FAQFAQ   SearchSearch   MemberlistMemberlist   UsergroupsUsergroups   RegisterRegister   ProfileProfile   Log in to check your private messagesLog in to check your private messages   Log inLog in 

ACTIVISM: Consumer Product Safety Improvement Act
Goto page Previous  1, 2, 3, 4, 5, 6, 7, 8  Next
 
Post new topic   Reply to topic    Fashion-Incubator User Forum Forum Index -> CPSIA & Consumer Safety
View previous topic :: View next topic  
Author Message
Alison Cummins
Official Archivist
Official Archivist


Joined: 17 Dec 2005
Posts: 2300
Location: Canada QC Montreal

PostPosted: Tue Nov 18, 2008 12:15 pm    Post subject: RE: keeping things to one page Reply with quote

As a wordy, detailed person myself I completely understand the tension between being accurate and being concise.

One way I get around it is to write a two- or three-paragraph executive summary of the main points, and to attach appendices with calculations, explanations and assumptions.

The “main points” of an executive summary are usually something like “1) Situation X will cost us (see appendix for cost calculations). 2) You should do Y to avoid those costs (see appendix for details). 3) Y is a particularly cheap and effective solution, and is the right thing to do (see appendix for alternate, rejected solutions).”

Do not be shy about item 2). It needs to be clear, not buried.
Back to top
View user's profile Send private message Send e-mail Visit poster's website
Jody
Guest





PostPosted: Tue Nov 18, 2008 1:24 pm    Post subject: Reply with quote

Yeah, I felt like the letter was too long, too. I suspect I lingered a bit too long on my outrage at how they have rammed this thing through. I work in government and feel very strongly about the importance of public input in shaping the laws that directly affect them.

If this were an official public comment period, they would have to review the entire thing and develop a responsiveness survey, regardless of how busy they are. But, since it isn't, I agree that we should shorten it up a bit...who knows, they might even read it if we do (a little sarcasm there...makes me feel better).

I'll wait to get everyone's comments until Friday and work on tightening it up. Thanks again.
Back to top
Jennifer Taggart
Guest





PostPosted: Wed Nov 19, 2008 12:02 am    Post subject: Comments on letter and other issues Reply with quote

Hi! This is Jennifer. First, a disclaimer, none of the following is intended to be legal advice to any particular member of this forum. And second, I have to say I've been getting some information from Kathleen about the questions, but not all of it, so I think some of my posted comments may not have been fully responsive or complete.

Okay, on to the issues, there are several components to the CPSIA.

One component is setting a general standard for lead in children's products. This standard applies to products designed or intended primarily for children 12 and younger. As of February 10, 2009, such children's products cannot contain more than 600 ppm lead. This standard then ratchets down to 300 ppm effective August 14, 2009. This standard may then go down to 100 ppm effective August 14, 2011 unless the CPSC determines that it is not technologically feasible to have this lower limit.

So, as of 2/10/09, any clothing that is a children product - intended primarily for children aged 12 years or younger - cannot have more than 600 ppm lead.

Another issue is lead paint limit. This limit applies only to painted or similar surface coatings - which would probably mostly be zippers, zipper pulls and perhaps buttons. This standard goes from 600 ppm (now) to 90 ppm. This applies for all painted materials for consumer use - not just kids stuff. I don't know enough about your industry to know if this coating standard applies to painted on decorations on clothing. But, at the very least, any components of finished garments are going to have to meet this standard.

Another standard is for phthalates. The law bans the manufacture, import, distribution or sale of children's toys or child care articles containing more than 0.1% of specified phthalates. This ban applies to children's toys - a consumer product designed or intended by the manufacturer for a child 12 years old or younger when the child plays. A child care article is a consumer product designed to facilitate sleep or the feeding of children age 3 and younger or to help such children with sucking or teething. I don't know if any members make consumer products that would be covered by the phthalates ban. There is currently a request for comments on this provision. Comments on the phthalate ban are due 1/12/09.

Beginning 11/13/08, all consumer products subject to any ban, standard, etc. enforced by the CPSC must be accompanied by a general conformity certificate. This requirement means the manufacturer (domestically produced) or importer (foreign manufacture) must provide a general certificate saying that the product complies with the applicable standards. This has been discussed before. There is a final rule on this. The CPSC admits that this was quickly implemented, and certainly will continue to revise these requirements. This does not have to be based on third party testing, although it can be.

Also, in addition to the general conformity statement, certain consumer products must be covered by third party testing certificates. And that seems to be the biggest issue.

