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Consumer Product Safety Improvement Act requirements
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mhswope
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Location: PA State College

PostPosted: Mon Nov 10, 2008 2:37 pm    Post subject: Reply with quote

I have the same question as Pam. Where is a reliable lab to test (in my case) flammability? I have an email out to one lab I found online.

Kathleen, perhaps the topic of finding/researching labs could be moved to it's own topic separate from this compliance discussion.

Marguerite
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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Mon Nov 10, 2008 3:17 pm    Post subject: Reply with quote

@Pam.

Testing usually requires destroying the length of fabric submitted. That said, people whose product is based on re-purposing old/obsolete garments may have a more difficult time getting the logistics nailed down. I presume this would require sorting the inputs into more granular categories and then sending the worst specimens out to be destroyed during the testing process.

@Marguerite.

It's going to take some time. There are two links, above, for labs. And, if you check Apparel Search, you'll find more. Google will yield even more results. Try talking with your fabric reps, too. They might have someone close by.
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Kathleen F.
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Joined: 08 Sep 2005
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PostPosted: Mon Nov 10, 2008 3:32 pm    Post subject: Reply with quote

mhswope wrote:
Kathleen, perhaps the topic of finding/researching labs could be moved to it's own topic separate from this compliance discussion.


Done. You can find it [url=//fashion-incubator.com/phpbb/viewtopic.php?p=18025#18025]here[/url].
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Esther
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PostPosted: Tue Nov 11, 2008 11:19 am    Post subject: Reply with quote

I have sent these questions off to the CPSC. You can do it too by going to the CPSC website.

Quote:
As a manufacturer-retailer of children's clothing and as a 10 year veteran of the fashion industry I have several questions in regards to this act. My styles are made from several components which can be recombined into new styles over time. As I have studied the recent legislation, it appears that each completed style will have to be tested as a unit. This places a heavy burden on manufacturers who use the same raw materials in multiple styles because it requires duplicate testing of the same components. I have been asked by my peers if the individual raw components can be tested individually to meet the intent of this act?

Another question relevant to recent legislation is in regards to custom clothiers, independent designers, and auction sites. These individuals sell one-of-a-kind children's products from new and/or recycled materials on websites like Etsy and Ebay. I am under the assumption that the recent legislation applies to them too?

I have operated my business using lean manufacturing techniques. This have given me an advantage to adapt quickly while reducing waste. It has allowed me to customize orders. As I understand the Act, each adaptation will have to be retested since it represents a material change to the style?


I doubt I'll get a direct reply. If I do, I will pass it on.
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Valerie Burner
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PostPosted: Tue Nov 11, 2008 11:29 am    Post subject: Reply with quote

Esther,

Thank you for taking the time to do this, and for your other replies to my questions. I appreciate it very much. I posted a comment on the ASDP's email discussion list (formerly PACC), in the hopes that as an association they might be better able to get a reply than an individual. From the tone of some of the replies, I am not sure they will take it seriously enough to bother. Oh well. I tried...
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J C Sprowls



Joined: 25 Mar 2006
Posts: 2004

PostPosted: Tue Nov 11, 2008 12:05 pm    Post subject: Reply with quote

I haven't had good luck with PACC or CTDA. You'll notice I stopped feeding them dues, too.
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Valerie Burner
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PostPosted: Tue Nov 11, 2008 12:46 pm    Post subject: Reply with quote

JC,

Thanks for that. I just joined this July... Will keep you posted.
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Pamela
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PostPosted: Tue Nov 11, 2008 12:57 pm    Post subject: Reply with quote

I have just started to watch these sessions but it probably would be beneficial for everyone to watch these. It is the CPSC Public Meeting: Testing and Certification. They actually video'd the whole day and I think there is some good information to be had here for those who are best with listening than trying to read thru the whole bill.

http://www.cpsc.gov/about/cpsia/testing.html

Look on the page for the Watch The Meeting links.

Pam
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SarahM
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PostPosted: Tue Nov 11, 2008 1:57 pm    Post subject: Handbags Reply with quote

I don't know if this belongs directly in this thread...but I clicked on some of the above links to try to figure out if handbags are covered in this new regulation.

They are not on the list and they are not "wearing" apparel. I don't make them for children.

