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Baby Slings, now a durable good?

 
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Kathleen F.
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Joined: 08 Sep 2005
Posts: 10975
Location: NM Albuquerque

PostPosted: Thu Jul 02, 2009 11:03 am    Post subject: Baby Slings, now a durable good? Reply with quote

It's been brought to my attention that baby slings may now be considered a durable good. Notice was sent last Monday via the cpsc listserv. I have an inquiry out now but can anyone confirm or explain? The reference to the change from CPSC is here (pdf).
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Susan G
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PostPosted: Thu Jul 02, 2009 12:17 pm    Post subject: Re: Baby Slings, now a durable good? Reply with quote

The below quote comes from page 2 of the link in Kathleen's
post. It sounds to me like baby slings are durable even if they are made of fabric.

Additional guidance comes from
considering the product examples in the
statute and the ASTM voluntary
standard subcommittees that cover such
items. The product list in the statute,
though not exclusive, illustrates the
types of products covered. Likewise,
other products involved in the ASTM
voluntary standards committee activity
reflect the type of products considered
by Commission staff to be durable infant
products which include: Children’s
folding chairs, changing tables,
bouncers, infant bath tubs, bed rails and
infant slings.
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Kathleen F.
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Location: NM Albuquerque

PostPosted: Thu Jul 09, 2009 8:11 am    Post subject: Reply with quote

Vesta provides an update:
Quote:
Oh jeez. This is new. Here's a blurb from further into the same document from which your quote was pulled:
Quote:
The statutory definition leaves uncertainty about which products would be considered durable infant or toddler products. Many products may last three or more years, but that does not necessarily mean that Congress intended them to be considered durable infant or toddler products under this section. An infant sling is not specifically listed and might be considered a textile product. However, it could be considered a type of infant carrier, a category that is listed as a durable infant or toddler product. The Commission is interested in comments on whether the final rule should contain a definitive listing of products requiring registration cards or any other comments that could help to clarify which products are covered by the registration card requirement when the final rule is published.

As discussed above, infant carriers that are used as car seats are already subject to registration requirements issued by NHTSA that are similar to the proposed CPSC registration requirements. The Commission proposes to exempt from this rulemaking car seats that are subject to NHTSA registration requirements."

This interpretation is so clearly outside of the intentions of durable products (see below), and I've even seen slings specifically excluded in previous opinions (I'm looking for that right now - it was a previous FAQ, which has either been modified or was in a different section). Basically, because both carseats and slings could be called "infant carriers", they're saying maybe slings are durable, which is silly. But CPSC is just showing how wide the net could conceivably be cast.

From here:
Quote:
Q. Will infants’ crib bedding, blankets, bath textiles, and apparel fall under the heading of “durable product”?

A. No. Congress did not define the term “durable,” but it is commonly understood to mean able to exist for a long time without significant deterioration. Cloth/textile items are generally not considered to be durable goods. None of the items Congress specified in section 104 as examples of durable products are items made entirely of cloth, rather they are primarily made from rigid materials (e.g., cribs, toddler beds, high chairs, strollers, bath seats)."

I, for one, will not be treating them as durable. I think it's a completely unreasonable evaluation of the product.

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annika
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PostPosted: Fri Jul 10, 2009 11:35 am    Post subject: Reply with quote

I cannot find the document now either, but back in November I swear I read that baby slings were specifically excluded. As Vesta says, it is entirely unreasonable for a primarily textile product to be considered a durable good alongside a rigid plastic car seat. I provide an online form by which consumers are requested to register their product but I am not going to be sending out registration cards either.
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Sarah Reid
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Joined: 24 Feb 2009
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Location: IA Des Moines

PostPosted: Sat Aug 01, 2009 8:52 am    Post subject: Reply with quote

It absolutely used to be in the FAQ that baby slings were NOT considered durable goods.

http://www.cpsc.gov/about/cpsia/faq/104faq.html#slings

As of earlier this month, this question included Slings, and that's been removed now. sheesh.

It does, however, continue to state that items made entirely of cloth are generally not durable goods. Slings are, generally speaking, entirely cloth. (Some have buckles and whatnot, but not mine. Cool )

I did submit comments about the registration requirements, indicating that many smaller businesses like mine that sell almost 100% direct to consumers already have a good system in place to keep track of who has what, and that registration cards would, in fact, be LESS accurate, but I doubt they care much. I can currently pull up everyone who's bought a sling from me since I opened and, though it would take some doing and a LOT of time, I could tell you exactly what sling each and every person bought.
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