What might help A LOT.....

[Former_Member]

Since I don't think this law will be repealed any time soon, if at all, I think.....
1. Component testing should be allowed. The CPSIA says that when you applique a lead-free fabric to a lead-free cotton tshirt, lead may suddenly appear in this finished product. I know it sounds stupid, but that is exactly why component testing isn't allowed as of right now. Apparently, the merger of these lead-free items might produce lead. I'm not a chemist, but something doesn't jive here.
2. Allow XRF testing to be sufficient. From many, many people I have talked to, this method is very accurate and can be done at a relatively low cost. I have a quote from a company located here in town that has quoted me $400.00 for about an hour, and however many products he can test in that time. Apparently, you can scan quite a few things in an hour. He recently XRF tested over 1000 items in an 8-hour day at a local gift shop. I know that's true because I called the shop and asked how the whole thing went. So, if component testing isn't allowed, at least this method wouldn't destroy the one-of-a-kind items or the micro batches we produce.
3. In line with the component testing, let us use the certificates from our suppliers. I know this doesn't help the people who buy fabrics, etc. from the big craft stores (many have said they won't be providing GCC's). This would mean not having to test every single finished product, but instead you can use the XRF testing to test only those components that you can't get certificates for. I know this won't help everybody or every product, but at least we wouldn't have to have every single product tested-only the ones we can't get certificates for.
I am painfully aware of the many, many more things that need to be done, but right now, I don't have a lot of confidence in this latest Rush/Waxman letter to the CPSC.
Obviously, lots more to say...please comment!!

[Former_Member]

nothing? not a single comment? interesting....

[Former_Member]

Just for semantics and clarity: remember that component testing is prohibitively expensive, as the cost burden is still borne by the manufacturer (us). Suppliers' certificates are the way to go (your #3).

There's another thread that asks why can't the CPSC do what the FDA does with GRAS (generally regarded as safe).

[fabricfanatic007]

You said they tested (XRF) over 1000 items in an 8 hr day? Isn't that still $3200 (based on the $400/hr rate you mentioned)? Ack! That sounds super steep to me =0 I'm still holding out for reforms/repeals. I just can't imagine getting rid of all the inventory I have on my store shelves (MANY one of a kind items). It'd break the business... no doubt. :(

[Dannielle]

If XRF testing would be acceptable (not just until Aug...totally not worth it for me to invest in it for a couple months), I could stay in business.

I was thinking it would be cost prohibitive, too. But the more I think about it, the more I think I could make it work if it were a long term solution.

I'd have to rework how I do things. I'd probably create for a month then have it all tested at once.

I'd have to raise prices a little but if I work in large batches I could make it work, I think.

[Dannielle]

adding...my large batches would be a boxful of one-of-a-kind dolls. So I'm not using the word "batch" in the same way the CPSC uses it.

[Former_Member]

fabricfanatic007....The $400 for the hour was actually $275 for the XRF equipment rental for the day and $125 per hour of scanning. So, the cost for those 8 hours + XRF equiment rental was actually $1275.00, not $3200. I think this is a very reasonable price compared to some of the other outrageous quotes I've seen especially if it is shared with another business.

Dannielle...Yes, when I say that I believe XRF testing should be allowed, I mean as a long term solution, not just until August. Like you said, you would have to rework how you do things, but it would certainly be a whole lot easier and more economical than having every single finished product, every size, colorway, etc. tested.

I don't think Congress is going to start from scratch and redo this law. I also don't think they will make the changes we need to make this thing more safe and effective.
Not trying to be pessimistic, but I think we all need to anticipate that some sort of testing/regulation will be a part of our future business operations. I'm only suggesting that these changes might make the bite of this whole thing hurt a little less.

[fabricfanatic007]

Got it :) So as I add inventory on a daily basis (which I do)... am I supposed to test it... AS it's added to the shelves in my store? I'm thinking "yes." Geeze. lol!

