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Question... and discussion to follow

 
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michael.martinez
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PostPosted: Thu Dec 11, 2008 11:41 pm    Post subject: Question... and discussion to follow Reply with quote

Has anyone considered that specialty fabric suppliers/manufacturers and manufacturers of specialty garments deal with these types of laws everyday?

Has anyone considered asking them what they've done ensure some kind of say in the matter?

Further, is it not dangerous to be perceived as a manufacturer/designer/group that doesn't want the utmost safety for the end users of said manufacturers /designers/groups product(s)?

I ask not to be divisive, but with sincerity and a bit of devils advocate. There are two parties at work here and its not strictly the government vs. manufacturers/designers/groups. There was obviously a huge outcry for something to done from groups of people along the way. Have these people disappeared? Will they not return if they see radical changes to something they think is beneficial to the end users?

This is a slippery slope. These types of laws are NOT created in a vacuum.

There are many groups that already deal with these types of laws and have done so for a very long time. Firefighter gear manufacturers have exactly 3 labs in the U.S. too test products and ONE of them is owned and operated by a manufacturer. The fabric suppliers/manufacturers share everything with the manufacturers of the product who share everything with the end users. There are no secrets when it comes to testing, sourcing and requirements.

In a similar vein, many occupational garment manufacturers are subject to these types of regulations as well. Why should consumer manufactures be held any less accountable?

If the problem with the CPSIA is perceived to be money for testing and the hassles related, a person/group that is FOR the new CPSIA requirements would only need to trot out ONE child who has been effected by lead poisoning or other ghastly affliction related to a sewn product. The case for those against the new CPSIA would be blown immediately in such a hearing.

The fire service is bombarded with new standards and laws on an almost monthly basis. When a firefighter dies or is hurt badly in the line of duty and the cause is anything except said firefighters actions. I.e. gear failure. We can expect to see a new policy, law or regulation in the following weeks or months. Same with mining, electrical work, construction, lab work, etc.

From my reading, I gather this is the second or third major law/act towards holding consumer garment manufactures more accountable for what they produce. You should consider yourselves lucky. I'm not saying lay down, I'm saying that there are a lot of folks that think this is a step in the right direction. 40 years ago, a law regarding children using bike helmets would have seemed ludicrous. Put that to a vote in most cities today and I bet the majority would mandate that children need to wear helmets when riding bicycles.

Please don't get angry at this; I'm only trying to show another POV.
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Miracle
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PostPosted: Fri Dec 12, 2008 12:21 am    Post subject: Reply with quote

Quote:
Has anyone considered that specialty fabric suppliers/manufacturers and manufacturers of specialty garments deal with these types of laws everyday?

Has anyone considered asking them what they've done ensure some kind of say in the matter?

Further, is it not dangerous to be perceived as a manufacturer/designer/group that doesn't want the utmost safety for the end users of said manufacturers /designers/groups product(s)?

....

If the problem with the CPSIA is perceived to be money for testing and the hassles related, a person/group that is FOR the new CPSIA requirements would only need to trot out ONE child who has been effected by lead poisoning or other ghastly affliction related to a sewn product.


Actually the problem with the CPSIA is not that it requires testing, it is that the way that it currently requires testing creates redundancy and multiple tests for the same items. If it allowed manufacturers to accept supplier provided certification for inputs, this wouldn't be an issue and there wouldn't be such an uproar.

I think the community has been clear on the issue, no one is trying to get out of testing, they are trying to get out of testing the same things, repeatedly, to comply with the law. Add that to the reality that the lack of allowing supplier provided certification means that each manufacturer using the same items to make the same end product is testing it individually.

I know that you don't consider this serious, potentially crippling, issue for child product manufacturers, but it honestly is. Are you going to help?
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michael.martinez
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PostPosted: Fri Dec 12, 2008 10:00 am    Post subject: Reply with quote

miracle wrote:

Actually the problem with the CPSIA is not that it requires testing, it is that the way that it currently requires testing creates redundancy and multiple tests for the same items. If it allowed manufacturers to accept supplier provided certification for inputs, this wouldn't be an issue and there wouldn't be such an uproar.

I think the community has been clear on the issue, no one is trying to get out of testing, they are trying to get out of testing the same things, repeatedly, to comply with the law. Add that to the reality that the lack of allowing supplier provided certification means that each manufacturer using the same items to make the same end product is testing it individually.

I know that you don't consider this serious, potentially crippling, issue for child product manufacturers, but it honestly is. Are you going to help?


I'm pointing out that many, many groups of garment manufacturers deal with the same types of laws. I'm also pointing out that Children have been moved from the standard definition of consumer. They are moving, have moved, to a protected class and MORE of this type of legislation should be expected going forward.

I'm saying put this to a vote and/or hearing, where do you think the people/jury/legislators will stand? Its pretty obvious to me.

To make gear that will be worn by a fire fighter, I have to pay UL crazy $$$ to test. If I want to repair fire gear, I have to make a sample for UL or intertek to test and the fee is $10K to get certified. If I fail there is no explanation, just pay again to have another go.

The fabric used for the fire service is tested at the yarn level, the loom level, the component level and finished product level. There are a myriad of different tests along the way. Manufacturers say this is redundant, Firefighters say this is necessary... so it really depends on who you ask.

There is just so much of this act that is still very unclear. If this was the fire service, to draw a comparison, we would take a "wait and see" approach. Front running legislation/standards/CFR's HAS been proven to be a time and money waste for the fire service, because legislation/standards/CFR's can change so radically from the initial, second and third subsequent iterations.

Sure, I like to help... but its hard to be fired up when so much is still unclear. I understand that this is new to most, but you must realize that other garment manufacturing groups have been dealing with these business prohibitive laws for a LONG TIME.
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Miracle
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PostPosted: Fri Dec 12, 2008 10:46 am    Post subject: Reply with quote

You make safety gear for people who fight fires.

How on earth is this comparable to a cloth diaper, for instance?

I don't even know why I entertained this. Yes children should be safe. I have children, I get it. But I also get that this law is built with an insane level of redundancy that wastes resources. Have you really read up on it?

If you make fire gear you knowingly went into a field to manufacture items to protect the lives of those who are in a very dangerous, potentially deadly, line of work. That would be comparable to making CDC suits, or bulletproof vests, not onesies and t-shirts. This is not about that, it's about lead and phthalates. It is about a poorly thought out testing requirement for phthalates and lead.

It's not that the industry doesn't want to test. They don't want to keep testing the same items repeatedly, for no other reason than the legislators who enacted it did not understand how good manufacturing principles work in various industries and who did not understand how to set up efficient testing programs.

That is the crux of the issue. Saying "so what other industries have to test too" is completely ignoring the actual issue with the legislation and telling manufacturers to sit back and "deal with" poorly written regulations.

Are you going to help?
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SarahM
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PostPosted: Fri Dec 12, 2008 11:14 am    Post subject: Reply with quote

Thanks for your POV. But it's a different case scenario. You are looking at a much smaller and totally different market.
Fire fighters vs. Children 12 and under.

I am confident the kinks will work themselves out of this SNAFU, but only with activism and speaking up about the process will this happen.
While appreciated, other comments take time away from the effort.
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Kathleen F.
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PostPosted: Fri Dec 12, 2008 11:48 am    Post subject: Reply with quote

Mike, your posts have been verging into trolling territory for some time now. Around here, we DNFTT. We lack the time and energy to reiterate the points of contention that you should have read before posting on the matter. We're not going to argue the case with you. Read up and then post. Otherwise I'll move your threads to the off topic area.
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