Michael Miller fabrics safe

[Former_Member]

I just received this email:

http://www.michaelmillerfabrics.com//Email/0000_HTML_CLIENT_EMAIL/cpsia.letter.results.pdf

[TheTinyFig]

You still need a GCC. A statement won't do you any good.

[Former_Member]

From what I understand at this point even if the supplies have been tested , you have to retest once you make something out of it. But thanks for sharing , so many ppl are freaking out right now and any and all info is helpful at this point. I fear many of us will be out of business.

[Former_Member]

Isn't the GCC the last two pages?

[TheTinyFig]

Looks like their test results to me? I'm not sure what a GCC looks like though.

[Former_Member]

lalaspequenos says: Isn't the GCC the last two pages?

If it is, it would be the GCC for their fabric, not the product you make with it. As the law stands, you would still have to test it in your final prodcut.

[boodybabies]

Here is a link to one of the mommybloggers (bless you all) which explains the GCC:
http://buggalove.blogspot.com/2009/01/cpsia-what-is-general-conformity.html

[Former_Member]

Thanks Boody,
So according to the buggalove blog the GCC means that "You make it yourself based on the information and data you get from your "reasonable testing program" "

So can I use the Miller fabric tests as a reasonable testing program for that component until Aug?

[Former_Member]

Thanks so much, lalaspequenos! Have you already added that to this thread compiling suppliers who test?
http://www.etsy.com/forums_thread.php?thread_id=6006981&page=11

As to the GCC's, I think it was Buggalove who tipped folks off to the CPSC's website at some point for a sample GCC. I searched and here's the one I found:

http://www.cpsc.gov/ABOUT/Cpsia/faq/elecertfaq.pdf

The trickiest part about this period between February 10th and the August deadline is that "reasonable testing program" has not been defined by the CPSC. I think most sellers feel that getting the testing results from suppliers to use in the GCC should be accepted as a "reasonable testing program" until the August deadline when third-party, digestive testing is required.

[Former_Member]

As for the issue of whether or not we're required to test the finished product at THIS phase (b/c we definitely have to after the August deadline), here's what the CPSC FAQ's says:

"Children’s products manufactured after February 10, 2009, when the lead limit may not exceed 600 ppm, will need a general conformity certification based on a test of the product or a reasonable testing program for products after that date."

Also:

"On what does my certification have to be based?
The general conformity certification must be based on a test of each product or a reasonable testing program."

It's that "or" in there that makes it unclear, but also seems to leave it open to a legitimate defense that a "reasonable" testing program would include getting the test results from all your supplies to put into your GCC for each individual product. Yes, there's no question about in after that August cut-off that we no longer have that option, but the writing is vague for this phase.

[Former_Member]

May the Lord have mercy if this idiotic law doesn't get repealed! ... *waits until 2/10 to figure out what to do*

[Former_Member]

No joke, HazelnutDesigns! I'm right there with you!

[Former_Member]

THANK YOU lalas!

[Former_Member]

I agree Hazelnut. I feel like I'm swimming in a sea of idiots with our government.

[Former_Member]

I'm so glad that I am not the only one who feels lost about what to do. I just cannot wrap my brain around this. I've read all about it and I comprehend the rules, but it's just stupid.