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Esther
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Joined: 17 Mar 2006
Posts: 1919
Location: ID Spudville
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 Posted: Tue Nov 11, 2008 5:05 pm Post subject: |
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| I don't know, maybe I let my evil side out. I posted a warning in the Etsy forums this afternoon. In all honesty those sellers need to know too. My post is going crazy with comments. I hope the CPSC gets overwhelmed with questions. |
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jennifer
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| Posted: Tue Nov 11, 2008 5:36 pm Post subject: Re: hurry up and wait.... |
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| Jody wrote: |
| 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? |
Thank you so much for analyzing this. I felt better after I read your post.
I think that product testing is a good practice but this is over the top. When I look at the items we make I think well I can understand certain things but not others. We make a lot of blankets and bibs and it seems like once we test the fabric for lead - hopefully that would be good enough if we are working with the same lots. But if we modify the style it has to be done all over? It just seems so arbitrary because even if one product is tested - it doesn't mean that the rest will be perfect. As much as we try people and machines will always make mistakes.
I agree that getting on sites like Etsy and group efforts would help. Also - getting the retailers on board would help. This is going to change their businesses as if it weren't bad enough already. |
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Eric H
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Joined: 02 Feb 2007
Posts: 205
Location: NM Albuquerque
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| Posted: Tue Nov 11, 2008 6:50 pm Post subject: |
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I finally bucked up my courage to read through all of this, and quickly came to the same conclusions that I did when attending [url=//fashion-incubator.com/archive/seminar_review_top_five_problems_you_should_avoid_when_importing/]a similar seminar at MAGIC on importing laws and requirements[/url]. Basically, (1) these should all be named the Lawyer Employment Act of 200X, and (2) I don't know why anyone would ever engage in the regulated activity (importing or manufacturing).
A few notes:
* I wouldn't put too much stock into ISO certification. Yes, it at least indicates that they have some semblance of quality control, but the ISO 9001 certification became somewhat of a joke several years ago. For one thing, many ISO trainers are also certifiers, so there is a certain amount of conflict of interest. In fact, I took a class with one of those Mega-Lean/6 Sigma Blackbelt/ISO 9001 gurus from a local community college, and he pretty much said that the certifiers (of which he is one) now have a vested interest in passing people because - are you ready? - they offer money-back guarantees that you will pass. Look beyond the certification, ask questions, make them prove that they aren't just practicing paper tiger McQuality.
* When we were setting up our hazardous waste satellite accumulation point, our safety officer explained to me that there were two ways to establish the contents of a waste stream: by input analysis or by assay (sampling and testing). You rely on the former when you are using known inputs and known processes, the latter when using multiple inputs and a variety of processes. Seems to me that you could take the same approach here. If you are making something relatively simple, you get your fabrics, facings, thread, and hardware tested and you're done. If you're doing something complex (specialty dyes, processes, re-purposing, etc.), you may have to resort to testing.
I'm with Alex in the belief that we will eventually be able to get suppliers to provide test results, but we have to be diligent about it and we have to recognize that it will take time to get them trained.
* Although the law might be specifying lead (I haven't read that far), the wider problem is heavy metal (of which lead is just one of many). In my case, we discovered cadmium and chromium in our waste stream in addition to the lead that we expected (we were also using some strong solvents, but they were all well below reportable thresholds). The cad and chrome were probably getting wiped off of plated bolts and other hardware during cleaning. You know those shiny snaps, zippers, and what-not? Yep, could be. And lead isn't just a recent Chinese paint ingredient - it has a long history because lead is a useful ingredient in paint. It's malleable, white, and tastes good.
