"101(a). This rule proposes a
procedure by which the Commission
will address requests for determinations
that these types of materials or products
do not and would not exceed the lead
limits. The effect of such a Commission
finding would be to relieve that material
or product from the testing requirement
of section 102 for purposes of
supporting the required certification.
If this proposal is issued in final form,
the Commission would concentrate its
efforts on evaluating those materials that
are commodity-like, are used across
industry in a number of applications,
and are subject to detailed consensus
standards related to lead content and
other pertinent properties. Given the
Commission’s resources, requests to
evaluate individual products of a single
manufacturer would be assigned a very
low priority."
This is only one statement that shows the regulatory agency applying the compliance and penalty standards for this law are engaged in the time honored tradition of making this a fair and effective law.
Until they decide who needs to comply and what needs to be tested, this law is not actionable.
This section states asks for a procedure to determine which items or materials don't need to be tested because BY NATURE they are already compliant or are believed to be due to their natural composition. Meaning they are already unlikely to contain levels of poisons unacceptable by the new standards.
The U.S. already has manufacturing standards. If you are following those, you are already covered. One law cannot stand in direct opposition to another and then not be fixed.
I recommend, however, that if your products are made using plastic beads and buttons, etc. from China that you rethink your materials in any case because you may already be out of compliance with current law.
Freedom is earned, not granted by entitlement.
You are already supposed to be in compliance with lead safety standards applied in the 1970s.
Stop the whining, wailing, and gnashing of teeth and learn the CURRENT law you are supposed to be following. Then, with the professional attitude with which you wish to be treated, let the feds know this law is written badly and needs to be carefully applied.
PROFESSIONAL, ladies. Stop acting like hysterical and hateful biddies.