Pacifier Clip Sellers - Are we doomed?

[Former_Member]

From my research, pacifier clips will need to be tested for CPSIA compliance. If we order supplies that are completely tested and approved by the manufacturer and have documentation...then we're on to small parts testing. I'm srambling for a solution because I have almost 75 of these babies in stock and I'm afraid to post them! However, I know that I'm not alone. Is there anyone else out there in the same boat? What have you learned about selling these?

My plan was to have a few hundred by a huge craft fair in August... Now I'm re-thinking!

FYI- I've learned from a few other threads that snaps from snap source can be used- they are already tested and compliant. I've e-mailed the company for documentation.

[Former_Member]

*groaning* I hadn't even though of small parts testing!!! I really hope someone has some amazing news!!!

[Former_Member]

Small parts testing has been around for years - just not high on crafters horizon. It is not new with CPSIA

[Former_Member]

I think there is a clause in the CPSIA documents about small parts being OK if it is part of the design. For example: hair clips are small, that's jus the way it is. Pacifiers are small, etc. You need to put a warning on your labels though. I copied my warning exactly the way it is written on clips I see in stores. It says:

WARNING: CHOKING HAZARD! SMALL PARTS. THIS IS NOT A TOY.
PLEASE SUPERVISE CHILDREN AT ALL TIMES AS SMALL PARTS MWY POSE A CHOKING HAZARD. NOT INTENDED FOR USE BY CHILDREN UNDER 3 YRS.

Since you are making pacifier clips your wording will be slightly different. Go to the store and look at how the warning is worded on them there, that's what I did.

[DandelionWishesCC]

Very interesting, marking, thinking of doing the same

[Former_Member]

PicCurcusDesigns... You found that warning on a pacifier clip packaging??? That's so odd saying it's not intended for children UNDER 3 *LOL* isn't it for all 3 year old (almost all) should be weaned off of a pacifier by then!!! Talk about odd!

[Former_Member]

Noooo...LOL
I found that warning on hair clips...
So, I used the same warning on the hair clips I make...
I suggested that Kadensmommy go to the store and see what kind of warning is on the pacifier clips there and word hers in the same way...

[Former_Member]

i did post a warning on my pacifier clips... however, would it be acceptable to put the warning in your policies? or should each listing that has smaller parts be noted seperately?

[Former_Member]

he warning needs to be on the actual clip with the CPSIA labels/tags.

[Former_Member]

I pulled mine. I had at least 50, I have NO clue what I will be doing with them :(
Im pretty bummed

[Former_Member]

Hiya,
From the little that I've read about the CPSIA stuff I understand it's mostly to do with children and safety....

Anyway... if I'm right - I've used the suspender type clips that you are talking about and stuck things on to them and am selling them at the markets as sarong clips (it's summer here), they could also be used as book marker clips and stationary clips

Hope that makes you feel less bummed :-)

[Former_Member]

Soooo.... I refuse to give up. Here is a response that I received from a testing lab that specializes in small parts/lead testing. I've also e-mailed the CPSIA and some vendors that I buy from.

This may be a breakthrough!

Hello Jennifer:



Thank you for contacting our lab to inquiry about our services. Yes, the CPSC is a very hot topic right now. As a CPSC accredited lab we are doing quite a bit of testing to help company’s ensure compliance in this area.



I took at look at your pacifier clips and you are correct, the actual clip itself does need to be test for a couple things:



1. Small Parts, Sharp Points, and Sharp Edges (Mechanical Hazards): I am checking with one of my co-workers on this – I do believe that your clip may be exempt. I should be able to confirm this for you tomorrow.



2. Lead Content Analysis: The current requirement for lead is that Children’s products must contain less than 300 ppm of lead. The main items I see that you need to test is the metal clip, snap, and paint on the fabric. I’m guessing that the manufacturing process is the same for all the clips and snaps that you use? If not, each different one really should be tested to ensure that you are below the current lead limits.



Once I gather the information about Mechanical Hazards I will be sure to put together a quote and send to you. Thanks.



Warm regards,

Crystal L. Johnson

Applied Technical Services

Chemistry Business Development

1049 Triad Court

Marietta, GA 30062



direct: 678-444-2965

fax: 770-424-6415




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From: kadensmommy33@aol.com [mailto:kadensmommy33@aol.com]
Sent: Thursday, January 28, 2010 8:12 PM
To: Crystal Johnson
Subject: Small Parts Testing Information Request




Hi Crystal,



I am a small business owner that produces handmade pacifier clips and sells them online. CPSIA compliance is a hot topic right now and I am looking into having my products tested. I am a small business owner by far and I would greatly appreciate any information you could pass along to me pertaining to pacifier clips. In researching my materials I have already determined that I meet the requirements for lead levels and other hazard requirements. My main concern is the snaps and clips themselves that are used in my product. Is it necessary to have my clips tested and labeled? If so, how does your lab conduct the testing and what is the cost? If you would like to view my product listings to get a visual of exactly what I'm using it can be found at http://www.kadensmommy33.etsy.com. Thank-you again and I look forward to hearing form you.



Sincerely,



Jennifer Rodriguez, Owner

Kady Paige Blankies

[Former_Member]

Wow thanks so much for sharing your information!

[Former_Member]

LILGIRLCA says:
Small parts testing has been around for years - just not high on crafters horizon. It is not new with CPSIA
---------------------
very true! Any toy or baby product I've seen in the stores in the last 15 years has been held to these small parts standards. I would want anything I used on my children to be held to these standards as well as standards for lead any other toxins.... whether they were made by a big or small company :)

[thecrochetloft]

I think parents/adults of children/babies should take responsibity on what is safe and not. All you have to do is WATCH Your babies/children. Use some common sense here.