Any other handbag folks out there know if this regulation applies to our product? THANKS!
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Marnie
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PostPosted: Tue Nov 11, 2008 2:10 pm    Post subject: Reply with quote

I just received this from the CAF:

Quote:
Earlier today the U.S. Consumer Product Safety Commission (CPSC) posted a new set of procedures, which help simplify the process considerably. All companies attempting to prepare Certificates of General Conformity should refer to the following document:

http://www.cpsc.gov/businfo/cfr111008.pdf <http://www.cpsc.gov/businfo/cfr111008.pdf>


Also, there is another workshop like the one Alex and I attended being held in Vancouver tomorrow. You don't have to be a CAF member to attend.

Quote:
Vancouver Workshop: To attend the Vancouver workshop, please download the Vancouver registration form
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Jody
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PostPosted: Tue Nov 11, 2008 2:35 pm    Post subject: hurry up and wait.... Reply with quote

Hello all,
I have been pretty concerned about this legislation since logging in and finding the post on the CPSIA as I simply do not have sufficient capital to absorb the costs of independent testing. Like many of your subscribers, I am such a small manufacturer that this legislation promises to put me out of business, even before my first launch.

I have spent the better part of two days now, looking at the legislation, the summaries, etc. and have come to the conclusion that it is simply too soon to tell whether I have to throw in the towel. Anyway, I have some perspectives that those of us watching this discussion may find useful and maybe even a bit comforting?

While Section 102 clearly indicates that all children's products will require certification (and thus testing), I can't get past the fact that the title of Section 102 says "certain children's products". This may seem like a technicality to some, I'm sure. However, in my day job, I work at the state level to implement the federal Clean Water Act. I know from experience that on the federal level, until the rules on how to implement a given piece of legislation are written, itís tough to predict how it will impact a given industry.

For folks who donít know how this stuff works, consider that whenever a law such as the CPSIA is passed by Congress, thereís never enough information in the language of the law itself to implement it. So, the federal agency responsible for implementing that particular type of law, the CPSC in this case, must develop the rules and regulations. These are the specifics of how the law works and generally contain much more detailed information than the law itself. The rules and regs then become part of the Code of Federal Regulations, which is essentially the rule book for federal agencies use when enforcing the law.

So, the first point Iíd like to make is that federal laws are typically articulated in very broad terms and that the rulemaking process distills this down to make it manageable for the regulated industry, which where most of us are concerned, is the apparel industry. In doing so, the CPSC will likely take many factors into consideration, such as potential impacts to industry, in drafting the new rules.

My second point is that it is possible that children's clothing will be exempted as a result of the federal rulemaking process. Even though Section 102 says "all" children's products, there is usually wiggle room built into the legislative language that allows for exemptions. We've all heard of the term loopholes. Thereís usually a reason for them and sometimes, itís because the law would cause undue hardship on a given industry without a corresponding benefit.

For example, counter to what we might expect, the Engineering Test Manual: Requirements for Toys and Other Articles intended for use by Children Under 8 Years of Age, located here specifically exempts childrenís apparel (and even more specifically buttons) from the small parts testing requirement (the one that tests for choking hazards). I donít know what the reasoning was behind this exemption, but Iím guessing it may have something to do with the fact that lots of kidsí clothes have buttons such that to require testing of every button may have been considered unreasonable for the costs this would impose on the industry. Again, this is just a guess. I know this example doesn't apply to lead in fabric and that this may indeed change with the new rules for small parts. I'm just trying to illustrate the point that there are often exemptions once a law is translated into rule.

My hope is that similar exemptions will be made for the children's apparel manufacturing industry, specifically as it relates to Sections 101 and 102 when the CPSC goes into rulemaking. This will occur in phases

I've probably overstayed my welcome on this discussion, but I felt like I probably wasn't the only one on this forum that needed to take a step back (off the ledge, in my case). I just want to let everyone know that the sky isn't necessarily falling. Itís simply too soon to know how this will impact our businesses.

So, I will make my third and final point and be done with this for awhile. As an increasingly important sector of the apparel industry, DEs should keep in mind that federal rulemakings usually involve one/more public comment periods. As with all federal agencies, the CPSC is required to review and consider every comment received in its rulemaking every comment received. This presents us with an opportunity to make our voices heard, preferably in unison (there is power in numbers). To this end, Iíve excerpted from the CPSC timeline a few of the actions that I think might be particularly relevant to our members. The dates shown below indicate when we might want to be on the lookout for a public comment period, at which time, we may as a group want to consider submitting a formal comment. CPSC notices of public comment periods are published here. Pay particular attention to the following actions:

