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ACTIVISM: Consumer Product Safety Improvement Act
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Kathleen F.
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PostPosted: Thu Nov 13, 2008 5:49 pm    Post subject: Re: time to act Reply with quote

MUUAAHHH to Jody
Okay, first I have kind of big news.

I am in contact with an attorney (Jennifer Taggert) in California to interview for the blog; she has clients going through this process (her comments in a bit). Prior to becoming an attorney, she was an environmental engineer. Two other tidbits, she has a business on the side doing the testing Eric mentioned (the heavy metals) and has tested over 20,000 children's products. She has a website called The Smart Mama and has a book called _The Smart Mama's Green Guide: Simple Steps to Reduce Your Child's Toxic Chemical Exposures_ coming out in June 2009. Her bio is here.

She is writing a response to the entry I posted today. She's also joining our forum. Hope you don't mind that I comp her.

Jody wrote:
The request for comments deals specifically with the phalate ban, which would also apply to children's products. When I read the document, my first thought was that my products don't have pthalates in them. But, then I started wondering about the buttons I use...

It would be to our benefit to see if we can join forces with AAFA to generate a greater political presence... If we do this, I think it would be important to first contact the AAFA and let them know what we're considering... And, the easiest way to do that might be to join forces with AAFA. We have only until February 11, 2009 to submit our comments. With the holidays coming, that date will sneak up on us pretty quickly. We need to organize now.

Kathleen, can you offer any suggestions on how we might do this from the forum (logistically speaking?). Also, I would be happy to call AAFA to discuss approaches with them. However, I would only do so if I have this group's blessing. If we have members who are also members of AAFA, they would probably be a more appropriate choice to have this conversation with AAFA. Just let me know.


I have already been pursuing the AAFA connection and I was waiting to hear back from Steve Lamar, Executive VP of the AAFA before I said anything. Steve convened a meeting yesterday with representatives of the industry to discuss this issue. That said Jody, I will likely need some logistical and other support you can offer in part because my executive functioning skills are poor. I wondering in the short term, perhaps to illustrate to the AAFA that we are serious about throwing our numbers behind them, whether we should do a survey on survey monkey or something. At this point I can't imagine how to structure something like that or what to write so Jody, if you can, it's all yours.

Now regarding Jennifer's comments on all of this. It is not good so it is imperative we act as Jody suggests.

She says the lead testing while not free, isn't the thing that will bury us; it's the heavy metals testing (phylates). She says it is very expensive. She says that even now, conditions as they are, her clients:
1. Are going out of business, this is the nail in the coffin and they don't want to deal with it anymore
2. Some are not complying, relying on the lack of inspectors
3. Others doing what they can.

For some balance, based on my estimated price of testing for a ten piece line in three colorways as costing $30,000; she says it doesn't surprise her. That's when she mentioned the phylate testing which would dramatically increase it.

Again, we need to weigh in with a formalized protest.
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Jody
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PostPosted: Fri Nov 14, 2008 2:37 pm    Post subject: Reply with quote

I will work on a formal comment to send to CPSC regarding getting an exemption from the pthalate ban for children's apparel. Again, I don't imagine many of us need to worry about pthalates in our products. But, the goal is to keep hammering away at getting children's apparel, indeed all apparel, specifically exempted. So, because the comment period for pthalates is now open, that's where I'll start.

It will take me a week or so to put together a draft, which I will post for this group's review and comment. As far as the best way to send it, we have a couple of options:

We can do this electronically in some way (I'm not up on all the cool techie stuff, so I'll have to consult someone on what the most effective means of doing this is).

Or

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. Then again, that's state government. The feds have already passed the buck on the "hundreds and hundreds" of comments they have received saying they don't have the resources to deal with them. BTW, being familiar with the way comment periods work, I can tell you that this is actually CPSC's way of letting Congress know what a mess they have created for the agency. CPSC isn't the bad guy here, it's our idiot Congress....but I digress....

We don't have to decide just yet -- we can figure out the logistics of getting our comments up to CPSC later. For now, please give me a week to do my research and write the comment. I'll send it to Kathleen to post so that everyone can review it and make any suggestions for improvement (I'm not a sensitive writer). PLEASE, DO NOT not print and send until I've had a chance to receive the group's input. Once I do, I'll finalize the document and work with Kathleen the logistics of getting it up to CPSC with the forum's power behind it (I should have some more specific ideas on how to do this by then).

