CPSIA-Is it the law or the TESTING that is a problem for you.

[Former_Member]

So, this is my feeling on this new law. I think that we all agree that the law is not a bad thing. We all want to keep our children safe. I have no problem with the law extending to cover children`s clothing and accessories. No problem at all. I also do not think that there needs to be exemptions from the law outside of NATURAL unfinished items like wood and cotton etc...as well the law should not be retroactive... that have already been discussed.

In the end I think it is the testing that poses the problem for almost everyone. I believe that instead of asking for a million exemptions to the law what people need to be fighting is the method of testing that will be required.

I think we should be fighting to make GCC`s a permanently allowable way of proving our items meet the conformity standards set out in the law. If I can get MSDS and or GCC`s from Michael Miller fabric for each fabric I purchase, Guutterman thread, the company that does my woven labels and the other fabric companies that I buy from, that should be enough. I have the certificates that state the manufacturers of the materials that I am using are certified lead and phthalate free and safe for use by children. That should easily prove that my end product, is also in compliance.

Do you get where I am coming from. I would just hate to see us fighting the wrong fight for the right reasons. Instead of fighting for 100 exemptions from the law, we need to be fighting for more accessible conformity for testing requirements. Thrift stores and consignment etc... should be a non-issue as long as they are selling non recalled, and reasonably current items, they should already be child safe, they should not need to test...period.

So....here is how I would like to see the end law. Natural materials in their raw state exempt from testing. GCC`s and MSDS sheets should be suitable as proof that an item is safe for children. Thrift stores, consignment (the entire second hand market) should be removed from the law 100%. I think other than that, the law is fine the way it is.

Anyone agree with me.
*sorry my question mark and some other punctuation is not working at the moment*

[boodybabies]

I completely agree. I did read a thread that linked to an article on a law that is designed to protect small business from "redundant testing", but I can't find the link now to explore it further...if it has any credibility.

[Former_Member]

It's more than just the testing requirements, it's the labelling requirements as well. Everyone is focused on testing right now, but after February, when that hurdle has passed, then we'll be looking at the regulations that go through in August.

I've finally found a way to comply with the law as of February, but come August I'm still out of business if the labelling part of the requirement AND the digestive testing by 3rd party labs requirement aren't amended.

[Former_Member]

I would be interested in seeing that article. I don`t know how I could have missed it. LOL, this topic seems to have consumed my life lately and US business only accounts for about 20% of my revenue.

[Former_Member]

I use upcycled and recycled material, so this solution still wouldn't help me, but I do see where you are coming from. People who make their own material would still also be stuck.

Besides, does the the manufacturer test for this? What testing is required for Michael Miller fabrics? I think these requirements are more strigent than those out there for things meant for adults.

[Former_Member]

I have this debate with myself daily. I was a huge advocate of getting control of lead in toys after all the recalls. I go on the recall website every month to browse how many more items have been recalled and make sure that my son doesn't have any in his possession.

I tend to agree with you about making sure the material I am using is certified, thread, and so forth rather than having to certify every final product and I'd be willing to pay the increased prices that will be a result so certified supplies would be the best option. IMO, I'd even be willing to test if I could continue to test with XRF or HDXRF and it was accessible for $20.00/less per test (preferably locally) but I was thinking although this would work for me, it wouldn't work many other . Also they'd have to remove the batch requirements and permanent labeling requirements completely.

[Former_Member]

It's definitely the cost of testing that's the biggest issue and the fact that it will have to be done over and over and over... The labelling thing isn't "such" a pain (unless you have tons of inventory in stock). But the way the law is written, it is basically impossible to fix. They need to scrap it and start over.

But beyond that, they are still punishing businesses that were never part of the problem. American toymakers did NOT start this mess, but now they're being forced to clean it up.

[qbranchltd]

This is a poorly written law. It also has been interpreted by CPSC badly and away from the intentions of Congress. The law was meant to stop IMPORTS with lead. It has been taken to extremes to include EVERYTHING involving children under age 12 including all currently shelved library books for children, elementary school text books in use, all handmade craft for children, all items that MIGHT be appealing to children, the removal and disposal of all children's items from store shelves in every store in the country, and on and on.

The testing is impossible to comply with for any small business. Large manufacturers may be able to comply with the testing - no small or home business will be able to. The costs of testing far exceed the income generated per item.

Just excluding natural materials in their raw state does nothing - will the world of children's clothes be natural beige in color in the US? Will children's furniture be unfinished? Unfinished wood warps and will not last.

