CPSIA Fianl Rule 8-19-09

[TanteMay]

http://www.cpsc.gov/businfo/frnotices/fr09/leaddeterminationsfinalrule-draft.pdf

I can work with this! What a difference from a year ago.

[Former_Member]

I hope lots of sellers feel that way coffeelady. What would Etsy be without all the great baby and kid stuff?

[Former_Member]

Not to mention all those adorable kid and baby photos modeling them lol. The front page would truly suffer. :)

[Former_Member]

I'm confused about the last paragraph... does solder on sterling need to be tested or not?

[Former_Member]

Thanks for posting. I'm finally feeling like I can start to create again without all the fear... I'm just trying as much as I can to use all exempt materials. Oh, and I am thinking a lot of us should become attorneys on the side for all the briefs we have read.

[Former_Member]

I'm glad that they changed 'material/fabric' to 'textiles' - that is very handy - yay!

I'm a happy girl, I've ordered my labels, I undersatnd my requiremetns - I can now go to bed relatively happy.

I only have to work out my metal self cover buttons now :)

[Former_Member]

If only I could spell...

[Former_Member]

Aag is it just my computer or is that a whomping big file? Taking forever to read it...the suspense is killing me...

[Former_Member]

Thanks for posting! I got it in my email last night, but didn't have the strength to read... Perhaps later today (after coffee).

[knitwit4ever]

So now we get creative with fasteners...or test our buttons. But at least the textile exception has been confirmed!

[Former_Member]

it looks like this is a summary in plain English (and a good deal shorter)
http://www.whatisthecpsia.com/?p=486

[Former_Member]

Thanks! I got the email notice of this yesterday! I haven't had a chance to really read it through yet though, I'll be home most of the day, I hope to decipher it later.

[Former_Member]

mcperrault says:
I'm confused about the last paragraph... does solder on sterling need to be tested or not?


IMO once you apply solder or any other non-exempt component to the sterling silver or other exempt metal they are saying that the once exempt material is altered & is no longer exempt and the whole piece needs to be tested for lead content. It's very similar to what they are saying about fabrics and paper -
For fabrics that are colored with a process other than fabric dye (exempt) like pigments (non-exempt) used in screen printing the whole finished piece will need testing.
For paper products like books any printed with the CMYK process will not need further testing as long as the binding procedures are also met while any other printing process will need to undergo the 3rd party testing.

[Former_Member]

Thanks, I'll have a chance to read later.

[Former_Member]

Just finished reading the entire document - now that is a much saner rule! Much easier to comply with. Also noted that the Commission will continue to consider requests for further determinations (exemptions) as long as they are accompanied by the proper documentation to back up the requests.

[Former_Member]

so if we sell onesies, we have to have the snaps tested?

[Former_Member]

I can't believe that it states flat out that the CPSIA will not harm small businesses. WTF????

I am holding on to the hope that they will consider component testing still. They said they'll issue rules about that later.

I will happily send my paints out to be tested, but not each time I put them on a different shaped animal. That's absurd.

Happy for you textile people that you get some relief. No relief for me yet.

[Former_Member]

It's still all so stupid. So many problems they haven't addressed. For example, if I pay for a particular craft paint to be tested by a third party lab, and the paint test comes back okay to use, then why should another crafter pay to have the exact same paint tested?

I realize that paint is a huge source of this whole lead contamination issue, but the method for gaining assurance that painted products are lead free is not efficient. Plus, I can bend over backwards to get all these paints tested, destroy my products in the process, send them out to be tested again and again each time I make a new pull toy animals, and STILL I could switch them and use lead filled paint if I wanted to.

This law is completely ineffective in that regard. The whole debate is framed as children's safety vs financial impact on businesses, but nobody is questioning whether it really makes products safer. If an unscrupulous manufacturer wanted to get around this law, it would be soooo easy to do so.

[bobbinalong]

Doesn't the OP's link say "draft"? To me, that does not mean it is final.

[azek2000]

I have a question. If I have documentation that the barrettes I use are safe and lead free, then I am ok? Since the manufacturer tested them?

[Former_Member]

No, azek2000, you will eventually have to test them yourself (after the stay expires). Stupid, huh?

How many people will have to send off a package of Dritz snaps to be tested? The commission has to address this redundancy.

[AllNaturalSleepShop]

marking for later

[Former_Member]

OK, I've read through most of it, skimmed what didn't seem to pertain to me. It's a step in the right direction. But once this stay is over if I have to test the hairclips that I use, I'll have to shut down unless it gets to be very affordable to test. I know that the clips are OK to use because my supplier has tested and I have the GCC for them. I think it would be rediculous to have to test them again.

[Former_Member]

What if you get your snaps or clips from a third party who has actually paid to test their products?

[Former_Member]

modmomME says:
What if you get your snaps or clips from a third party who has actually paid to test their products?
_______________

I'm hoping that that will be OK too! so far I think we will still need to test ourselves.