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

[#1]

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*

[Former_Member]

I`m off to do some housework now even though I really want to hang out here and continue the discussion, it`s been a great one.

I`m going to check back later tonight or in the morning to see what`s come of it.

Cheers
:o)

[Former_Member]

HipMelon, I seriously could kiss you. LOL I have been trying to figure out this permanent label thing and never thought of that. Actually I have printed on printable fabric before but it ran when it got wet. That's what I get for not reading the directions. I forgot the iron step! I am going to try this tomorrow. I'm off too. Need some shut eye.

[Faeorain]

I usually go about every 2 weeks...trust me, around here, the stores are still loaded with the cheap toys from China that were made in the past few decades...like the ones that can be found at the dollar stores, and many of those items have been recalled.

I'm not saying I support the law the way it is...in fact, I am against it for the the most part due to the way it is set up. I'm just pointing out one of the flaws. If they are looking at it from a standpoint of protecting kids, it just doesn't make sense having the thrift store exemption. Trust me, a lot of that stuff is still going to end up on the shelves of the thrift stores. A lot of those workers are not that dilligent. My MIL and mother both worked in thrift stores, and they can attest to that. They take almost anything ( except used underwear..thank goodness).

[Former_Member]

it's the testing... with no respect to use of already tested supplies. the whole retest the final product is just absurd for people who aren't making 1000 of one item at a time.

[Former_Member]

thrift stores are not exempt... they are only exempt from 3rd party testing... but even if the inadvertently sell a lead contaminated toy, they face federal charges.

it made it pretty clear that they are to watch recall lists, and carefully take in stock.

[Former_Member]

testing definitely

[Faeorain]

staceyJEANonline says:
thrift stores are not exempt... they are only exempt from 3rd party testing... but even if the inadvertently sell a lead contaminated toy, they face federal charges.

it made it pretty clear that they are to watch recall lists, and carefully take in stock.

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I wonder if I should be saying something to them then, the next time I go in. I know I saw some of those vehicle and figure playsets from the dollar store the last time I was in there.

[Former_Member]

take them a flyer... i imagine the employees know very little. but, corporate should already be preparing. i'd think.

you never know tho.

[Former_Member]

Faeorain. I would broach the topic with them. They are already required to abide by the recall lists and if they aren't they ARE breaking current law. The CPSIA law (as was already stated) has made it clear that they need to be careful when taking in items.

I know regs in the US are different, but I can say here in Canada over the past 2 years or so I have seen a huge decrease in items on shelves that shouldn't be. a few years ago there was all kinds of OLD car seats and stuff being sold in second hand stores and now NONE, nada nil zilch. Some consignments will still take them, but I don't see them in thrifts or traditional second hand stores at all. Same goes for toys, things that would be recalled are generally not on shelves. some do slip through, but old toys with long cords and old fisher price toys that used to be everywhere are almost non existent around my area now.

People need to be educated, I believe if they knew better they would do better.

***back to the housework***

[Former_Member]

My problems with the law:

Redundant testing--can't do it in a financial sense, but haven't got any answers from the websites I buy my yarn from as to whether I can get MSDS (I think that's what they're called) from them! Not to mention by information on their own website there's little to no lead in yarn to begin with...

Labeling--I can most likely do the "who and where" part of the labeling requirement, just add my address to the labels I have now I guess. The date of manufacture and batch/lot identification are going to be difficult if not impossible though. I mean, look at my shop--other than the flower pins there's nothing there that's two of the same, and the pins are too small to fit a label on. And as someone else said, sometimes I get several things done in a day, sometimes nothing, how am I supposed to get dated labels for that kind of completion schedule? I can't. Also the way I work sometimes it takes several days to get an item done, is the manufacture date the day I start it or the day it's finished? I don't imagine CPSC has any ideas about that...

Really the only things I agree with in the law are the extra manpower and funding requirements, which should be put toward enforcing the existing laws that the recalled items violated.

