This is the last day to send in comments to CPSC here is mine feel free to use an facts provided
need to be sent to Sec102ComponentPartsTesting@cpsc.gov
or by fax (301) 504-0127
Please send comments if you have not
Section 102 Mandatory Third-Party Testing Of Component Parts.
I am writing to comment on Section 102
I would like to address the following in terms of textiles
* How the risk of introducing non-compliant product in the marketplace would be affected by permitting third-party testing of the component parts of a consumer product versus third-party testing of the finished consumer product.
Research that scientists have done on textiles proves that there is not a risk of introducing non-complaint products into the marketplace when products are permitted for third-party testing of the component parts. The large amount of scientific data provided to Nancy Nord at the apparel meeting prove that textiles do not need third-party testing at all and do not pose a threat to the health and safety of our children. Scientific evidence given by many scientists, at this meeting, again reiterates the same conclusion that it is unnecessary to test for materials that are proven to not contain exceeding amounts of lead. Therefore it is unnecessary for any type of third-party testing on apparel if they are manufactured exclusively from textiles.
*Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace.
The risk of allowing non-compliant consumer products, regarding products made with textiles, would not increase during the manufacturing process. If the component parts are compliant there are not any processes that would introduce any non-compliant consumer products. This statement is supported by the scientific data provided to Nancy Nord by the companies that participated in the scientific testing on apparel, such as Wal-Mart, Children’s Place, and JC Penny. I use textiles to make children’s apparel and if the fabric, elastic, and thread I am using are compliant I do not use any processes that would allow my final product to be non-compliant. The only processes used are scissors to cut the fabric, an iron, and my sewing machine. These processes would not change component parts to become non-compliant products. The companies listed above used wet lab testing and XRF guns on their already manufactured products and no exceeding amounts of lead were found. This proves that whether or not textiles are in component form or in the form of manufactured apparel they do not pose a threat to the safety of anyone.
*Whether consideration of third-party testing of component parts should be given for any particular industry groups or particular components parts or material. Explain what it is about these industries, component parts, and/or materials that make them uniquely suited to this approach.
Consideration for third-party testing of component parts should be given for textiles and apparel or products made from these textiles. It is unnecessary to test for components parts made from textiles such as fabric, elastic, yarn, and thread because scientific evidence proves that these component parts do not contain exceeding amounts of lead and are not a threat to the safety of the consumer. The Commission needs to acknowledge the scientific evidence provided about lead in textiles. Textiles and products made from textiles are uniquely suited for consideration due to the large amount of scientific evidence that supports the fact that these materials and the processes used to manufacture the materials do not threaten the safety or health of children.
I am a mother of 2 and an owner of a small home business that makes apparel for children exclusively from textiles. I am 100% for keeping our children safe from products that could be harmful to them. This Act was written with the greatest intent but has many flaws. The way it is currently written will be harmful to the economy and destroy many small businesses causing the already sickening economy to worsen. Thousands of people that make safe and nontoxic products will be affected by the Act which I am sure was not your intention. I believe that the Act should affect only products that pose a threat to the health and safety of children not products that are safe for them. The Commission needs to acknowledge the scientific evidence provided to them and make necessary adjustments so that the Act will work effectively.
