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Consumer Product Safety Improvement Act requirements
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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Fri Nov 14, 2008 9:48 am    Post subject: Reply with quote

It's still a cluster.

BV uses the term "children's" and "child" a lot. Those questions are leading. IOW: where BV and its clients feel that CPSC is vague, they are offering a definition (any definition) that limits the scope and reach of the act. IOW: they're putting it in a box.

Right now, it appears most manufacturers are under the impression that this only applies to children's products. However, the CPSIA is not clear.
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Valerie Burner
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PostPosted: Fri Nov 14, 2008 11:15 am    Post subject: Reply with quote

Vesta,

Yes, that would be ideal to get lead to 0 ppm. Especially for organics. But even with the chocolate, they are saying that it is caused by everything from the lead found in the soil, to emissions from leaded gasolines, to herbicides and pesticides (GMO products anyone???), to the processing equipment, to the packaging, to the shipping containers, to the manufacturing plants, to the packaging materials on the actual candy itself. Oh- and don't forget the alkalyzing- that does cause some lead contamination.

Not only that, but there have been recent studies showing huge amounts of toxic chemicals from dioxin to heavy metals in mother's milk.

Where in this world do we go to find products with acceptabel levels of anything anymore?

IMO, this IS a knee-jerk reaction to all the recalls from past years- almost exclusively of children's toys, and from what I saw on the recall list from the past couple of years, "Manufactured in China" was the largest common denominator.

I don't see how they can hold the last people in the manufacturing chain responsible for the accumulation of something that we had no intention of having in that product in the first place.
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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Fri Nov 14, 2008 2:59 pm    Post subject: Reply with quote

Please note that the FAQ document is a work in progress and is being changed w/out version control. As of a few minutes, ago, the CPSC has posted a new version of the FAQ document.

http://www.cpsc.gov/about/cpsia/faq/faq.pdf

The wind is blowing in the direction of Children's products and wearing apparel. Though, as Jody mentioned, the law has been passed; but, the policy is being written.

IOW: there's still time to interject.

[soapbox ON]

I would hope that all apparel producers consider that they should support their brethren in the children's sector because the winds can easily shift and favors are golden.
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Valerie Burner
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PostPosted: Fri Nov 14, 2008 3:23 pm    Post subject: Reply with quote

I agree with you JC. I don't do children's clothes, but even if this does not concern adult clothing items, I am still on board to do all I can to help.
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Anne
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PostPosted: Fri Nov 14, 2008 3:52 pm    Post subject: Reply with quote

This would be much more reasonable if it allowed testing of component parts instead of the finished product. That way, component parts used across multiple styles wouldn't need duplicate testing.

Edited to add: Q. On what does my certification have to be based?
A. The general conformity certification must be based on a test of each product or a reasonable testing program.

Does this mean that what I described above would meet the requirement of a "reasonable testing program"?
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Miracle
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Joined: 13 Jan 2006
Posts: 946
Location: CA

PostPosted: Fri Nov 14, 2008 4:17 pm    Post subject: Reply with quote

Quote:
I would hope that all apparel producers consider that they should support their brethren in the children's sector because the winds can easily shift and favors are golden.


I agree with that!
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Esther
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Joined: 17 Mar 2006
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PostPosted: Fri Nov 14, 2008 4:22 pm    Post subject: Reply with quote

I studied who voted on the legislation. It had nearly universal approval from both sides of the aisle except for one. Yup, Ron Paul. I already sent off letters to my representatives expressing my frustration.
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Lisa Bloodgood
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PostPosted: Fri Nov 14, 2008 4:39 pm    Post subject: Reply with quote

I'll help, too, even though I'm not a children's wear producer/manuf.

Does anyone know how to find the addresses for Congresspeople and Senators or should I do a search?
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Kathleen F.
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Joined: 08 Sep 2005
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Location: NM Albuquerque

PostPosted: Fri Nov 14, 2008 4:48 pm    Post subject: Reply with quote

The new thread on activism [url=//fashion-incubator.com/phpbb/viewtopic.php?p=18264#18264]is here[/url].

Below is cross posted material for continuity.

