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CPSC small business ombudsman

 
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Heather Zakian
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PostPosted: Tue Sep 27, 2011 12:54 pm    Post subject: CPSC small business ombudsman Reply with quote

So, it doesn't look like anyone has posted on this topic for a while, but as I work through the necessities for my own products, I thought I would share with you guys.

I found the CPSC Small Business Ombudsman (http://www.cpsc.gov/businfo/smbus.html), Neal Cohen to be tremendously helpful. I used the "contact form" and it did take him about a month to respond, but he responded with a very long (7 page) and very thorough response to my requirements as a children's product manufacturer.

I'm happy to share my experience if anyone finds it relevant, otherwise, check out the link. Don't bother calling the Sm Biz Ombudsman office...they don't answer.
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Christie Porter
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Joined: 01 Sep 2011
Posts: 31
Location: OH Cincinnati

PostPosted: Thu Sep 29, 2011 6:11 am    Post subject: small business ombudsman Reply with quote

Hi Heather,

It seems you are new to the forum as I am and are involved with baby products. (I knit baby blankets.) I would be most interested in what you discovered when contacting the CPSC small business ombudsman. I am in the process of working through the labeling requirements for my blankets.

Did N. Cohen address any of the exemptions from tracking labels -- such as if the mark would adversely affect product aesthetics?

Thanks and good luck to your new business.
Christie
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Heather Zakian
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PostPosted: Thu Sep 29, 2011 10:47 am    Post subject: Reply with quote

Hi Christie,

Happy to share. He did briefly mention labels. I'm going to copy and paste his email to pertinent to labels here:

Returning to my original list above, EVERY manufacturer (including importer) and private labeler of children’s product must ensure that they follow the following process-oriented requirements:



(1) third party test their product from a CPSC recognized laboratory; (http://www.cpsc.gov/cgi-bin/labsearch/ ) THIS IS WHERE YOU CAN LOCATE A RECOGNIZED LAB

(2) issue a “children’s product certificate of compliance” for their product; (http://www.cpsc.gov/about/cpsia/faq/elecertfaq.pdf) and THIS IS WHERE YOU CAN LOCATE A MODEL CERTIFICATE

(3) affix a permanent ‘tracking label’ to their product. (http://www.cpsc.gov/about/cpsia/sect103policy.pdf) THIS IS WHERE YOU CAN LOCATE INFO ON TRACKING LABELS

I do want to also mention that he also said this in the beginning of his very lengthy email: "There are currently no exceptions based on the size of the businesses or based on whether the children’s products are being donated. To be clear, third party testing means that you cannot test it yourself but must pay a third party laboratory recognized by the CPSC as qualified to conduct the required test(s). (*This may possibly change in the near future as a new law recently passed – H.R. 2715, August 12, 2011 – but our agency still needs to take action to implement it.) "

I have a follow up email asking for any exceptions/exemptions for small businesses that came out of HR 2715, happy to pass along when I receive.

I hope this helps you!
Heather
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