[Former_Member]

thecrochetloft
thecrochetloft says:
I think parents/adults of children/babies should take responsibity on what is safe and not. All you have to do is WATCH Your babies/children. Use some common sense here.
--------------------
... so you are driving in the car with your baby in the back, rear facing as per the law. The purpose of a binky holder/pacifier clip in this case is to keep said pacifier from falling on the floor of the car when you can't reach it (because you are in the front seat driving!). I'm sorry but I want that clip to damn well be checked for safety and I don't care who made it. It is the purpose of the devise to be used to hold the binky when you can't!

And I want anything my children use to be checked for lead and cadmium and the whole nine yards. We hold big companies responsible for making items to a quality standard and i think if we want to be running a business, not a hobby, we have to be held to the same standard.

I'm sorry but it is this school of thought that makes me very leery of buying for my children on Etsy which is shame because there are many reputable business owner here who comply. However, because they are not allowed to advertise that they have complied (i wish they could) I never know if I am a getting a responsible manufacturer who is doing the right thing or someone who is disgusted with the need to make sure their items are safe and so have tried to find every way possible to skirt the law.

And so I find myself only buying for me here... which is a shame because there are great kids shops here

Sadly, this school of thought casts a bit of a shadow on all of them for me because there are so few who shops speak out against this "seller should not be responsible for what they make" mentality and instead say, "yeah we WANT to do the right thing to make sure children are safe" .

When a do hit a shop who a is safety conscious and is doing it because they feel it is their responsibility to make a safe, quality product... well I make sure I remember their name for shopping :)

[thecrochetloft]

i only sell for adults

[Former_Member]

newhopebeading - You are absolutely right that there are a lot of irresponsible shops here on ETSY that do sell lead laced children's jewelry, baby headbands dripping with beads that can easily be pulled off. But I think that more often than not the shops are aware of possible risks and take measures to ensure the safety of their products. I doubt that the Chinese sweat shops double stitch their stuffed animals the way that I do on my blankets.

If you see adorable children's items on ETSY there's no rule stopping you from contacting the seller directly to see how their shops comply with current laws.

[Former_Member]

newhopebeading - You are absolutely right that there are a lot of irresponsible shops here on ETSY that do sell lead laced children's jewelry, baby headbands dripping with beads that can easily be pulled off. But I think that more often than not the shops are aware of possible risks and take measures to ensure the safety of their products. I doubt that the Chinese sweat shops double stitch their stuffed animals the way that I do on my blankets.

If you see adorable children's items on ETSY there's no rule stopping you from contacting the seller directly to see how their shops comply with current laws.
-------------------------------------------

and I would contact them to check before I bought :) ...but when I see somethings it just leaves a bad taste in my mouth in general...

You say:
"But I think that more often than not the shops are aware of possible risks and take measures to ensure the safety of their products. "

But that is just what galls me...it is their job to know, they are running a business. And many, many, many do know. When I hear statements like "oh parents just need to use common sense" or "we used to sit in the front seat of the car when we were kids (I did too" I'm just think, "What year did they drop in from?" LOL When people say this they know it is the law and they just don't like it because they may not be able to do what they have done in the past.

I also know they know it is the law when I see huge disclaimers in shops with swarovski crystals for infants (can you say choking AND lead hazard) saying something to the effect of:

"The buyer agrees not to hold the seller responsible in the event of an injury to a child yada yada yada"

It doesn't work that way folks!!!You can't make something that is not legal to make and then think that by saying you are not responsible you will be legally ok... someone gave these folks some bad legal advice!

I also think Etsy has hidden behind the cloak of "we are just a venue and are not responsible" but I can tell you from my experience in a "former life" as a writing consultant helping pharmaceutical companies rewrite their packaging after they lost law suites for unclear packaging, that Etsy may be in for a rude awakening too should the shit ever hit the fan and some child really be hurt by a glaringly non compliant product. Usually when the shit hits the fan on these things it flies far and wide.
Don't shoot the messenger .. it is just the reality of the corporate world and, like it or not, if you are making things for kids you are playing in that arena.

[Former_Member]

thecrochetloft
thecrochetloft says:
i only sell for adults
----------------------
Me too because I know the things I make are not safe or appropriate for children :)

[Former_Member]

lol BBforbabies I thought you said NOT aware LOL... I need to go to sleep :) you get my point... just drives me crazy sometimes LOL

[Former_Member]

This is why I have been keeping my products without any small parts or metal at all so far. I'm a fairly new shop but used to design a children's private label for a major department store. I can say that the factories that this company used in other countries absolutely worked hard to make sure that everything passed safety testing. Because 1-it was extremely expensive for them (the factory paid the cost NOT my company) and they were required to re-test until it passed or not ship the product if it failed and 2- it was very time consuming.

There are pull tests that items like beads and buttons must pass where a prong yanks on them and they must withstand pressure. (I think 15 pounds of it.) Anything that is snall enough to fit in the top end of a toilet paper roll is considered a small part.

My main question here--knowing what I know about how expensive testing is and that an item of each color and type must be tested--is how can a home based businesses afford this? And, how do you ensure that your manufacturing is consistent in order to duplicate the exact same results each time? Especially when sewing by hand? I would like to start adding clothing to my shop but am nervous adding zippers and buttons because of the testing. Thanks!