Please also stayed tuned in. I know this is all very overwhelming for a lot of us. However, if we consider ourselves professionals or aspire to become professionals, we must take this legislation seriously. Kathleen has mobilized folks in a number of places to begin dealing with how this legislation might impact our industry. We are beginning to organize, which is an important first step in ensuring that this legislation doesn't put us out of business. What I'm doing is just one small piece.

The law has been passed, but the policy remains to be written. The more plugged in and organized we become, the more political power we have to help shape that policy.
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SarahM
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PostPosted: Fri Nov 14, 2008 2:59 pm    Post subject: Reply with quote

Are there any Congressmen/women or staffers that we should talk to about this? Get some support from within?

Ron Paul is my Congressman, but he's really out there. He won't even support NASA (in his district), since it's not in the Constitution.
But then again, he was the only member to vote against the Lead Ban in children's toys.
http://www.pensitoreview.com/2008/07/31/dr-ron-paul-casts-only-vote-against-lead-in-toys-ban/

Seriously tho, who do we know?
What other organizations can we partner with? http://www.cfda.com/ ?

I know the economy is a the major issue, but this is important too. Congress designed this regulation to make products safer, not to put folks out of work.
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Kathleen F.
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PostPosted: Fri Nov 14, 2008 4:37 pm    Post subject: Reply with quote

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 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.

The portion below is Jody's earlier work, cross posted from the other thread for purposes of continuity.

Jody wrote:
Hello all,
I have reviewed all three of the recently issued documents from CPSC that JC posted (Thanks, JC). The third link is to a request for public comment, which I think we need to act upon as a group.

Our forum clearly has a great deal of political will. If you read my earlier post, I explained about the importance of public comment periods and how they are our primary means for getting our voices heard, which is necessary to protecting our interests.

The request for comments deals specifically with the phalate ban, which would also apply to children's products. When I read the document, my first thought was that my products don't have pthalates in them. But, then I started wondering about the buttons I use...

Whether your products or mine may have pthalates in them is irrelevant. My point is, that amidst what is clearly chaos, we need to be vigilant about the way this law is implemented in the coming months. This means submitting comments during each public comment period for CPSIA rulemaking that could potentially have an affect on our industry. I work for government....we don't always get it right when we make the rules...

This is an opportunity to make the case to have children's apparel exempted from these requirements. There will be more opportunities in the coming months, and we should take advantage of each and every one to ask for an exemption.

Despite what you see in the request for comments, this is doable.
If you read the request, you probably think that you don't have access to the kind of information that they are asking for. And, you're probably right. I know I don't. So, I did a quick search on pthalates in children's apparel and found a golden nugget: https://www.apparelandfootwear.org/letters/phthalatecommentsapparel.pdf

This is a letter sent to the CPSC on October 18, 2008 by the American Apparel and Footwear Assoication (AAFA) specifically requesting that children's apparel be exempted from the ban on phtalates. This organization presents sound argument and has already mobilized to protect the interests of its members. We should do the same.

It would be to our benefit to see if we can join forces with AAFA to generate a greater political presence. I'm not sure what the best way to do this might be but a previous post made some suggestions in this regard.

One idea that would be very easy to for us as a group to implement would be to start a letter writing campain that builds off of the AAFA arguments for the exemption. If we do this, I think it would be important to first contact the AAFA and let them know what we're considering. In addition to being a professional courtesy, a conversation with this organization might help us to brainstorm additional ideas on how to inject some sanity into the coming regulation so that it doesn't put us out of business.

I think it's important to act on this. And, the easiest way to do that might be to join forces with AAFA. We have only until February 11, 2009 to submit our comments. With the holidays coming, that date will sneak up on us pretty quickly. We need to organize now.

Kathleen, can you offer any suggestions on how we might do this from the forum (logistically speaking?). Also, I would be happy to call AAFA to discuss approaches with them. However, I would only do so if I have this group's blessing. If we have members who are also members of AAFA, they would probably be a more appropriate choice to have this conversation with AAFA. Just let me know.