The first third party testing was for lead paint. That is effective 12/22/08. This applies to painted or similar surfaced coated materials only. There is a final rule for this already published.

Then, as laid out in the law in section 102, you will have dates coming on line for third party testing requirements for various children's products: full size cribs; small parts; children's metal jewelry; baby bouncers, walkers & jumpers; and finally, all other children's product safety rules. This will have the requirements published 10 months after enactment - or by 6/14/09.

So, in terms of third party testing for the 600 ppm standard for lead in children's products, and any other applicable requirements, that rulemaking, such as it is, will be next summer.
Back to top
Miracle
Site Admin
Site Admin


Joined: 13 Jan 2006
Posts: 946
Location: CA

PostPosted: Wed Nov 19, 2008 12:08 am    Post subject: Reply with quote

Jennifer:

For the sake of argument, let's say you have a garment made entirely of fabric and thread and thus are only dealing with the regulation(s) that apply to textiles...

Must you test each individual garment, or is testing of the textile sufficient?

Does this differ for children's apparel vs apparel not intended for children?
Back to top
View user's profile Send private message
Kathleen F.
Site Admin
Site Admin


Joined: 08 Sep 2005
Posts: 11214
Location: NM Albuquerque

PostPosted: Wed Nov 19, 2008 6:59 am    Post subject: Reply with quote

Hi Jennifer, thanks for weighing in, that helps a great deal.

In today's Washington Post, an article that discusses the law with respect to children's toys. Btw, we are under the same constraints they are, no different.
Back to top
View user's profile Send private message Send e-mail
Pamela
Guest





PostPosted: Wed Nov 19, 2008 10:23 am    Post subject: Reply with quote

In writing the letters that we need to write how do we say in a nutshell that the entire children's industry will go down the tubes with this law. There will be little to no toys, little to no strollers, car seats, books, videos, stuffed animals, clothing, jewelry, craft goods, and everything that makes up children. One person had it right when he said Feb 10 will be National Bankruptcy Day because the entire face of retail will change.

What were they thinking.

The ones left making any money will be the ones enforcing the law so the rest of us can't make a living.

Pam
Back to top
Miracle
Site Admin
Site Admin


Joined: 13 Jan 2006
Posts: 946
Location: CA

PostPosted: Wed Nov 19, 2008 10:47 am    Post subject: Reply with quote

Quote:
how do we say in a nutshell that the entire children's industry will go down the tubes with this law


I don't think that's exactly true and I don't think it helps to say things like that if they aren't exactly true. It makes it easy to discredit your position.
Back to top
View user's profile Send private message
Jennifer Taggart
Guest





PostPosted: Wed Nov 19, 2008 11:57 am    Post subject: Fabric v. Completed garment Reply with quote

Miracle - All components of the finished garment must meet the applicable requirements. Setting aside any flammability requirements, you could test the fabric & the thread & any other components separately if no further fabric processing was undertaken after the garment was assembled provided that the samples were representative. I think that answers your question.
Back to top
Jennifer Taggart
Guest





PostPosted: Wed Nov 19, 2008 12:03 pm    Post subject: Sending letter re exempting certain items Reply with quote

To all - I'm catching up on watching the video from the lead meeting, and have discovered that the CPSC solicited written comments on exempting certain types of items for the testing rules - such as a 100% cotton t-shirt. So, I think we need to send a targeted letter in NOW on that subject.

Jennifer
Back to top
SarahM
Guest





PostPosted: Wed Nov 19, 2008 12:11 pm    Post subject: ACTIVISM Reply with quote

We need to find out what effort others are making? Is anyone working with a lobbyist/grassroots coalition campaign? We're stronger together.

In addition to Etsy, what about all the pro-sellers on Amazon.com?Overstock? QVC? Perhaps getting them on board.

What do we really want? We need talking points (clear and concise.)

Of course, non of us want to sell unsafe products, but this process needs to be clear and reasonable for small domestic manufacturers.


Last edited by SarahM on Wed Dec 31, 2008 11:35 am; edited 1 time in total
Back to top
Esther
Moderator
Moderator


Joined: 17 Mar 2006
Posts: 1898
Location: ID Spudville

PostPosted: Wed Nov 19, 2008 12:36 pm    Post subject: Reply with quote

Found this article from the Wall St. Journal about who Obama intends to appoint to various agencies. In particular the candidate for the CPSC intends on tougher regulations and stiffer penalties. At $15,000,000 and 5 years in jail, I am left wondering how much tougher it can get.