Jody wrote:
Kathleen can post the final letter somewhere where we can all print a clean, uncluttered copy. Then we can each sign and mail the letter individually. This idea may ultimately be more effective...I work in government and I can tell you that getting 300+ hardcopy letters in response to a public comment period is a pretty intimidating thing.

I prefer this idea most. Hopefully the environmental engineer/scientist cum attorney I found will weigh in soon and can provide verbiage.

We should start another thread for activism [url=//fashion-incubator.com/phpbb/viewtopic.php?p=18264#18264](done)[/url] specifically. We need to be organized. I can only do so much. We will need each of you to reach into those communities in which you have influence, to start talking it up, those who haven't already. These means bulletin boards, blogs, forums, email lists, all grassroots. It would be great if we could define a list of communities to target so we get them all. Ideally, each of us will agree to be responsible for promoting the issue in each of those communities. I will start the other thread later and move stuff from here over there. Some will need to be cross posted.

Other news:
I'm [url=//fashion-incubator.com/phpbb/viewtopic.php?p=18335#18335]worried about Bethany[/url]. It's probably too soon to talk her down but..

I'm waiting to hear back from the AAFA. They're having a meeting on the 3rd of December for the newly formed Product Safety Council which was created on Wednesday specifically to respond to the CPSIA problem. I want to go to it but it's members only. Apparently, my only option is to [url=//fashion-incubator.com/archive/how-to-find-help-in-the-apparel-industry-for-nearly-nothing/]follow my own advice[/url]. Sooo.... I've signed up to join the AAFA. It hurt, A LOT. $2,500 worth of hurt -and people bitch about a lousy $60? I hope the investment will pay off for us.
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michael.martinez
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PostPosted: Fri Nov 14, 2008 4:51 pm    Post subject: Reply with quote

Lisa B wrote:
Does anyone know how to find the addresses for Congresspeople and Senators or should I do a search?
[url=//fashion-incubator.com/phpbb/viewtopic.php?p=18350#18350]Here are some telephone numbers[/url] of legislators to get started;
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michael.martinez
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PostPosted: Fri Nov 14, 2008 6:35 pm    Post subject: Reply with quote

I just went to Target with the wife and baby, Diapers and a new teething ring (We haven't slept in 8 months the teeth just keep coming, maybe that explains my acerbic nature). I asked to see the store manager. I asked the manager about this ACT and She gave the "thousand mile stare." She went and checked her email and the corporate board stuff. Nothing.

When she does know something, she said she'll call...

My take away; the CSPC are still a ways off from actual implementation. I see this all the time with NFPA and OSHA changes. In fact, we don't always fully adopt these things. Sometimes we just adopt what is feasible, accept the liability and press on.
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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Fri Nov 14, 2008 7:31 pm    Post subject: Reply with quote

@Michael.

I suspect that large Retail establishments have not yet trickled down the policy because there's nothing to articulate, yet. So, the doe eyed expression doesn't surprise me. I also suspect that it won't be each store manager's responsibility to manage. I suspect that it will need to be controlled at the Corporate Buyers' office with some type of intake control at the store level.

Also, please realise that the CPSC Act contains an "out". The CPSC has reserved the right to decide what to implement and what to enforce at will. It's wrapped in some "feel-good" language about leaving the interpretation open to evolve over time. But, it's just too risky a business proposition to accept as-is.

This should be our focus. We shouldn't be able to drive a truck through legal text - ever.

@Anne.

I agree. It would be reasonable to only test component parts, esp where the output tests from suppliers was insufficient (e.g. a woven mill might test for distortion and shrinkage; but, not colorfastness). They don't test everything, by the way, just the minimum expectations of what they suspect their customers will hold them accountable for.

However, the text of the Act the problem. It's generally good business (and, good production) to do materials testing, anyway. In fact, it's in the book - maybe not in such formal terms; but, it's there. The message is to ensure quality at every entry and exit point.


Last edited by J C Sprowls on Fri Nov 14, 2008 8:47 pm; edited 1 time in total
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Anne
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PostPosted: Fri Nov 14, 2008 8:36 pm    Post subject: Reply with quote

The text says that the manufacturer shall:
‘‘(A) submit sufficient samples of the children’s product,
or samples that are identical in all material respects to
the product, to a third party conformity assessment body, etc.

