategy will be to send our appeal, once I get it drafted, first to those media that have recently covered the CPSIA (Washington Post, Wall Street Journal), then to as many other big guns we can find. This appeal should emphasize a different angle to the story that other media are ignoring (this is the scoop factor), that is, the impact to the economy in February. Here again, I will try to draft a letter that puts our concerns within the context of unintended consequences. I will try to get a release drafted for media today, but I can’t promise….I want to focus on our letter to CSPC.

Our Letter to CPSC
I think the letter we have drafted, once I go through your suggestions, will be ready (no major revisions appear to be needed based on your comments).
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Brenda
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PostPosted: Sat Nov 22, 2008 1:01 pm    Post subject: Safety Commission and Congress link Reply with quote

I found this link from the Toy Industry Assoc. You can use it to contact the right folks:

http://www.toyassociation.org/AM/Template.cfm?Section=Toy_Safety&Template=/CM/HTMLDisplay.cfm&ContentID=5916

In the midst of this I wonder; Where were the lobbyists for the big manufacturing companies?
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Kathleen F.
Site Admin
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Joined: 08 Sep 2005
Posts: 11075
Location: NM Albuquerque

PostPosted: Sat Nov 22, 2008 5:40 pm    Post subject: Reply with quote

Jody wrote:
I’m finding it increasingly difficult to follow everyone’s efforts. Waging an effective battle requires strategy. To that end, I’d like to recommend that we get a little more organized to increase our effectiveness.

From all the comments posted here, at least five good approaches have emerged. What I would like to do, with Kathleen’s help, is to post a separate thread for each. What I’m suggesting is to use separate threads on this forum much like you would create subcommittees under a Board. This way, when any of us completes a task such as contacting a specific media outlet, posting on a specific blog, etc., we can post to the appropriate thread. Likewise, when each of us is working on something, we can go straight to that thread to find out what’s been done so far so that no one ends up spinning their wheels. We have lots of energy and connections here – we need to use both very wisely to avoid burn out.

1. Distribution of materials through the Internet to get our message out there for the purpose of generating support at the grassroots level (through blogs, listservers, discussion groups on Etsy, eBay, posting iPetitions, etc.)
2. Flooding our Congressional representatives with comments
3. Flooding CPSC with comments
4. Generating media interest in our concerns
5. Working through and alongside professional trade organizations to get our message heard
6. Any others?


Kathleen, I'll leave it to you to decide if you want to post these topics under separate threads.


Done. They are here:
Activism CPSIA: ONLINE
Activism CPSIA: CONGRESS
Activism CPSIA: CPSC
Activism CPSIA: MEDIA
Activism CPSIA: TRADE GROUPS

In addition, I'm working on a separate website to act as a central clearing house.
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Miracle
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Joined: 13 Jan 2006
Posts: 946
Location: CA

PostPosted: Sat Nov 22, 2008 5:44 pm    Post subject: Reply with quote

Kathleen,

Have you made the CPSIA section available to ALL, as opposed to approved members? It should be a "public" section
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Kathleen F.
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PostPosted: Sat Nov 22, 2008 6:07 pm    Post subject: Reply with quote

The problem is Miracle, leaving it open to the public means that anyone can see the profiles of members who post there and members have already said they don't want that. That's why I thought I'd start another site.
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Miracle
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PostPosted: Sat Nov 22, 2008 6:31 pm    Post subject: Reply with quote

Really? You don't have a way to disable that? I've been on forums where certain threads were public but I could not see the profile without being a member.
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Kathleen F.
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Joined: 08 Sep 2005
Posts: 11075
Location: NM Albuquerque

PostPosted: Sat Nov 22, 2008 8:09 pm    Post subject: Reply with quote

yeah, I'm sure I can disable that but of course I don't know how. phpbb is the most admin-user unfriendly forum ever. Any minor change like that means installing a new mod. I'll delete this last couple of entries later.

still, the public won't be able to post, which is why I'm doing this other site. I am exhausted...
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Jody
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PostPosted: Sat Nov 22, 2008 10:28 pm    Post subject: Reply with quote

THANKS KATHLEEN!!!