Obama signals tougher regulations at Federal Agencies.

BTW, I sent an email off to John Lott - a conservative economist, author, and Foxnews contributor.
Back to top
View user's profile Send private message Send e-mail Visit poster's website
mhswope
Renewing Member
Renewing Member


Joined: 22 Feb 2007
Posts: 3616
Location: PA State College

PostPosted: Wed Nov 19, 2008 12:43 pm    Post subject: Reply with quote

Esther,

That's not a bad thing in itself. It's up to use to let him know about the impact of this particular act, and we're working on doing that. He doesn't work in a vacuum, so if we're targeting the right agencies/people, he'll get the message.

Marguerite
Back to top
View user's profile Send private message Visit poster's website
SarahM
Guest





PostPosted: Wed Nov 19, 2008 12:45 pm    Post subject: Reply with quote

scary.

Last edited by SarahM on Wed Dec 10, 2008 10:29 am; edited 1 time in total
Back to top
Pamela
Guest





PostPosted: Wed Nov 19, 2008 1:03 pm    Post subject: Reply with quote

Intertek (an approved testing lab company) is putting on several Power Lunches during the month of December specifically about the CPSIA.

http://www.intertek-labtest.com/resources/events/intertek_power_lunch/?lang=en

Pam
Back to top
Kathleen F.
Site Admin
Site Admin


Joined: 08 Sep 2005
Posts: 11214
Location: NM Albuquerque

PostPosted: Wed Nov 19, 2008 7:24 pm    Post subject: Re: ACTIVISM Reply with quote

SarahM wrote:
We need to find out what effort others are making? Is anyone working with a lobbyist/grassroots coalition campaign?

I hate to break this to you Sarah, but WE are the grassroots coalition! It's us. Please see [url=//fashion-incubator.com/phpbb/viewtopic.php?p=18352#18352]this entry[/url], yes, we need a list of people to target with the information. Each of us, in other forums we belong to, other blogs we read or those we write of our own, need to be talking this up. I post about this issue every. single. day in every forum I can think of. I can't do all of them. Where do you hang? Please find a way to work it into the conversation.

Believe me, I'm spending too much of my day on this. I've written letters to anyone who will listen, I post comments on WWD everyday (I'm pissed they still haven't covered it). Yesterday I connected with the publisher at Earnshaws. They're covering the story in January's issue. What we really need now, most of all, is a letter that we can all link to and pass around for people to print out and mail. We need a petition we can circulate. I'm holding off until Jody (no pressure hun) can finalize a draft that Jennifer says holds water.

The heavies working on this are listed in [url=//fashion-incubator.com/phpbb/viewtopic.php?p=18352#18352]the post I already linked to[/url]. Look, I don't know what else I can do. I've joined the AAFA; that set me back nearly $3,000! They are the biggest apparel industry lobbying group. I've signed up to attend the strategy meeting to be held in D.C. on Dec 3rd. Between hotel and airfare, that cost me another $1,000 AND I'm not even manufacturing!!! I want to show up at that meeting with a huge box of letters from all of you, anything we can get off of F-I traffic. It is up to all of you to pass the word, anywhere you hang out on the web. Frankly, I don't know what else I can do; I'm out $4,000 and have had only one $25 donation to help me offset the costs and from someone who has the least ability to contribute.

edited to add:
Esther wrote:
Found this article from the Wall St. Journal about who Obama intends to appoint to various agencies. In particular the candidate for the CPSC intends on tougher regulations and stiffer penalties. At $15,000,000 and 5 years in jail, I am left wondering how much tougher it can get.

Btw, you wouldn't believe how many comments I've had to delete on the blog from people who are already blaming Obama for this! WTF? When I tell them this legislation was passed during the current republican administration, they just become more unhinged. Frankly, I don't see how Obama could make this worse. Besides, we need to focus on what has been done, not what might be.
Back to top
View user's profile Send private message Send e-mail
Display posts from previous:   
Post new topic   Reply to topic    Fashion-Incubator User Forum Forum Index -> CPSIA & Consumer Safety All times are GMT - 6 Hours
Goto page Previous  1, 2, 3, 4, 5, 6, 7, 8  Next
Page 3 of 8

 
Jump to:  
You cannot post new topics in this forum
You cannot reply to topics in this forum
You cannot edit your posts in this forum
You cannot delete your posts in this forum
You cannot vote in polls in this forum


Powered by phpBB © 2001, 2005 phpBB Group