If you use all the same components across two styles, they are "identical in all *material* respects", right? So if you completely tested a finished sample of one of them by an accredited lab, then you could certify both? For example, you have a romper certified, then the onesie version is just without legs and with fewer snaps (same fabric, same binding, same snaps, same thread, same everything). I'd like to consult a lawyer on this. And I still have hope from the language "based on a test of each product or
upon a reasonable testing program". I am not opposed to testing, just think it's unreasonable to have to test every single style variation, especially if they all use the same materials.[/i]
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Kathleen F.
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Joined: 08 Sep 2005
Posts: 11540
Location: NM Albuquerque

PostPosted: Mon Nov 17, 2008 12:42 pm    Post subject: Reply with quote

Kvetching first: I spoke too soon. My AAFA membership is $2,650. Ouch. They're even cutting me a break. Technically, I'm a service provider so I'm supposed to pay more ($4,100) for my level of sales (under five million). They cut me a break when I said my annual sales were less than what their average member earned in annual compensation and that none of their members would hire me for anything (and I explained my motivation for joining).

I spoke with one of the two people at AAFA who are in charge of this project full time. She was very worried. She says the biggest hit will come February 10th when all product on the shelves is required to be compliant, no more arguing over provenance or time lines by then. She said members biggest problem at that time will be loans (factoring and PO financing) because according to every loan agreement there is, lenders only loan money on inventory that is saleable and legal. If it's not compliant, it's not legal. Iow, it won't be just manufacturers hit hard come february but retailers too.
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Suna
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PostPosted: Mon Nov 17, 2008 10:09 pm    Post subject: Reply with quote

I downloaded the following info from Intertek web site.

----------------------------------------
Certificate of Compliance
(for textiles / apparel manufactured on or after November 12, 2008)

Adult Clothing Textiles:
• 16 CFR 1610 – Standard for the Flammability of Clothing Textiles (testing on all colors on non-exempt fabrics)

• 16 CFR 1611 – Flammability of Vinyl Plastic Film (if plastic material) – like vinyl aprons Third-party testing is not mandatory



Children Clothing Textiles:
• 16 CFR 1610 – Flammability of Clothing Textiles - all colors on non-exempt fabrics – mandatory third party testing starts from September 2009 (Children aged 12 years and under)

• 16 CFR 1611 – Flammability of Vinyl Plastic Film (if plastic material) – like vinyl bibs - mandatory third party testing starts from September 2009 (Children aged 12 years and under)

• 16 CFR 1303 – Lead in Surface Coatings - maximum 600 ppm (to be maximum 90 ppm from August, 2009 – any product on the shelf from August 14, 2009) - Lead paint third party testing begins from December 2008 (Children aged 12 years and under)

• 16 CFR 1615/1616 – Flammability of children’s sleepwear – third party testing begins from September 2009 (Children’s sleepwear up to size 14 – excludes infant garments sized 9 months or smaller and tight-fitting sleepwear)

• 16 CFR 1500.48 and .49 – Sharp Points and Sharp Edges – third party testing begins from September 2009 (Children aged 8 years and under)

• 16 CFR 1501 – Small Parts - third party testing required from February 2009 (Children under 3 years)

• **Total lead (in substrates) – 600 ppm from February 10, 2009 – reduces to 300 ppm effective August 14, 2009 – CPSIA Title I Section 101 - EPA 3050B/EPA3051/EPA 3052 test method for testing – (Children aged 12 and under)

• **Phthalates – CPSIA Title I Section 108 – child-care article: includes apparel used to facilitate sleep. Test method for testing: ASTM D3421 (Children aged 3 and under)

DEHP, DBP or BBP – concentrations of more than 0.1% banned from February 10, 2009
DINP, DIDP or DnOP – concentrations of more than 0.1% - banned for an interim period starting February 10, 2009 pending an investigation by the chronic hazard advisory panel until a final rule is promulgated

** Certificate of Compliance for lead in substrate and phthalates needed from the date mentioned (February 10, 2009).

Drawstrings – voluntary standard does not require certification unless made officially mandatory by CPSC.

FIBER AND CARE LABELS ARE EXEMPT FROM CoC FOR BOTH CHILDREN AND ADULT APPAREL AS THESE ARE ENFORCED BY FTC – ANOTHER REGULATORY BODY.
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