CPSIA Virtual Lab

[Former_Member]

So my baby started screaming during the Q&A and I was unable to finish and see if my Q got an A. Did they answer whether or not they think component testing will be allowed in the future? i.e. if I make a shirt with exempt materials and have snaps that have been tested by their manufacturer will that suffice? Or are they going to go back to where you have to test the final piece?

I know component testing will suffice now but was curious if it will after 2/11.

[knitwit4ever]

Yes, they talked about it. If I remember right, go to the CPSIA homepage link, then Topics, then Lead and look for info. He said some component testing was currently being allowed, though I haven't read any details.

[Former_Member]

I think that he started to talk about it, but then it seemed to get unclear. Maybe that was the time that I had to go and stop my DD from banging the glass on my grandfather clock.

Was it clear to anyone else?

[Former_Member]

Yes, they talked about it. If I remember right, go to the CPSIA homepage link, then Topics, then Lead and look for info. He said some component testing was currently being allowed, though I haven't read any details.

I wish that he had been more sepcific about things, and a LOT less specific about others. I don't think that there are many sellers on Etsy who are making bath seats, and high chairs made out of plastic, but there are a lot of us who are confused about batch numbers, componet testing, and tracking labels which he seemed to gloss over.

[moonstr]

http://www.etsy.com/storque/events/cpsia-join-cpsc-officials-for-a-chat-with-sellers-7385/
click words marked power point in blue

[Former_Member]

Sorry, I'm back the baby was screaming again. He's got his first cold.

Right, I saw the presentation. I was curious about the question and answer period. I know that currently they are allowing for us to keep the certificates on file for our components if they were tested already. I was hoping they would clarify if that was going to continue or not.

If it was then, then I have a source for exempt material closures and some lab tested snaps to use in baby clothing. If they are planning on NOT allowing us to use another manufacturer's testing then I don't want to invest my time and money in creating a product line I then won't be able to sell in a year.

I will not have the funds to pay for my own testing, whereas I do have the funds to pay a larger supplier I bit more for tested components. The larger supplier can spread the cost around for testing giant bunches of snaps.

Does this make it clear as mud? :)

[Former_Member]

Alright, baby is asleep and now I think I'm getting the cold as well... *sigh* If anyone got some clarification please let me know. I'll check this thread in the morning.

[qbranchltd]

Any way to read through the transcript?

[knitwit4ever]

The closest I can find, following his suggested source for the info, is this:
http://www.cpsc.gov/businfo/frnotices/fr10/comppol.pdf
See page 68594 (2nd page of document), Item #9

Reads to me that any kid's product (non-paint, non-jewelry and non-exempt materials only) manufactured before 2/10/2011 can use paperwork for compliance; after that component testing will be required.

But I'd love to be wrong!

[LeafandYard]

He did address that question, and he basically said the commission has been talking about it since December. It sounded to me, though it could have been more clear, that they were working on allowing that as part of the law, or at least considering it.

[knitwit4ever]

I agree, Fyrecreek, it sounded like there was more possibility than was apparent in that 12/09 document. But it wasn't all that clear!

[LeafandYard]

Better to tell us they're talking than to just say no, I suppose!

[Former_Member]

Thats good news! If they weren't considering it then they would have given the definative "No". Since they haven't had any problems saying no in other areas. All business is a gamble, I just wanted to make sure it was still on the table.

[Former_Member]

As a Canadian I'm just curious; if you were to export your products to another country that was unaffected by the CPSIA, would you still have to meet their requirements to export?

[Former_Member]

neatTreats says:
As a Canadian I'm just curious; if you were to export your products to another country that was unaffected by the CPSIA, would you still have to meet their requirements to export?
____________________________________________________________

Though he did not address that in last night's meeting the way I understand this law is that children's items that do not meet the CPISA standards can not cross state borders without possible reprocussions for the sender. So not only would a seller from the USA have to meet the CPSIA standards if we are sending something internationally but we also have to abide by any import and manufacturing laws for the country we are sending to. One example that I'm familar with is sending jewelry to the UK - if I describe and sell something to a customer in the UK as containing sterling silver I must have either a assay certificate or registered with the UK a hallmark that can be traced back to the the holder of the assay certificate stating the purity level of the silver. And if the item is futher described as being for a child of a certain ages there are other safety laws in place that I must meet, many are dependant on the exact age described like choking hazards have a different age group and definition of minimum sizes allowed in UK than in the USA. This is all on top of any USA laws & regulations that I must meet as a seller of jewelry based in the USA.

[happywhosits]

I see that the CPSA has their own Etsy user ID now. Wonder if they will post in the forums? Or if they will respond to a convo?

Eileen...

[knitwit4ever]

They do??

[Former_Member]

happywhosits,
I don't know if they would respond to an ETSY convo but for the next 30 days they are taking open questioning at the e-mail address below concerning specific questions on the CPISA.
HTAquestions @ cpsc . gov (copyn-paste remove spaces before e-mailing)

[knitwit4ever]

Thanks, Jewelrydesigns, for that e-mail address!

[bobbinalong]

I get so annoyed with so much of this CPSIA/government stuff. Yeah, they are going to see to it that all of the items we make and sell are safe. But . . . how about the many, many kids whose Moms go to the fabric stores and make their kids clothes? How will these children be protected? The content could be dangerous and I promise you that they will use buttons and zippers - and they won't be tested. And I think about all the kids in this country who are doing without due to financial hardships that will be affected.

This all goes back to Congress. I cannot believe any thought was given to this overall situation. If there are "stays" on items, aren't the kids living with this "danger" for another period of time? I think the manufacturers of the zippers and paint, etc. should be the ones giving the government the info on how dangerous their items are, not us backtracking to find info from them, or rushing to a lab.

[Former_Member]

Sadly, governments don't always think about the full ramifications of something before making it a law. As an American Citizen it is my right to let them know what I think about the law, but I still have to comply with it until/if it is changed.

I don't see them changing this one so I have sent feedback hoping to at least get component testing. Since larger suppliers are more capable of spreading the cost around, and I believe if they ever firmly say they will allow the component testing then more suppliers will offer this as a service.

Or at least thats my hope.