#12: August 2009 -- The Commission shall promulgate a rule providing guidance with respect to what component, or classes of components of childrenís products will be considered to inaccessible.
This is important because the rule as I read it applies only to the ďaccessibleĒ components of a product. Therefore, the definition of what is and isnít accessible is going to be a key factor in determining the impact of this legislation to DEs. The CPSC summary document for Section 101 indicates that ďSome childrenís products may be exempted or excused from these new lead limits if a component part containing lead is inaccessible.Ē So, if the CSPC decides that the fabric in a garment is not accessible, then the lead rule wouldnít apply to the textiles we use. Of course, we would still need to think about the buttons, snaps, and other potentially lead-bearing items we useÖ

#16: November 2009 The Commission shall by regulation initiate a program by which a manufacturer or private labeler may label a consumer product as complying with the certification requirements.
These regulations should tell us specifically what information we will have to include on our labels and other requirements such as whether they have to be permanently attached, etc.

#19: November 2009 -- The Commission shall by regulation establish protocols and standards for verifying that a product tested by a conformity assessment body complies with childrenís product safety rule.I believe that this is going to be a very important rulemaking to watch. I expect that, as in the small parts example, these protocols will identify any exemptions to the required testing.
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Alex R
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PostPosted: Tue Nov 11, 2008 2:40 pm    Post subject: Reply with quote

Quote:
Earlier today the U.S. Consumer Product Safety Commission (CPSC) posted a new set of procedures, which help simplify the process considerably. All companies attempting to prepare Certificates of General Conformity should refer to the following document:

http://www.cpsc.gov/businfo/cfr111008.pdf <http>


A definite must read! This answers a lot of questions I had... Interesting to note, the 2009 budget has been frozen at 2008 levels. That 700 billion bailout didn't leave much left in the bucket ;) That said, they quite clearly state their intention to enforce.


SarahM wrote:
but I clicked on some of the above links to try to figure out if handbags are covered in this new regulation.

They are not on the list and they are not "wearing" apparel. I don't make them for children.

Any other handbag folks out there know if this regulation applies to our product?


As they say in the above link, this applies to any "product that is subject to an applicable consumer product safety rule under the CPSA, or similar rule , ban, standard, or regulation under any other Act enforced by the Commision". This covers A LOT of ground!

What are your bags made from? Give us a list of materials!

Off the top of my head, you'd have to look out for flammability if the bags contain fabric, and possibly lead depending on the type of hardware. Even if your products aren't for children.
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Kathleen F.
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Joined: 08 Sep 2005
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Location: NM Albuquerque

PostPosted: Tue Nov 11, 2008 2:54 pm    Post subject: Reply with quote

OT Rant:
Valerie Burner wrote:
I posted a comment on the ASDP's email discussion list (formerly PACC), in the hopes that as an association they might be better able to get a reply than an individual. From the tone of some of the replies, I am not sure they will take it seriously enough to bother.

J C Sprowls wrote:
I haven't had good luck with PACC or CTDA. You'll notice I stopped feeding them dues, too.

Oh good luck with that Valerie. I got sucked into it too but I resigned before my year was out -no refund of course. I got sick and tired of all the amateur level antics, constantly bashing RTW with contradictory arguments; that we are deliberate crap producing sweatshop owners conspiring to destroy them and how much better they are in every way while at the same time, we are conspiring to keep industrial methods a secret from them (if we make crap, why would they want to know the secrets of it?). I appealed to management over some particularly offensive postings and they did not see fit to do anything about it so I left. I don't know how they expect to encourage professionals to join if the environment is hostile and inhospitable to them. I doubt that but a few -and those that do, rarely if ever post- are making a living at it.

Reminder: our forum is confidential. Sharing from here is not permitted. You can post info from the blog because it's public but not from here. Besides, let them do their own homework. If they were the consummate professionals they purport themselves to be, they would care so I'm not surprised in the slightest that you say they do not. Just goes to show you...
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Valerie Burner
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PostPosted: Tue Nov 11, 2008 3:15 pm    Post subject: Reply with quote

Kathleen,

After I read it this morning, I sat there and wondered why I read it at all. It just left me feeling wiped out. I actually questioned my own desire to continue on with any of this- and then I thought- well, maybe I'd better not say exactly what I thought!!! I am not going to let anything stop me from doing what I want to do anymore.

Do not worry- I only recommended that they read the article, and I pasted the link to the article itself. I thought that they could read that and get the same idea that we all have, but some didn't. You can lead a horse to water.....
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Miracle
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PostPosted: Tue Nov 11, 2008 4:10 pm    Post subject: Reply with quote

You guys should check out the current news, they've found formaldehyde in Victoria's Secret bras.
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