* Miracle's suggestion to call them is a good one. We should also be able to petition, participate in public hearings at the rule-making phase, and bombard representatives with requests for waivers, forbearance and/or relief for manufacturers of a certain size, etc. Two suggestions, then:
1) someone draft a form letter so that all of our representatives can get the same information and request for action and
2) can we set up a webinar for the members of this forum with a lawyer or authoritative CPSC employee to get these questions answered so that we can move forward instead of being paralyzed by uncertainty? |
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Miracle
Site Admin
Joined: 13 Jan 2006
Posts: 946
Location: CA
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| Posted: Tue Nov 11, 2008 7:12 pm Post subject: |
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| lead... tastes good. |
Really? Wow, that explains some funny questions i got about removal of the old tile in my house. Like... had my kids been eating it... And I was like who in the sam hill eats tile? What are you trying to say? |
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Eric H
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Joined: 02 Feb 2007
Posts: 205
Location: NM Albuquerque
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| Posted: Tue Nov 11, 2008 7:31 pm Post subject: |
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| miracle wrote: |
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| lead... tastes good. |
Really? Wow, that explains some funny questions i got about removal of the old tile in my house. Like... had my kids been eating it... And I was like who in the sam hill eats tile? What are you trying to say? |
No, the tile probably contained asbestos, which is great for fiber in your diet, but is otherwise tasteless, much like all of the other fiber in your diet. Unless they were talking about the mastic, which may have lead, which is reportedly tasty stuff:
| V(otum) S(olvit) L(ibens) M(erito) wrote: |
| Lead contaminated the homes of Romans in many different ways. Drinking water was transported along lead-lined aqueducts, through lead pipes, stored in lead cisterns, and maybe drunk from lead pewter vessels. The walls and woodwork of rooms were painted with lead-based paints. But one item in particular must have contributed to the lead in their diet, and that was a sweetening agent known as sapa. The famous Roman writer Pliny (23-79) gives the recipe for making sapa and specifically mentions that it must be made in lead pans. Roman cooks had only two sweetening agents that they could use for desserts: honey and sapa. (Sugar was unknown to the Romans. Sugar cane was originally to be found only in Polynesia, and gradually spread westwards reaching Europe about 800). Sapa was made by boiling down unwanted or sour wine in lead pans and we now know that the syrup so produced tasted sweet because it contained a lot of lead acetate. |
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Miracle
Site Admin
Joined: 13 Jan 2006
Posts: 946
Location: CA
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| Posted: Tue Nov 11, 2008 8:06 pm Post subject: |
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| No, the tile probably contained asbestos, which is great for fiber in your diet, but is otherwise tasteless, much like all of the other fiber in your diet. |
Nope. The lead was in the tile, asbestos in the ceiling. Isn't that crazy? You'd think since the stuff is no longer allowed that you could not sell a property with it in there. You should have seen me the day I found out i had an asbestos ceiling. But when I see this stuff happening in countries where environmental regulations are not as strict, I understand how.
Sorry for disturbing the topic with my random musings about my toxic house. Carry on. |
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Kathleen F.
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Joined: 08 Sep 2005
Posts: 11557
Location: NM Albuquerque
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| Posted: Tue Nov 11, 2008 9:58 pm Post subject: |
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Are we done discussing tasty children's snacks? 
Seriously:
| Eric H wrote: |
* Miracle's suggestion to call them is a good one. We should also be able to petition, participate in public hearings at the rule-making phase, and bombard representatives with requests for waivers, forbearance and/or relief for manufacturers of a certain size, etc. Two suggestions, then:
1) someone draft a form letter so that all of our representatives can get the same information and request for action and
2) can we set up a webinar for the members of this forum with a lawyer or authoritative CPSC employee to get these questions answered so that we can move forward instead of being paralyzed by uncertainty? |
We have a few lawyer members. I suppose I could approach one of them to draft something (?) altho our most recent lawyer member definitively disavowed participating in legal questions which I thought was kind of sad/bad because all of us bring insights and expertise from our existing or previous careers and few of us consider withholding it. But then again, I get it. She's probably annoyed by constant questions -like I'm not .
Minimally, I am willing to do a mass mailing to forum members or do an online petition thingy we can post to the blog, whatever is effective. Iow, I'm signed on to this in whatever ways you all think is most appropriate for me to lend whatever influence I may have. That sounds kind of wishy-washy, don't mean it that way. I like the idea of a webinar for members. I asked Vesta about her contacts (and a recall post for that matter) which are the most logical persons to solicit to participate but either she is too busy, is studiously avoiding me or is annoyed with the request and ignoring it. I can't say which it is. Then again, it could be owing to a combination of all three. |
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Vesta
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| Posted: Wed Nov 12, 2008 9:49 am Post subject: |
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| I asked Vesta about her contacts (and a recall post for that matter) which are the most logical persons to solicit to participate but either she is too busy, is studiously avoiding me or is annoyed with the request and ignoring it. I can't say which it is. Then again, it could be owing to a combination of all three. |
Yeah, a combination. 
I'll make an email introduction to my contact at the CPSC. But I will warn you that she's been difficult to get responses from since the recall ended. I'm apparently being triaged out of her list of priorities. I can understand that.
I can do a recall post, but I'm in the middle of a major reorganization of my company, as well as a new web site overhaul. And one of my employees went AWOL, and another one went all pregnant on me. So I'm swamped even with everyday stuff. Meaning, it won't be in the short-term.
And just so we don't let the distractions die totally, kids have been known to peel off lead paint and eat it, because of how good it tastes. Landlords beware. You're liable when that happens. |
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Miracle
Site Admin
Joined: 13 Jan 2006
Posts: 946
Location: CA
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| Posted: Wed Nov 12, 2008 10:57 am Post subject: |
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| and another one went all pregnant on me |
The nerve! :wink:
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| kids have been known to peel off lead paint and eat it, because of how good it tastes. |
Kids are just too much trouble. I'm going to sell mine on eBay. |
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unlimiteddesign
Renewing Member
Joined: 24 Sep 2007
Posts: 978
Location: CA Los Angeles
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| Posted: Wed Nov 12, 2008 11:05 am Post subject: |
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| * I wouldn't put too much stock into ISO certification. Yes, it at least indicates that they have some semblance of quality control, but the ISO 9001 certification became somewhat of a joke several years ago. For one thing, many ISO trainers are also certifiers, so there is a certain amount of conflict of interest. In fact, I took a class with one of those Mega-Lean/6 Sigma Blackbelt/ISO 9001 gurus from a local community college, and he pretty much said that the certifiers (of which he is one) now have a vested interest in passing people because - are you ready? - they offer money-back guarantees that you will pass. Look beyond the certification, ask questions, make them prove that they aren't just practicing paper tiger McQuality. |
Eric, I completely agree.... I never bothered getting certified here because I couldn't justify the costs involved in getting an "independent 3rd party" to audit our process.
