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Component testing and the new Falvey letter

 
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Kiki.Fluhr
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PostPosted: Fri Jan 23, 2009 12:37 pm    Post subject: Component testing and the new Falvey letter Reply with quote

http://www.cpsc.gov/library/foia/advisory/323.pdf

Am I right in thinking that this decision allows for component testing until August? I really am not trying to start a fight because I know this is a heated subject, so if I am mistaken please just delete this.
Thanks!
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Mom 4 Life
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PostPosted: Fri Jan 23, 2009 7:25 pm    Post subject: component testing Reply with quote

I would love to find out if there is a final word on this as well!
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Kathleen F.
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PostPosted: Sat Jan 24, 2009 9:16 am    Post subject: Reply with quote

The situation remains unchanged. You are permitted to use a "reasonable testing program" such as XRF testing until August. The nature of XRF is you test the unit by comparing each varying "surface" e.g. "component". So you are neither allowed nor forbidden to do component testing but it must be a "reasonable testing program".

Caution: Dan Marshall of HTA is telling manufacturers they can use vendor supplied certificates of components to comply with the law. This is FALSE. If I were him, I'd worry about being sued.
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PUBLIC MEETING
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PostPosted: Mon Jan 26, 2009 3:38 pm    Post subject: CPSC MEETING Reply with quote

For those of you interested in the meeting and Q@A of the Apparel Industry, please go to the CPSC website and have a look see.

Link is provided, scroll to the bottom of the page.

http://www.cpsc.gov/about/cpsia/apparel.html


Bets
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Kathleen F.
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Posts: 11250
Location: NM Albuquerque

PostPosted: Thu Jan 29, 2009 9:06 pm    Post subject: Reply with quote

I moved an entry from Trace over [url=//fashion-incubator.com/phpbb/viewtopic.php?p=24554#24554]here[/url] which is our section for the activities of kindred.

I removed Tracy D's entry because the Etsy entry turned her around (Tracy, you are correct).

It's prolly best to just link to other entries off site rather than printing them in their entirety here (unless there's no other option of course) because people then confuse information published here, as having passed muster and that's not necessarily the case.
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Trace
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PostPosted: Fri Jan 30, 2009 8:35 pm    Post subject: Latest CPSC letter on testing changes Reply with quote

Okay, so now it looks like most industries are in the same boat along with the thrift stores and eBay sellers... You're not required to test or provide certification for your products, but if you sell something with lead (or phthalates, for manufacturers), you're still in violation of the law.

CPSC Grants One Year Stay of Testing and Certification Requirements for Certain Products
http://cpsc.gov/cpscpub/prerel/prhtml09/09115.html
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Eric H
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Joined: 02 Feb 2007
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Location: NM Albuquerque

PostPosted: Sat Jan 31, 2009 9:12 am    Post subject: Reply with quote

In fact, this more or less puts everyone back to the situation shortly before the law was passed. 600 ppm was the limit on lead then, you just didn't need to test or produce GCCs for it. Now you have other obligations, and you still have the reasonable testing program. Moore's letter said something like, "If you weren't having safety problems before, I would continue manufacturing."

But as Kathleen has been pointing out, the industry is changed for good in the wake of this. Those of you thinking, "Ah-HA! reprieve! I can stop worrying and go back to what I was doing" are going to find themselves gradually sinking below the surface and will finally disappear when the stay is lifted.

I think that was a little optimistic since we know that Jennifer Taggart was finding things that tested positive for lead. Moore also suggested that you start demanding compliant inputs from your sources, a hint that he is strongly in favor of component testing. Don't wait a year to start scrutinizing your sources.
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Tracy D
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PostPosted: Sat Jan 31, 2009 10:47 pm    Post subject: Reply with quote

I think that if I had a choice of two suppliers of say white batiste, same quality, but one has a gcc and the other doesn't. I'd be willing to pay even a little more for the tested fabric....assuming the testing would be ok for me to use too. (if that makes sense, it's getting late and it's been a long day)

Tracy D
in Texas
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