This law must exclude the small and home businesses. It must exclude books and printed paper. It must allow retail stores to sell off the inventory that was safe a month ago but suddenly is deemed a "hazardous material". All in all the law is ridiculous as was Congress for rushing into passing legislation that will cripple the economy of this country far worse than anything it has ever experienced including 1929.

[PearlyGrey]

I am having a hard time getting a response from my snap and fabric companies....I am sure they don't want to be libel either!

[Former_Member]

For the product I make I already have to have permanent labels so adding to them for ME is not a huge issue, as I already internally, for inventory purposes, number and batch everything, however I do understand how it could be an issue for some. Because it is something I am already required to do it wasn`t something I have given a lot of thought to. I have a CA number so we are required to have fabric content and wash instructions affixed to the item on a permanent label. Like the kind when you buy clothing.

I think for labelling it should be sufficient to have the information required on a card that is just attached to the item with a tagging barb.

[Former_Member]

I think it is the way the law is written, not the concept behind it, that I'm not really happy with.

[Former_Member]

My argument is with the wide sweep of the law, not just testing. All books? All sports equipment? All school supplies? All clothing? All personal care items? Up to the age of 12 years? Much too broad a sweep. A law should be able to be complied with by the public and enforced by those in charge...this law cannot be implemented or enforced fairly and across the board...what kind of law is that?

[Former_Member]

I don't have an issue with permanent labels, I will use woven labels for my product. The problem is putting an ever changing GCC number (since it changes per batch) and having to list the date of manufacture, batch number and so forth. This is impossible if I am sewing them in my workspace. I don't pay a contract sewer to make 1000's at a time so even if I do a minimum order for woven labels to list this info I would have to do a min of 50 at a time. Cost would be too high.

[Former_Member]

I can't afford the testing, either batch or component. Labelling requirements would be tricky, but not as insurmountable as the testing.

The Act and the regulations stemming from it are also problematic in that it feels as though we're being caught in the middle of the politics of Congress/CPSC.

The legislation reaches too far and hurts too many people, and Congress/PIRG/etc. all hide behind "we did it for the children." Like they really care about my kids.

I'm not a fan of big government; I'd prefer that everyone take responsibility for him/herself and their families, rather than rely on the government for everything.

[Former_Member]

If you're talking about a garment, a permanent label is at least physically possible. But on a wider scale, for some items it is not possible to put a permanent label on them.

[Former_Member]

homecreations
homecreations says:
I use upcycled and recycled material, so this solution still wouldn't help me, but I do see where you are coming from. People who make their own material would still also be stuck.

Besides, does the the manufacturer test for this? What testing is required for Michael Miller fabrics? I think these requirements are more strigent than those out there for things meant for adults.
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Companies like Michael Miller (and I`ve heard rumblings from others of the bigger companies through the grapevine) are working on getting GCC`s to give to their clients. Most companies are already required to keep MSDS sheets on their products and if you ask for them they HAVE to provide them to their customers. If the fabric makers don`t have GCC`s or MSDS the companies that print the fabric WILL have MSDS sheets for the inks that they use to print the fabric.
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For people that make their own materials, depending on what they are they still shouldn`t have much of a problem. If they are making beads from FIMO, they can get MSDS sheets from FIMO. If you ask they HAVE to give them to you. If you are making soap you should be able to get MSDS from all of the companies that you buy your soapmaking supplies from, right down the line.

See I don`t think that the law needs to exclude books or printed items or small businesses, if we can get GCC`s from the companies that supply is with the materials we use to create our items. Companies that publish books need to have the MSDS to prove their inks are lead free.

I know that if GCC`s are allowed permanently it won`t be a problem for my business, and we are a small to medium sized business. Even XRF being allowed permanently would be fine for us as well as long component testing was added. For the fabrics that I can`t get GCC`s for if I can have a sample tested by XRF it will be fine. I can`t afford to test every finished product, but I can afford to do XRF component testing where I need to. I think if they can add more valid testing methods and allow component testing, that would be nice too.

The law is kind of like swiss cheese, and I do agree with the PP who stated it should be scrapped and re-written from the ground up.

[Former_Member]

CheekyMonster says:
I don't have an issue with permanent labels, I will use woven labels for my product. The problem is putting an ever changing GCC number (since it changes per batch) and having to list the date of manufacture, batch number and so forth. This is impossible if I am sewing them in my workspace. I don't pay a contract sewer to make 1000's at a time so even if I do a minimum order for woven labels to list this info I would have to do a min of 50 at a time. Cost would be too high.
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You can buy printable fabric and use an inkjet printer to print labels, I used to do that, once you iron it the ink is permanent, I have items I made for myself 3 years ago and labelled and you can still read the label. Once you print, cut the label out and fray check the edges and it is a good inexpensive permanent label.