Still, I would encourage people to at least get a book and see what the big fuss is all about 
_________________
-"Where there is a will, there is a way"- |
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Vesta
Guest
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| Posted: Wed Nov 12, 2008 11:33 am Post subject: |
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| Kids are just too much trouble. I'm going to sell mine on eBay. |
I'll throw mine in, and we'll give the buyer a group discount. |
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J C Sprowls
Joined: 25 Mar 2006
Posts: 2004
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| Posted: Thu Nov 13, 2008 9:10 am Post subject: |
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Update received from CPSIA, this morning:
http://www.cpsc.gov/cpscpub/prerel/prhtml09/09042.html
http://www.cpsc.gov/businfo/frnotices/fr09/certification.pdf
http://www.cpsc.gov/about/cpsia/108rfc.pdf - comments from working group requested
BTW... when you read this, you'll be no less perplexed. My initial read looked like they were saying: "Psych! We only meant to say...".
And, a second read left me with another impression. As always, it looks like you'll have to make your own compliance determinations (probably with the help of legal counsel).
Edit: add'l emails are streaming in. I'll continue to edit this post with the appropriate links.
BTW: has anyone learned how to join the working group, yet? If so, I'd appreciate the contact information or instructions. |
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Kathleen F.
Site Admin
Joined: 08 Sep 2005
Posts: 11557
Location: NM Albuquerque
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| Posted: Thu Nov 13, 2008 11:35 am Post subject: |
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I don't want to derail this thread so just a brief mention on ISO I'd meant to include in my previous comment.
| lisa versa wrote: |
| Any idea which third party certifications will pass for acceptable? Certified Organic, Oeko-Tex 100, ISO 1400, GOTS for dying or any others? Are these alone enough to prove you are working toward meeting the criteria? |
FYI: There's several kinds of ISO certs. Don't know who it was who hijacked ISO 14000, converting it to ISO 9000 (and it doesn't matter) but the difference is dramatic. ISO 14000 is a self certification program, essentially meaningless. You basically fill out the paperwork, announce your processes (no matter how inane they may be) and say you will follow them. Then you can put a big "ISO 14000" sticker in gold foil all over your brochures and letterhead. Just like in kindergarten when you got a gold star for raising your hand politely. It is because it is self certification and that there's no one to hold you accountable and yank your cert, that it doesn't hold much credibility. It only impresses people who don't know what it is.
| J C Sprowls wrote: |
| Yes, ISO-compliant fabric mills will perform testing. |
Not true in any way, shape or form whether it's 9000 or 14000. Both certs are tied to documenting processes and procedures (no matter how useless or necessary) and your adherence to them. ISO 9000 simply means an outside auditor has documented your adherence to whatever standards you say you will follow. It is not a patina of superior practices. One of your documented practices could be to kill a chicken and read its entrails before cutting a sample and as long as you adhere to it, you'd sail through auditing no matter how ludicrous the practice. Iow, your ISO compliant mill would have to officially include assay (and they may not!) AND include additional processes for correction of non-compliant goods AND subsequent assay for verification, in order for them to be a "compliant" source for our purposes. Summary: assay may not be one of their required internally defined processes. They may be relying on that chicken coop out back.
This is why I gave up on ISO almost five years ago when -I confess- I was going through the process of becoming an ISO auditor. It was through this exploration that I found the vastly superior Lean (officially) because it forces you to examine the necessity and value of your processes and ISO didn't, so it became a matter of integrity that I not have a hand in legitimizing dopey practices. Now, ISO is not entirely useless; it's invaluable to help you document your processes in simple language if you're not ready for the A4 reporting style typically used in Lean. |
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J C Sprowls
Joined: 25 Mar 2006
Posts: 2004
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| Posted: Thu Nov 13, 2008 11:46 am Post subject: |
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| True. Upon reflection, ISO is only as meaningful as the integrity of the compliance officer directing it. |
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Kathleen F.
Site Admin
Joined: 08 Sep 2005
Posts: 11557
Location: NM Albuquerque
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| Posted: Thu Nov 13, 2008 12:05 pm Post subject: |
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| J C Sprowls wrote: |
| True. Upon reflection, ISO is only as meaningful as the integrity of the compliance officer directing it. |
J C, the point is that it's not up to the compliance officer. The auditor has no say over the validity of your processes, only whether you follow the ones you've defined. |
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