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mollyodesigns
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PostPosted: Sun Dec 07, 2008 2:28 pm    Post subject: Reply with quote

Where is the standing ovation smiley face?! Kathleen, that is why we are all here looking to you for guidance. I will be sending this on immediately to Boutique Cafe, Designing Minds, Bijou Americano and Boutique Buyers Blog just to name a few. I will also post on my blog and send on to my email list of custom boutique designers. Also, posting on several ebay boards. I will of course take Amy's name out and the specifics about Journal Modiste. I will add to the list as I send it out.

Thanks!
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mollyodesigns
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PostPosted: Sun Dec 07, 2008 4:56 pm    Post subject: Reply with quote

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Last edited by mollyodesigns on Mon Dec 08, 2008 10:44 am; edited 1 time in total
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Lisa DOWNTOWN JOEY
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PostPosted: Sun Dec 07, 2008 6:12 pm    Post subject: Reply with quote

Amy Shearer of Journal Modiste is an old friend of mine. She's already sent out another letter to all members of Journal Modiste.

I'm sure Amy has nothing but the best intentions. There have been several situations in the boutique community where Amy acted with the upmost integrity.

Seems she wants to truly help, not give bad info. Here's her letter:

December 06, 2008

Hi everyone,

I need to clarify something I said earlier, I shouldn't send emails out past my bedtime ;). I said that I didn't think this would effect you and I may be wrong. I am not a lawyer and should not have made that comment. I don't know if it will effect your business, I hope it doesn't, sincerely hope it doesn't. I was just trying to bring some calm and probably misspoke.

We need to treat this like it will effect our businesses and write/email/call the members of the subcommittee NOW. I just did. Even if it doesn't effect our businesses personally, it will devaste whole industries of children's toys and other products from small manufacturers that we love.

Here are some direct links to the law:
http://www.cpsc.gov/ABOUT/Cpsia/cpsia.html
http://www.cpsc.gov/cpsia.pdf

Thank you and let's all work together to change this law,
Amy Shearer
http://www.journalmodiste.com
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mollyodesigns
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PostPosted: Sun Dec 07, 2008 6:16 pm    Post subject: Reply with quote

I'm so happy she sent out another letter. I don't think she ever had bad intentions I just don't think she had an understanding of how horrible this will be for people. She has an very large audience of designers who will listen to her. Those are the type of people we need to get the correct information out there :)
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senecahart
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PostPosted: Sun Dec 07, 2008 6:45 pm    Post subject: Reply with quote

I just wanted to say that I received both Journal Modiste letters, and I am glad that the second one was sent out- a lot of people are confused and looking for direction and guidance, and any one reassuring anyone that they won't be affected without something to back it up is not a good thing.

Kudos to Amy for clarifying her mis-statement.

As to the title of this thread, any one else frustrated, YES, I am. I posted my concerns about the CPSIA on a forum and this is the ONE AND ONLY response I got:

"ok... The way to circumvent this issue for craftsman to NOT label the object as a "Childs toy" but to label it a a collectors item. You put in micro print "Not intended as a toy" Or for clothing "Doll clothing" There are way around everything. I make handmade tutu's and and Jewelry, I make childrens room decor. But before I decorate a childs room I tell the parents " These objects are not intended for Children" then I proceed. It covers my ass if the kids pulls a letter off the wall and gnawls on it.... Now I don't use leaded paint or anything toxic. BUT should the child pull it off and eat it, I TOLD the parents it was not a toy...... so its on the parents after that. I've bought several hand made wooded toys for my children (Hey I've got three and wood lasts a long time) and ALL of the artisans told me that "they are NOT toys" So what I did with them was up to me...... I understand the concerns for the "little" guys, but I also have to be concerned with all the import crap from China, Vietnam....I would rather circumvent the law than to let mass producers of toys get away with contaminated crap..."

So is she going to pay my 100K fine I wonder?????
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April
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PostPosted: Sun Dec 07, 2008 9:42 pm    Post subject: Reply with quote

Kathleen F. wrote:
Etsy management has already stated they intend to enforce the regulations strictly. Anyone who lacks the official certification from an approved lab, will be banned from selling affected goods on Etsy.


Where did you hear this tidbit? Recently, there has been a lot of chatter on the Etsy forums concerning CPSIA, but as far as I have been able to tell, Etsy management has been completely silent on the issue. I imagine this statement would make QUITE an impact if it was posted in the forums...
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April
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PostPosted: Sun Dec 07, 2008 10:08 pm    Post subject: Reply with quote

Never mind, I saw the response on another thread -- a response from an etsy admin stating that selling non-compliant goods would violate the terms of use...
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Miracle
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Joined: 13 Jan 2006
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PostPosted: Sun Dec 07, 2008 10:33 pm    Post subject: Reply with quote

Quote:
"ok... The way to circumvent this issue for craftsman to NOT label the object as a "Childs toy" but to label it a a collectors item. You put in micro print "Not intended as a toy" Or for clothing "Doll clothing" There are way around everything....... I understand the concerns for the "little" guys, but I also have to be concerned with all the import crap from China, Vietnam....I would rather circumvent the law than to let mass producers of toys get away with contaminated crap..."