Just a workable solution for those who are looking for one.

[Former_Member]

I love your store Bugga Love, esp, the anti-CPSIA stuff :o)

[Faeorain]

Sorry, can't quite agree.

The thrift store exemption makes the least sense of all. If the law is truly intended to protect children, the thrift stores should be the last ones to be exempt. There is still a lot of that recalled stuff floating around out there. Not everyone sends back recalled items. There were so many older products that people had for years, and with the long recall lists they had, I'm sure there are equally as many products that were never tested or discovered yet to be contaminated. People clean out their attics and garages after years of storage, and one of the first places it goes is to the goodwill or the sallies. As far as the law trying to keep contaminated items from kids, the thrift store exemption just doesn't make any sense.

[qbranchltd]

HipMelon says:
See I don`t think that the law needs to exclude books or printed items or small businesses, if we can get GCC`s from the companies that supply is with the materials we use to create our items. Companies that publish books need to have the MSDS to prove their inks are lead free.

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So you are in favor of National Children's Book Burning Day - all current library books for children and all school text books must be destroyed on Feb. 10. Can your taxes support the replacement costs?

This law cannot be looked at narrowly to just the extent of crafts. This law is far reaching. There is a larger world of impact than just crafts.

[Former_Member]

My objection to the law was it was hastily done and poorly thought out. There is no reason redundant testing or testing on materials that just aren't applicable needs to be done.

Personally, I would prefer to see a labeling law. For first sale in this country, a product must be labeled as: tested for lead, phthalates, etc. and are at safe levels for children; tested above these levels; nature material inherently lead and phthalate free; or were not tested. Lots that are tested would recieve a unique identifier number that would be part of the label (making recalls easier too).

Assemblers/manufactures that only used products sold in the US could instead file a form listing each material used in each lot as well as the labeling info provided on the products they used. (Of course, only products that passed testing or are inherently safe could be used in making the final product.) They would then be allowed to label the products with a special "made from safe tested materials" label.

Of course, OOAK items would be still be a problem if you want labeling, but having the ability to label "not tested" should work well for many.

I think this would solve the controversy of testing, both the cost as well as the issue of defining what items should be tested. This would also allow parents greater ability to fill their homes with safe items, including safe items not considered children's items (like couches, cookware, and mom's jewelry) that their children may well get into.

While protecting children (and all people) is important, I would rather see the government work towards empowering the consumer to make informed decisions than legislate every single facet of our lives.

[Former_Member]

I already stated (if I didn`t then it was an oversight on my part) the retro-active part of the law did need to be taken out. I don`t want to see ANYTHING currently on shelves thrown into landfills or burned.

I am talking about moving forward for the future.

Sorry if I wasn`t clear there leaving myself open for a missunderstanding.

[Former_Member]

Would definitely be better to require the manufacturers of materials to supply certification, rather than test the finished product. But that could also be problematic, since pretty much anything, especially for those hand-making stuff, could potentially be used as a supply. For those who upcycle, getting such certification would be impossible.

Personally, I think that all businesses making under a certain amount per year should be exempt from testing and simply allowed to place a disclaimer on their products - let the consumer decide!

[Former_Member]

HipMelon says:
I love your store Bugga Love, esp, the anti-CPSIA stuff :o)
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Thank you HipMelon :)

[Former_Member]

Faeorain
Faeorain says:
Sorry, can't quite agree.

The thrift store exemption makes the least sense of all. If the law is truly intended to protect children, the thrift stores should be the last ones to be exempt. There is still a lot of that recalled stuff floating around out there. Not everyone sends back recalled items. There were so many older products that people had for years, and with the long recall lists they had, I'm sure there are equally as many products that were never tested or discovered yet to be contaminated. People clean out their attics and garages after years of storage, and one of the first places it goes is to the goodwill or the sallies. As far as the law trying to keep contaminated items from kids, the thrift store exemption just doesn't make any sense.
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Thrift stores need to use common sense when accepting items. It is fairly clear and easy to tell what is old and what is reasonably current. Anything made since the advent of the internet is fairly easy to find out if it has been recalled. Most thrifts already do not accept items like car seats and safety equipment, at least in Canada they don`t. In the current exemption for thrift stores it already states they should not accept items that are LIKELY to not pass current standards and they are already required to check recall lists, so if they ARE selling recalled items they are already breaking the law, long before the new law goes into effect.