CPSIA: Confusion run amok

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The title of this entry is a good summary of the AAFA meeting. Not to say people didn’t have a handle on the situation, just that you’re not the only one who is perplexed by the CPSIA regulations and proposed implementation. I don’t even know where to start so this I guess this is a sort of debriefing dump.

To give you an idea, I heard a lot of the same questions there that I’ve heard from many of you. For example, one person thought they were off the hook for the new CPSIA regulations because they only do full package private label and thought their package supplier was going to have to deal with this, not them. Okay people, let’s do a quick review of Manufacturing 101 because many here are also confused on the matter. Whether you own a single sewing machine, you are the manufacturer if you cause the item to exist. That is a legal designation and not my opinion. As an example, go argue about it with the state of California. They are never charmed or patient with one’s self determined definitions of “manufacturer”.

Another item of contention was -get this- what is a style number? And you thought it was just me who ragged on you about those. Debate centered on what is a style number because even there, not everyone uses or designs them to mean the same thing as I’ve explained here. The reason it matters is because required testing will not be according to the looser definition of style number but most likely according to SKU which could be crudely described as the “child” of style numbers. So the end result is, if you’re not on the same page as everyone else and using accepted garment industry practices, something as silly as lack of style numbers (industry standard practices) will trip you up if you’re not following them. The discussion of style numbers, SKUs and tracking processes were just a few things that led me to believe that you won’t be able to skate by on your homegrown developed organizational processes -if you ever really could. Nope, you’re going to have to be a lot more professional. A logical consequence of this legislation is that kids wear manufacturers will become the barre or minimal standard in the application of garment industry standard practices. Better get that book I wrote if you don’t have it yet. If you have it, go to page 205 (The Big Dirty Secret) which will vis a vis, tell you a lot. You’d think I’d be used to it by now but it always side swipes me.

Another thing, you’re not the only one feeling beat up about this. A lot of people are in the same boat. I think manufacturers are missing a tremendous opportunity. Consumers stand to lose a great deal; it’s a matter of explaining what those losses represent before we can hope to elicit their support. I believe this because about 20% of the visitors to this site are consumers rather than manufacturers. As far as I can tell, they are just as upset as we are. When I’ve explained what this means to them and us, they totally get it. I’ve composed a list of eight central reasons they appear to be opposed to the legislation too. They’re writing letters to their legislators and talking about it on their blogs to educate other consumers. Consumers are our friends, not just our customers.

This is how I reduced it down. If manufacturers are confused about the law and retailers are confused about it too, then why does the implication exist that the only group who does understand the legislation are special interest groups? I say this over and over till I’m blue in the face but never attribute to malice, that which can be explained by stupidity -not to imply they are stupid, it’s an expression. Based on conversations with the groups I’ve spoken with, at least one on one, they can minimally be described as dismayed at the unintended impact of this legislation. I believe it is incumbent upon us to educate and partner with them to explain the far reaching consequences before it is too late.

All in all, it was a good day. I met some people who are really great, very knowledgeable and friendly. I look forward to telling you more later. I’m tired. Hope your day was a good one.

Related in the forum:
The War Room: CPSIA & Consumer Safety. This is a very active section with nearly 60 different threads and over 1,000 postings. Open to the public.

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  1. Valerie Burner says:


    Thank you for all the effort you have put forth in this endeavor. I don’t think you have been callous or unkind to consumers in any way. If anything, you have made us aware of the fact that the consumer has the power to make the choice about buying our products, and the more professional we are in the process, the better off we all are. Perhaps you’re just tired. Get some sleep, and we will await more news from you.

  2. Babbie Rosenthal says:

    There is so little known about the CPSIA, and very little to be found online when Googling it. Oh, wait, there are “parent interest” blogs which herald it and complain nastily that shelves are not being swept clean at this moment, and Consumer Reports lauds CPSIA and crows about their lobbying. Can we expect consumers to be reasonable?

  3. sfriedberg says:

    “required testing will not be according to style number but most likely according to sku”

    That is just outrageous for something like the garment industry, where every size is a separate SKU. I can understand testing each colorway, but not every size of men’s pants from 28×30 to 48×40. To be remotely practical, there must be an approved way to convert tests on the inputs into certifications for each SKU, without explicitly testing a sample of each SKU.

    By the way, this new paper trail really reminds me of the WW II vintage mandatory documentation on Mil-Spec metal fasteners. Every little bag of repair parts was traceable back to the specific batches of steel, brass, or titanium that were rolled, cast, machined or otherwise converted into washers, nuts and bolts and then placed in inventory. Supposedly, if the wings fell off your airplane, they could figure out not only what company supplied the bad parts, but who that company’s suppliers were, all the way back to molten metal refined from ore taken out of the ground.

    For decades the paperwork was kept in some subterranean salt mine. (Really, that’s where lots of paper records are kept in long-term storage.) And you know what? Only an infinitesimal fraction of those records were ever consulted, for any reason. It was all strictly cover-your-tail record keeping. Extremely costly, and of dubious value.

  4. Kaaren Hoback says:

    No one wants even one child harmed by either lead or phthalates but thinking an adult is going to ingest a sufficient quantity of harmful compounds from their zipper pulls, or even embellishments in the form of leaded Swarovski crystals is beyond the pale.

    The consumer will side with manufacturer’s and designers when they realize the inherent cost involved that results in both higher prices and lack of availability of what they decide they want.

    Certainly, the cost of testing will carry forward to the retail price- and the bling may need to disappear from their precious tees and handbags. The $2500 SEWN product evening purses available at specialty shops will clear off the shelves? I think that would create a black market for some circles.

    Rare, crocked dye goods are probably more harmful and annoying than any thing now involved in this debate – as are leather goods tanned the “old way” using human waste.

    We need a well-written article explaining the pros and cons of the current proposed rules; and what the net effect to consumers will be. Knowledge, temperance and calm are required. Educate your base- involve your consumers- get an article in your local newspapers – write your representatives.

    Grumbling on this list is preaching to the choir- do something.


  5. Terrie says:

    Note: I am a consumer and not a designer or manufacture. I read the wonderful post that Kathleen does to educate myself and to be entertained. Her view point and opions expand my knowledge (and make me laugh) and I greatly appreciate that. What that means is I am not educated in this field…so these are just opinion.

    I am a mother of two very young children and had to throw away several hundred dollars worth of toys during the lead recall. My group of friends were similarly inconvienced. We worried, we researched, we talked to each other, and we got angry over our misplaced trust in the toy manufactures. It was all very time consuming and unnecessary.

    Having said that… it seems unacceptable to impose standards out of fear and not based on true necessity. Children under 8 are likely to put things in their mouth, but as a grown woman I tend to reserve my mouth for eating too much and talking too much. I do not chew on zipper pulls. These standards seem reactionary and without true merit or foundation. Regulations need to be in place to protect people from unknown hazards, but they should be well thought out and not unnecessarily burdensome. The part I find interesting is the lack of knowledge that these regulations exist among those they are meant to protect. I have been educating my friends about them since the first post and their existence was a surprise to everyone I know. The ramifications of this are disproportional to the threat these hazards pose to our society.

    I wish you all the best in your endeavors and would like to help, but I am not certain how.

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