Those of you producing children’s wear should be aware that the stay of enforcement (CPSIA §102(a)) will be expiring on February 10th. A broad coalition of children’s products producers have signed on to a letter submitted by NAM (National Assoc of Manufacturers) to the CPSC, requesting an extension for very valid reasons (pdf). Minimally, the agency has failed to finalize testing requirements (the so called “15 month rule”). I know, I know, you think I’m crazy because it can’t be possible that the CPSC expects manufacturers to comply with requirements they have yet to define -but they can. Yes indeedy!
Please act now by sending a message to the CPSC, requesting an extension of the stay of enforcement until the agency can finalize the “15 month rule”. The AAFA has set up an automated mailer here. Please act now. Consider adding your support even if you don’t produce children’s products or are a consumer. If the stay is not extended, we will lose incalculable numbers of small artisan producers of children’s clothing and toys so there won’t be much cool stuff to buy anymore. Thank you!
Amended: I think people are clicking on the wrong link to respond. USE THIS ONE.
If you don’t know what CPSIA is, catch up here.
Content of AAFA’s message is as follows:
Your action is needed urgently to help persuade the Consumer Product Safety Commission (CPSC) to extend a stay of enforcement on third party testing and certification for lead standards.
This stay has provided important relief to children’s product manufacturers and retailers throughout the country while the CPSC has sorted out complicated testing and certification procedures.
Unfortunately, that stay will be automatically lifted on February 10, 2011.
And the CPSC has not yet finished those procedures and has no chance to complete work on those procedures before the stay automatically lifts.
Lifting the stay prematurely will force companies to meet testing procedures and rules that have not yet been written. This will cause significant costs and burdens to many companies, including many small and micro businesses, who cannot afford these added expenses.
Lifting the stay will result in job losses as companies are forced to trim payrolls to pay extra lab costs. Others may go out of business altogether.
Lifting the stay before the testing rules are ready is simply not fair.
Lifting the stay will provide no gain in consumer product safety since children’s products already have to meet the underlying lead standards.
Please send an email today to the CPSC and urge them to extend the stay of enforcement – before it is automatically lifted on February 10, 2011 – so the CPSC has enough time to finish and publicize common sense testing procedures and so manufacturers and retailers have enough time to learn them.