I've seen a few comments in other threads saying we should be having CPSC staff scrutinizing imports, but I had a thought. Wouldn't that be under the jurisdiction of the Customs Service (which I believe is funded by the Homeland Security Department)? Maybe we need to have HSD reevaluate their priorities?

[Former_Member]

HipMelon
HipMelon says:
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.
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Yeah, or even just a sheet of paper along with the item that the consumer can save so they have the contact info in case they have any questions or problems. Especially for the smaller items for which there's really no feasible way to tag them.

[krtwood]

One woodworker that's been talking to the CPSC, they asked him well how do you know there isn't lead in the paint you are buying at Lowe's? Uh, because it's been illegal for 30 fucking years? You can't just pass off enforcement of the law to every business on Earth because you can't do your job. If they aren't sure there isn't lead in the paint at Lowe's then they should be asking for the funding to enforce the lead paint law, not passing the buck to me, to do the testing in the most inefficient way humanly possible, by waiting until it's been applied to 50 different things and testing each of them separately. The paint isn't going to magically become leaded the 31st time I use it. I am not going to use a stick of lead to stir it.

It's that the law is written to be the stupidest possible way to accomplish the goal you could come up with. They want to test the final product because something may have slipped through, so the only way to really be sure is to test the final product. But it didn't occur to them that is utterly impossible. You have to accept the fact that some things are going to slip through and mitigate the risks as best you can - in proportion to the magnitude of the risk.

[Former_Member]

Exactly krt....one of the articles I saw (or maybe it was a forum thread, not sure) was titled "CPSC Believes in Alchemy", and it seems like that's exactly what's going on. Lead in textiles and many/most other crafting supplies is nonexistent, or nearly so....if CPSC wants to try to shut us down they can do their own testing on our products. I for one have other things to worry about, my dd had a visit with her dad this evening and the perverted bastard tried to put his hand down her pants! Needless to say she's not going over there again...planning on calling CPS in the morning.

[kinchi]

krtwood said:
One woodworker that's been talking to the CPSC, they asked him well how do you know there isn't lead in the paint you are buying at Lowe's? Uh, because it's been illegal for 30 fucking years? You can't just pass off enforcement of the law to every business on Earth because you can't do your job. If they aren't sure there isn't lead in the paint at Lowe's then they should be asking for the funding to enforce the lead paint law, not passing the buck to me, to do the testing in the most inefficient way humanly possible, by waiting until it's been applied to 50 different things and testing each of them separately. The paint isn't going to magically become leaded the 31st time I use it. I am not going to use a stick of lead to stir it.

It's that the law is written to be the stupidest possible way to accomplish the goal you could come up with. They want to test the final product because something may have slipped through, so the only way to really be sure is to test the final product. But it didn't occur to them that is utterly impossible. You have to accept the fact that some things are going to slip through and mitigate the risks as best you can - in proportion to the magnitude of the risk.

[kinchi]

Oops, I wanted to ad: my sentiments exactly!

[Former_Member]

Forgot to ask in my last post...hey HipMelon, the printable tags you mentioned--any idea where they're available? Do they work with a regular computer printer or do you need a special device to print on them?

[kinchi]

I work with recycled fabrics from the 60's and 70's. I wholeheartedly agree with the post I quoted above. The problem I see is that things that are not a risk at all to contain lead should be tested. Dyed and normally printed fabrics are highly unlikely to contain dangerous amounts of lead. Because of the thinnes of the fibers and the fact that they should move and flow seperately after printing, leadpaint would be a very stupid choise to print them with. I bet not even a painting by Jackson Pollock would test above 600, speaking of paint on fabric..

[kinchi]

OMG Ruth!! Yes, go to the police, protect your girl! Good luck today.

