CPSIA - QUESTIONS We need to have answered - ONGOING

[bobbinalong]

I talked to my Congressman's office this morning. Below is the email I received back from him. It is addressed to all of us. I put the attachment at the bottom. Control + click on it to open it.

I had emailed him one of our threads earlier this morning. As this thread builds with your questions, I can email it to him.

His reply to me. ===================================

Judy,

See the attached request for comments recently issued by CPSC. This seems to be a major issue with regard to handmade products.

This is an opportunity for you – the stakeholders – to provide input to CPSC about how you believe CPSIA will impact you and your suggestions for clarifications and steps that could help ease the burden (specific to testing requirements for component parts).

If you can provide me with a list of specific questions you have I’m sure our office would be willing to communicate with CPSC in an effort to get accurate answers (although it seems that final decisions/interpretations and, therefore, complete information on this won’t be available until sometime after the comment period ends on Jan 30).

http://www.cpsc.gov/about/cpsia/ComponentPartsComments.pdf

[KreatedbyKelly]

Thanks for this information!

[Former_Member]

Marking for later.

[bobbinalong]

I will begin.

♥; Are handmade items all required for third party testing, dolls, wooden products, clothing?

♥; Does this law involve donations also? Toy drives for kids? Craft shows? Thrift stores?

[wigglysee]

marking for later

[TheFurkidStudio]

I just sent this in:

I am an artist and use readily available, legally sold CONSUMER products to make my plush art, which I market and sell to adult collectors.

I use the following:

women's and children's socks
polyester fiber (from pillows)
thread and embroidery floss
buttons
cotton cloth

All of my items are purchased at department stores and craft stores. It seems to me that these consumer goods should be what gets tested, and not the final product that I, a one person operation, assemble them into.

I do not alter their content in any way, other than by cutting the cloth and thread with scissors. How can I be expected to pay hundreds and thousands of dollars for testing, just to make and sell my art?

Please address this--I truly believe that the raw materials--things that children are already permitted to buy--are the things that should be certified.

Thank you for this opportunity to be heard.

Best,
Stacey

[LaurieRyan]

sent this to a friend, now what I want to know is where can a person find out the real information on this new law so people know what is allowed and what isn't. I've heard way too many different stories here and would really like to know for sure, it does affect me as a business person but it does affect my friends

[Former_Member]

I don't get this. I thought all the hoopla was about lead in paint. How is fabric and thread an issue? Is there lead paint in fabric?

[Former_Member]

I just want to see what happens on here b/c I *need* some waldorf dolls and I can't get them untill after the holidays, I'll cry if I can't get quality handmade items which as far as I'm conserned are WAY safer than factory made one...

[organicquiltcompany]

Thanks for this -- I am marking for later!

[Former_Member]

I just posted in the Facebook group called "Help save handmade toys from the CPSIA" ~

One thing I haven't seen in all the online discussions on this topic is ~ where exactly are the laboratories we're supposed to use for testing? How many are there in the country? Could they even handle the influx of small crafters if we (hypothetically) wanted to pay the $$$ to get our stuff tested? And how long would this delay releasing a new product - 6 weeks? 6 months? 6 years? That alone should make the law unenforceable, because there's no feasible way to comply with it.

Also keep in mind - there's no money or staff allocated to enforcing this law. I really think this law will be suspended and re-written. I firmly believe, no matter how scary it seems no, we'll survive this. So keep up the good work, everybody - keep writing, blogging, petitioning, emailing and so on. We'll beat this!

[Former_Member]

Bumping for more exposure....

[TheTinyFig]

I want to know how to determine what types of jewelry are meant for a child and what aren't. I have seen people making everything from cute jewelry to fancy beaded, wire-wrapped jewelry very confused. At any point in their life ANY piece of jewelry can be worn by a child. What if you are not targeting children specifically but it is viewed by the general consumer that your items are youthful or child-like? And when does it become the parent's responsibility? When do they become liable for the choices they make for their children?

[TheFurkidStudio]

lrichmond--I can't imagine there is. But the way the law is currently written, in includes textiles and fabric. Makes no sense, but it's in there.

Thank you, US government!

[LaurieRyan]

Also makes me wonder are the labs lobbying for the law so they can increase their business??????? would that be possible?

[Former_Member]

here are some suggestions for amending the CPSIA:

1. Toys and children's products made in batches of less than 5,000 units per year or manufactured within the USA and trusted countries with established toy and children's product safety regimes such as Canada and the European Union be held exempt from third party testing requirements.

2. assume that natural materials (wood, wool, silk, bamboo, cotton, and uncoated textiles) and food-grade materials (wood finishes made from beeswax and certain oils) are lead- and phthalate-free, and don't require them to be tested. Such toys and children's products could still be subject to random auditing by the CPSC.

3. CPSC should be made to offer free testing services for USA toymakers, handcrafters and importers from Europe or Canada with revenues less than one million dollars.

questions:

1. why are safe materials being targeted: wood, yarn, textiles?

2. why should organic fabrics be targeted when they must be certified by GOTS which requires a lead content of less than 1ppm (the CPSIA allows 300ppm)?

I'll think of more

[TheFurkidStudio]

tinyfig, that's my issue exactly. It's so subjective...if your style as an artist is cute or whimsical, even if you're not marketing to kids, then the CPSC could come after you. They decide, regardless of your intentions. It's total BS.

[TheTinyFig]

You know, even if the CPSC does answer these questions they may not be accurate as everyone has been getting different answers from different reps. They themselves don't know how to interpret the law the way it was intended to be.

[Former_Member]

I think the Federal Government should be required to do an economic impact analysis on this law! How many small businesses would be affected? We have the individual crafters, the small manufacturers and cooperatives, the small retailers (they're speaking up on Facebook), venues such as flea markets, thrift stores, benefit sales and charities...

Some clarity here could deep-six this terrible law!

[Former_Member]

bumping to get others suggestions and questions

[bobbinalong]

Why can a mom go to a fabric store, purchase a pattern, fabric, thread and make her toddler an outfit. I can be standing beside her in the fabric store, at the cutting table. I purchase 2 yards of the very same fabric, from the same bolt, and take it home and make a toy or doll dress to sell. Why do I have to have 3rd party testing?

[chatnoirstudios]

Marking for later reading.

[Former_Member]

I really agree with the post by electicabyjan...this is the same agency that was supposed to regulating lead content last year...passing laws will not increase regulation. The government can't even regulate wall street...they are not going to be able to do this...and it will be in the courts for clarification since it self-contradicting...

that said, I take pride in my company and I'd like to grow my business and I don't want to do it "illegally"

[Former_Member]

marking

[bobbinalong]

More thoughts??