Last edited by Kathleen F. on Fri Nov 14, 2008 4:52 pm; edited 1 time in total
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michael.martinez
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PostPosted: Fri Nov 14, 2008 4:52 pm    Post subject: Reply with quote

We used this list (text file) when we fought tooth and nail against the bailout. It contains names, phone and fax numbers of U.S. legislators.
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Kathleen F.
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PostPosted: Fri Nov 14, 2008 5:12 pm    Post subject: Reply with quote

michael.martinez wrote:
We used this list (text file) when we fought tooth and nail against the bailout.

Well, thank you very much Michael!

Like I was saying, we need people to take responsibility for a sector, to promote the news within a community in which they are active altho perhaps not influential; iow, it needs to go viral.

1. People need to write about it on their blogs. We need a simple sample entry with a call to action that people can copy and paste to their sites, newsletters, email lists and forums to personalize as they see fit no matter how far ranging. The issue is, if this proceeds as outlined, this will affect everyone including consumers.

It would be helpful to develop a list of communities and get volunteers for each. Here's what I came up with earlier when I had downtime, by no means complete. If someone's name is there, it means that person has already started lobbying efforts:

Etsy- Esther
Youtube -can this problem be illustrated with video?
All the mommy blogs
All the mommy forums
Ladies who Launch
SUN (start up nation)
All the business and entrepreneurial forums
Society of Manufacturing Engineers -Kathleen
AME (probably Kathleen)
The Outdoor Industry
Coop America- Kathleen


Other organizations currently fighting the regulations:
AAFA -Kathleen
The Toy Association. Needed is a contact person so they know we're in with them.
Information Technology Industry Council
Consumer Electronics Association
IPC (source for the last three)

PRESS:
I've searched the archives of the following and don't turn up anything substantive.

WWD- (I wrote them)
WSJ
Apparel Magazine
Apparel News
The Economist
Drapers

Lastly, this is stupid but it will help. If you search for CPSIA Regulations on Google, Fashion-Incubator is the last result on the first page. Please click through from the search results page to F-I to help move it up to the top. If you search for CPSIA Requirements, F-I is first, or rather, I just checked it, it's now second. Please click on the F-I link from the google results page to keep it there. Thanks. We need to help others find us.


Last edited by Kathleen F. on Wed Nov 19, 2008 7:34 pm; edited 1 time in total
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Esther
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PostPosted: Fri Nov 14, 2008 6:13 pm    Post subject: Reply with quote

I'll do an announcement on the MomPack - a list of 5,000 mompreneurs. BTW, the Etsy discussion is up to 130 comments in 3 days. Definitely can be done on Youtube but I don't have any kind of camera.... 2 blog entries and counting at the DesignLoft.

Last edited by Esther on Mon Nov 17, 2008 8:04 am; edited 1 time in total
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Kathleen F.
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PostPosted: Fri Nov 14, 2008 6:32 pm    Post subject: Reply with quote

Everyone should post link to their threads and blog entries. I'll get mine later. That way the rest of us can go and provide back up as we're able.
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Valerie Burner
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PostPosted: Fri Nov 14, 2008 8:03 pm    Post subject: Reply with quote

I will do what I can with the ASDP. What about the publications that cater to them (sponsor as well)? Threads, etc...

I agree that the mass mailing would be most effective. I was also thinking about some of the FD schools that have instructors and students who make and sell clothing. (SCAD in Atlanta has its own store). How low will this go? Do you think fabric store chains would have any interest in joining the cause? Just some thoughts...
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DarbyC
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PostPosted: Sat Nov 15, 2008 11:43 am    Post subject: Reply with quote

Well, I don't know if it'll do any good, but yesterday I emailed the NYTimes about this... hoping they'll do a story on it.
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Jody
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PostPosted: Sat Nov 15, 2008 12:43 pm    Post subject: Reply with quote

A quick post...while doing my research, I ran across a CPSC website that provides the contact information for CPSC liasons in each state.