This kind of crap is annoying and is why, much of the time, small business doesn't get heard and doesn't get support. Indie operators are most likely to work in blind ignorance of the laws that concern them, shirking it off believing it only applies to "the big guys". Telling somebody "I'm not liable" doesn't mean you're legally not liable.

I wouldn't be surprised if people started policing sites like that, and statements like that, and turning people in for violations.
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Kathleen F.
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PostPosted: Mon Dec 08, 2008 9:18 am    Post subject: Reply with quote

senecahart wrote:
I just wanted to say that I received both Journal Modiste letters, and I am glad that the second one was sent out- a lot of people are confused and looking for direction and guidance, and any one reassuring anyone that they won't be affected without something to back it up is not a good thing.

Kudos to Amy for clarifying her mis-statement.

I wish I could be as pleased. I wish she'd gone beyond the cpsc links to provide her readers with connections to others working on this. No wonder this industry is so fragmented.
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blizzard77
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PostPosted: Mon Dec 08, 2008 12:28 pm    Post subject: Reply with quote

Kathleen F. wrote:
. As I've said elsewhere, I think we need to start an aggressive cpsia enforcement campaign and report violator's to their state AGs office. It's nothing personal but there's no other way to get these people off the pot.
.


Kathleen, that may well be necessary in the future, but considering that none of us are sure WHEN we would need to begin such a campaign IMO it should not be of focus right now. And WHO would it focus on? Those with over 600ppm of lead or those who are over 99ppm? Who are we to judge what a "reasonable" testing program consists of?

Consider that we likely (can't use definite statements when talking about this nebulous law!) do NOT have to have third-party lead testing completed by 2/10 but we DO have to have it completed by 8/14/09 since most of us *know* our products do not have over 600ppm of lead (which is what the CPSIA says is prohibited on 2/10 along with the requirement to implement a "reasonable" testing program). Those with products under 600ppm are not immediately at risk for prosecution nor are they distributing "hazardous goods".

So, that leads back to my original problem. What constitutes a "reasonable" testing program for a (very) small, independent manufacturer as that IS required on 2/10? Most over-the-counter lead test swabs are not intended for use on textiles. And most of my particular components are not tested okotek standard. So neither of those "reasonable" solutions work for me. If there is a thread going on this, please could someone post it for me? Thanks.
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Esther
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PostPosted: Mon Dec 08, 2008 12:46 pm    Post subject: Reply with quote

Quote:
Consider that we likely (can't use definite statements when talking about this nebulous law!) do NOT have to have third-party lead testing completed by 2/10 but we DO have to have it completed by 8/14/09 since most of us *know* our products do not have over 600ppm of lead (which is what the CPSIA says is prohibited on 2/10 along with the requirement to implement a "reasonable" testing program). Those with products under 600ppm are not immediately at risk for prosecution nor are they distributing "hazardous goods".


The CPSC has not defined what a "reasonable testing" program is and that is open for individual interpretation. What they have done is ban products with 600 ppm of lead on February 10, 2009 with successively lower limits over time. You can't assume your products are below that amount. You have to prove it. This means you can not sell your product without certification. Assuming will get you in a world of trouble.

Another misconception is that previously existing safety regulations must be met. This includes the FFA (fabric flammability act), small parts, and whatever regulations previously existed on your product. These regulations must also be certified for children product makers. The only difference between then and now is you can't fly under the radar because of the size of your business. If you don't have certification proving your products are safe, even if they truly are, you can not sell them in the US.
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Kathleen F.
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PostPosted: Mon Dec 08, 2008 12:47 pm    Post subject: Reply with quote

blizzard77 wrote:
Kathleen, that may well be necessary in the future, but considering that none of us are sure WHEN we would need to begin such a campaign IMO it should not be of focus right now.

Not true. Products subject to lead must conform by 2/10 contrary to myriad misstatements on the net.

Quote:
So, that leads back to my original problem. What constitutes a "reasonable" testing program for a (very) small, independent manufacturer as that IS required on 2/10? ...If there is a thread going on this, please could someone post it for me? Thanks.

Again, as stated elsewhere, it must be a CSPC approved lab. ONLY. The thread for lab resources is [url=//fashion-incubator.com/phpbb/viewtopic.php?t=3259]here[/url]. Obviously, few of us agree this constitutes a "reasonable" testing program but then we're not making the rules are we?
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Julia S
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PostPosted: Mon Dec 08, 2008 9:05 pm    Post subject: Reply with quote

Per Molly's statement, "With all the people that keep saying "this doesn't apply to me" and acting like we are making all this stuff up?! "
I have to agree 100%. Along with being a freelance fashion designer, I teach fashion design and have mentioned it to a couple of my colleagues who do not understand the impact of it even for us as we instruct our students, some of whom are planning on entering the children's wear market, that this is bad.