[Dannielle]

FabricFanatic...see, this is what I'm thinking...

I usually add new stock every 1-3 days...whatever I've made in that time.

If I were to make it work I'd have to take a month off from listing and just create. Then get everything I made that month tested. The next month I'll start creating a new boxload of dolls to test at the end of the month. During that month I'll list the tested dolls...a few each day...as I would have in the past.

It would work. I'd just need a month off to get the system rolling.

[Former_Member]

fabricfanatic007Got it :) So as I add inventory on a daily basis (which I do)... am I supposed to test it... AS it's added to the shelves in my store? I'm thinking "yes." Geeze. lol!

If you are the store owner, it would be the company/people that sell to you that should have the product tested and supply you with a certificate of compliance?... I think. Unless of course you are talking about products already purchased. Again... I think!!!

[Dannielle]

ah, don't mind me...just realized you're talking about a brick&mortar store vs an etsy shop.

[Former_Member]

That would help "some", for those who are already making enough to afford the $400 an hour. Me? That would wipe out about a quarter of my total yearly profits. Still not a good option for me.

The ONLY thing that will help at all, is if they regulate the cost of testing based on affordability - kind of like they do at the chiropractor's office, if your insurance doesn't cover it.

But this can only be done after a lot of FACTUAL RESEARCH - no more "guessing games".

[Dannielle]

That's just one quoted price, though. There's someone who has posted here who does testing (see allthenumber's post on XRF testing) who is charging $100/hr.

*If* it's possible to test 100 items in an hour (not sure on that) then it's only $1/item. Most of us could get away with raising prices $1, yes?

[Former_Member]

It wouldn't be a dollar per item though... it would be more like a dollar per COMPONENT. You'd have to check each fabric, each thread, each button, zipper, snap, interfacing, elastic, etc. ONE of my garments has at minimum, 6 components. And they are all OOAK (made from recycled materials...). That could get very expensive, very quickly.

[Former_Member]

even it XRF testing is $5/pop my items usually have 3 or more materials. so that's $15 and then postage two and from the tester....

My products will double or triple in price.
NO one is going to buy one of my plushies at $50+.... sorry
just can't afford it.

[Former_Member]

I also have a HUGE problem with the requirements for testing on every "batch". Most of us, if we make batches at all, do it in very small amounts (less than 10). I happen to only print on demand, rather than keep a lot of inventory around that may not sell, so since I replace my ink cartridges at least every week, I'd probably have to test every time I sold a children's print (if I find they are not excepted). I currently sell these prints for $15 each. If I sell 5 of them a month - all different - I'd have to up the price to at least $115 EACH to cover my expenses. NOT a reasonable solution AT ALL for someone in my position.

[Dannielle]

Are you sure XRF is per component? I mean, I guess it depends on the area covered in the test "ray" or whatever, right? If more than one component gets scanned at once, it counts, right? Maybe?

My dolls are little...to test "per component" they'd have to get totally taken apart. If they'd have to be taken apart to be tested, why would I have to put the parts together into a finished product first? Or is that just to make me even more crazy??

I plan to contact a local lab (from the CPSC's list of approved labs) Monday to ask about testing options. These are questions I'll ask since I don't have a clue lol.

[Dannielle]

it would make a BIG difference to me, obviously. I manage to fit 10-16 different components into 2.5" of doll. I could raise prices a dollar or two. No way could I raise them $10-20 per doll.

[AuntCindysAttic]

From my understanding, it's component testing, not whole doll testing. Something I read said that a kid died from eating a lead charm from a shoe. If they tested the shoe as a whole, it likely would have passed, even if the charm wouldn't have. That's why they require component testing. It is definitely cost prohibitive for me. :( When I buy fabric, I buy enough for 7 little purses & then will have a bit left over that I could use in a quilt. So, my batch of 7 would still be a huge expense. I usually don't make them all at once, either. Ugh.