[Former_Member]

RuthsCreations says:
Forgot to ask in my last post...hey HipMelon, the printable tags you mentioned--any idea where they're available? Do they work with a regular computer printer or do you need a special device to print on them?
__________________________________________

You can go to Walmart fabric dept, or to Michael`s and probably Jo-Ann fabric as well and look for Printable fabric. It will come in a package of 8.5 by 11 inch sheets. You can get 100% cotton or a cotton blend. Both work. When you take the fabric out of the package, it is stuck to a sheet of paper. You just put it in your ink jet printer like regular paper. Then with print shop or some label making program you can make your labels then print them on your printer. Then (with the brand I have used personally) you iron the fabric, then dunk it in water, peel the paper backing off and blot with a towel (no rubbing) then iron again and the ink sets good. Then you can cut the labels out with scissors and fray check the edges. It is not really as time consuming as it sounds. LOL. I have yoga pants that I made for myself at least 3 years ago now and I can still read the labels. Same goes for the ones I have put on blankets and clothing I made for my kids. Washed, dried and worn many times and can still read the labels fine. I use mainly wovens now, but the printed ones worked well.

Another option is to buy *dark t-shirt heat transfer paper* You can print on it with your ink jet printer then cut the tags out and press them directly onto your fabric. This is great if you are making plushies, you can press it directly onto the fabric on the bottom of the plushie. You can get the dark t-shirt transfer paper at Walmart in the stationary by all of the other iron on papers or again at Michaels craft store.

[Former_Member]

The heat transfer paper is what is used on the inside of many brands of t-shirts that have the tagless labels on the inside of the collars. More and more clothing companies are doing this. The wash wear on the dark fabric heat transfer paper is great.

Good Luck.

[Former_Member]

The law. It's so infuriatingly stupid.

[Former_Member]

If it were possible to get testing that would NOT destroy my item, for free or next to free. (lets say $1/ per material-color tested) I could do it.

However, lets say someone is offering testing at $5/item-material-color-dyelot tested...and I have to mail my inventory there, and pay for return shipping.

I've just quadrupled my production cost for the item that I make.

How many people will pay for a plushie, even made of very high grade materials, that is over $50 for a 4-6 in tall plushie? I've got plushies made of SILK at about $50 per...and I've sold ONE of those in a three year time frame.

[Former_Member]

and the more I've reread the law there more the impossibility of compliance becomes,

It's more than just the testing...
I never did get an answer of how to put a permanent label (or the information they want) on a 4-6 in tall crochet critter. They DO NOT allow "stickers" they do not allow hang or ribbon tags, because of the issue of the tags or stickers being removed by the consumer.

I emailed that question (along with about 6-7 very specific questions) and never heard back from ANYONE at CPSA, I sent my questions to the email address they requested questions sent to!

[Former_Member]

The site for the CSPA with the FAQ has a disclaimer right at the top that the FAQ should not be relied on!

Um OK, they can't guarantee that THEY understand the law, or how they are supposed to APPLY to law, and we're supposed to NOT BREAK the law?

[BikiniSandi]

Think of the sheer magnitude of manpower that will be needed to even enforce this new law.

Testers, and how many labs will need to be built? Construction jobs (woo hoo)
Officers to go around inspecting all stores, online and off
Secret Shoppers to act as officers to inspect all childrens items that might be missed by official officers in uniform
Government personel to send out warnings to offenders
Lawyers to file suits
Judges to handle the mountain of new cases to be tried
Jurors, ooops forgot they don't make enough to cover travel expenses to and from courthouse
Police to arrest all offenders that missed the court date
Prison guards for all the offenders that can't even make bail much less pay for testing on products
More construction jobs to build new prisons
The banks will have to go back to giving out loans to anybody and everybody even though no one will be able to pay them back
And the government will be officially owned by the banks within about 3 years.

But at least we won't be able to buy a toy that will catch fire if left within 25 feet of a hot stove. And we can eat all the toys we want to and consume less lead than we get from our water that we get from our own kitchen faucets.