I have been watching and reading everything from the sidelines about these new regulations and from a freelance designer's point of view, whose children's wear clients are 95% of my business, I have to know what is going on in order to best guide them as well. However, everything is becoming so overwhelming that the only true statement I can make is that the decision to pass these new regulations is insane.

Now, I can understand what brought about the regulations and that was the lead content in toys imported from China, and of course, everyone wants to make sure that products that we give and sell for children are as safe as they can be, however, from what I am reading, it is the requirement of so many tests, that in my opinion seem redundant in some cases, and the high costs, which is worrisome.

I agree with Kathleen, the new regulations are bad for both small businesses and large businesses. And the consumers and consumer advocate groups are thinking they are doing great with having the law passed. Are they going to be happy with spending $200 on a playsuit for a child? Because ultimately, price points will be going through the roof and in the end the consumers will be asked to pay up if they want that item.

I have been trying to catch up on all of the posts here and on the NationalBankruptcyDay.com site for the past couple of days, and I am still overwhelmed, and I haven't even finished reading everything.

I would like to know if there are any other instructors out there that are finding all of this as an alarm for concern and if you are passing on the information to your students and fellow instructors. If so, are you finding that people are receptive, or as Molly put it, being looked at as if you just went bonkers?

I have been trying to get the word out and have been bombarding my email contacts with the links to the petition and to this site.

I believe that if we can all start banding together, big and small, we MIGHT be able to push for those amendments sooner than later. At least, I would like to think so.
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dd
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PostPosted: Mon Dec 08, 2008 10:00 pm    Post subject: Reply with quote

Kathleen F. wrote:
blizzard77 wrote:
Kathleen, that may well be necessary in the future, but considering that none of us are sure WHEN we would need to begin such a campaign IMO it should not be of focus right now.

Not true. Products subject to lead must conform by 2/10 contrary to myriad misstatements on the net.

Quote:
So, that leads back to my original problem. What constitutes a "reasonable" testing program for a (very) small, independent manufacturer as that IS required on 2/10? ...If there is a thread going on this, please could someone post it for me? Thanks.

Again, as stated elsewhere, it must be a CSPC approved lab. ONLY. The thread for lab resources is [url=//fashion-incubator.com/phpbb/viewtopic.php?t=3259]here[/url]. Obviously, few of us agree this constitutes a "reasonable" testing program but then we're not making the rules are we?


I think some correction is in order. On feb 10, 2009, general conformity certificates are required for childrens products and they cannot contain more then 600ppm after that date. On aug 14, 2009, the level drops to 300ppm and certified 3rd party testing is required. Total lead testing cannot be done by a certified lab on feb 10 because they have not even certified labs for that test yet. Don't mix this up with lead paint testing. Third party lab certification wont take place until june 2009.
See this time line for all this http://www.cpsc.gov/ABOUT/Cpsia/faq/101faq.html#section101timetable. This is not to say that third party labs won't be used on feb 10 because most will have to use them to determine what they need anyway. But I think some need to quit promoting the idea that certified 3rd party lab testing is needed for lead in substrate as of feb 10.
--------------------
Correcting my self: total lead testing 3rd party lab accreditation procedures will begin in may 2009 according to the time line.
-------------------
And further clarifying my statement now that I read it.. General conformity certificates are required pertaining to the total lead content testing after feb 10. This is in addition to general conformity certificates already being required for products made after nov 12, for all other laws already in place..
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Jennifer Taggart
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PostPosted: Tue Dec 09, 2008 2:12 am    Post subject: Reasonable Testing Program & Timing of 3rd Party Testing Reply with quote

DD is right. Third party testing is not required for total lead in children's products on 2/10/09. The 3rd party testing is required 90 days after the CPSC publishes a notice on it - and the CPSC has NOT published a notice on lead testing, only lead paint testing. In fact, the CPSC has to publish a notice on lead by May 16, 2009, for the 300 ppm standard that starts in August of 2009.

In fact, in the CPSC's FAQ talking about testing, the CPSC states that as of 2/10/09, children's products will have to have general conformity statements which can be based upon a reasonable testing program, and that third party testing will be required for the 300 ppm in August of 2009.

Is that a distinction without a difference? No, it is not. A reasonable testing program is a much more flexible standard. It may involve relying upon 3rd party testing, but does NOT have to. It may involve component certifications from suppliers. And, it may involve testing using a Niton XRF portable analyzer, such as the CPSC suggested during its presentation on November 6 on lead.

I've got a Niton XRF analyzer that I use to consult. Just point of information, my rates are much lower than laboratory testing. One can also rent a Niton XRF analyzer for a relatively low cost compared to laboratory testing.

Jennifer
www.thesmartmama.com
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