I plan to make a list of my questions and will probably try to meet with my state's liason. If each of us contacts our liason with our questions, concerns, we might get some answers or at least get a feel for what the "pulse"is relative to apparel (of course, the liasons may not really know yet, given the confusion that exists right now). More importantly though, this is yet one more way that we can begin to impress upon CPSC the amount of concern this legislation is creating in our industry. These liasons serve as the local (state) connection to CPSC and are likely in fairly regular communication with them on emerging issues:

http://www.cpsc.gov/businfo/state/state.html

Also, I ran across something else that looks like it might make for a good argument for an apparel exemption...This was published in response to comments regarding the revision of the flammability standard:

"F. Regulatory Flexibility Certification
The Regulatory Flexibility Act
(‘‘RFA’’) generally requires that agencies
review proposed rules for their potential
economic impact on small entities,
including small businesses. Section 603
of the RFA calls for agencies to prepare
and make available for public comment
an initial regulatory flexibility analysis
describing the impact of the proposed
rule on small entities and identifying
impact-reducing alternatives. 5 U.S.C.
603. However, section 605 states that
this requirement does not apply if the
head of the agency certifies that the rule
will not have a significant economic
impact on a substantial number of small
entities, and the agency provides an
explanation for that conclusion."


My initial thoughts are
1) I have not found any such dertification by the head of CPSC that this rule won't have a significant impact (if anyone else has, please direct me to it), and
2) The CPSC cold not have possibly done a thorough review under this requirement because they probably don't recognize the new, emerging sector of the apparel industry that DEs represent. My guess is that they have no idea how many of us are out here. This is why we need to find a way to quantify our sector in terms of size. We need to put our industry on the radar.

Kathleen, can you provide me with any forum statistics to use in making the case that the CPSC should conduct a regulatory flexibility analysis?

I'm also thinking that if we can put together some hard numbers (estimates) on the potential cost of this legislation to our businesses, most of which are indeed small to even micro, we might be able to use this argument effectively. I'm not sure how to do this...I've seen where some of you have tried to anticipate the actual costs of the lead testing. I'll pull these from your posts and see if we need more information to bolster our case.
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Liron
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PostPosted: Sat Nov 15, 2008 1:16 pm    Post subject: Reply with quote

At the risk of sounding silly, I don't know how much apparel is exported from Israel to the US, but if there is anything I can do to spread the rumor I'll do my best to help.
Liron
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michael.martinez
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PostPosted: Sat Nov 15, 2008 1:39 pm    Post subject: Reply with quote

There may be a way to tie this in with the economy and get more people on board. Can someone give me numbers of companies this might effect. I'm talking aggregate here. Like 2,500 businesses will close or something to that effect. I would also need sources.

I will run this by a rather large (7,000) group of people working on the Economic bailout stuff and see what they think... I'll do my part, because I think this is B.S... even though it will not effect me, at least directly. God speed, to all of you that choose activism, its all we have left.
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Liron
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PostPosted: Sat Nov 15, 2008 2:39 pm    Post subject: Reply with quote

I wrote an email to Israeli Export & International Cooperation Institute. I hope this helps.
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Jody
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PostPosted: Sun Nov 16, 2008 8:57 am    Post subject: Reply with quote

Valerie,
Yes - Fabric store chains will be highly interested in this, if not for the costs it will impose on their own business overhead, but also for the costs in terms of business. I was noodling around all the possible angles yesterday, and it occurred to me that many DE who don't have wholesale purchasing power obtain their raw materials from places like Joann's, Hancock, Hobby Lobby. Even if they aren't forced to comply, if this legislation drives the little people out of business, that will definitely affect their bottom line.

So, if you all can reply to this post with any retail fabric stores, I will draft a letter to send to thier corporate offices encouraging them to weigh in on this legislation. I can get the contact info for the big chains I know of here in the midwest (JoAnn, Hancock, and Hobby Lobby), but I would need names for any others in the rest of the country. Little locals shops will be OK, too, especially if you can get me contact info.

Michael - You're absolutely right that we need to put this in terms of dollars and cents. Unfortunately, statistic on the DE industry are hard to find. However, this isn't necessarily a problem. We can provide reasonable estimates in our comments to CPSC (they don't have the time or interest in verifying numbers....the goal is to force them, in a very public way, to think about the impact to small business).

In the letter I'm working on for this group and anyone else who wants to weigh in, I'm planning to use the numbers of folks on our forum, Etsy, eBay, etc. and contrast those with an estimate of costs that each business might expect to incur (Kathleen and others have posted estimates of costs that I can use). Another angle I'm looking at to get compelling stats is the Census Bureau, which keeps stats on all business sectors by way of the NAISES codes. Still looking into this, but it looks promising.

Back to work...
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