Our revised letter is ready to send to CPSC. I've posted it, along with the necessary mailing address under CPSIA Activism: CPSC
http://fashion-incubator.com/phpbb/viewtopic.php?p=18803#18803

I also put together an iPetition using a modified version of this letter. The mechanics of the iPetition are discussed in my post on: Activism CPSIA: Online
http://fashion-incubator.com/phpbb/viewtopic.php?p=18802#18802

Here's the link to the petition. It will continue to evolve a bit in terms of functionality. But, please waste no time in distributing it: http://www.ipetitions.com/petition/economicimpactsofCPSIA/
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mhswope
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Joined: 22 Feb 2007
Posts: 3528
Location: PA State College

PostPosted: Sun Nov 23, 2008 12:41 pm    Post subject: Reply with quote

I'm so grateful, Kathleen, that you're going to create another public website. I have at least 2 friends who make baby items to sell locally, and they will both write letters, etc. I know there are many many people (ie, like on etsy) who don't belong to the forum who would be active, especially if we make it easy for them.

Marguerite
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Miracle
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Joined: 13 Jan 2006
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PostPosted: Sun Nov 23, 2008 10:08 pm    Post subject: Reply with quote

One thing I am not clear on:

On the blog it says that the estimate for testing a line of 10 pcs in 3 colorways is $30K. Does the law state that a manufacturer has to test each version of each GARMENT (vs testing the actual components) or was that someone's interpretation of the law?

And if so, who interpreted it this way?

I am still unclear about this.
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Esther
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Joined: 17 Mar 2006
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PostPosted: Mon Nov 24, 2008 8:36 am    Post subject: Reply with quote

Quote:
On the blog it says that the estimate for testing a line of 10 pcs in 3 colorways is $30K. Does the law state that a manufacturer has to test each version of each GARMENT (vs testing the actual components) or was that someone's interpretation of the law?


The whole thing is rather confusing. The law as it stands now says each unit must be tested individually. Of course this is impractical with clothing because some tests cannot be done as a unit, at least not easily, flammability being one of them.

Quote:
‘(2) THIRD PARTY TESTING REQUIREMENT.—Effective on the dates provided in paragraph (3), before importing for consumption or warehousing or distributing in commerce any children’s product that is subject to a children’s product safety rule, every manufacturer of such children’s product (and the private labeler of such children’s product if such children’s product bears a private label) shall—

‘‘(A) submit sufficient samples of the children’s product, or samples that are identical in all material respects to the product, to a third party conformity assessment body accredited under paragraph (3) to be tested for compliance with such children’s product safety rule; and

‘‘(B) based on such testing, issue a certificate that certifies that such children’s product complies with the children’s product safety rule based on the assessment of a third party conformity assessment body accredited to conduct such tests.

A manufacturer or private labeler shall issue either a separate certificate for each children’s product safety rule applicable to a product or a combined certificate that certifies compliance with all applicable children’s product safety rules, in which case each such rule shall be specified.


The CPSC has yet to define what it means to submit samples that are identical to the product. The hope with textiles is they will allow component testing.
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Miracle
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PostPosted: Mon Nov 24, 2008 9:03 am    Post subject: Reply with quote

So then where did the $30K figure come from?
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Kathleen F.
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Joined: 08 Sep 2005
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PostPosted: Mon Nov 24, 2008 11:41 am    Post subject: Reply with quote

miracle wrote:
So then where did the $30K figure come from?

I'm the one to blame for this if anyone is. I came up with this figure based on the quotes for testing that Esther sent me. The $30,000 presumed ten styles in three colorways, a reasonable estimation of the size of product line put out by a small producer. The prices quoted for the various tests ran from $500-$982. I ran with the higher figure for two reasons.

1. The testing quote didn't include phthalate or heavy metals due to come on line in Aug '09 and

2. Inflation in price quotes. One thing everyone is forgetting is we don't have enough labs to test all this stuff. Assuming market demand and lab services are in equilibrium, a dramatic increase in the demand for testing is going to cause prices to shoot up.
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