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  1. sally smith

    i'm glad that i found this website. on monday morning when i go to work, i want other fellow emlpoyees to know about thie website.i have already stated my opinion at this site and i hope that it will have a positive affect.

    Suggested by sally smith on 01/24/2009 @ 04:30PM PT

  2. Jillette Henson

    This law is great in only one way!  To prevent lead and phalates from being in kids products.  This is a great idea. 

    This law is absolutely hiddeous in so many other ways.  Why not start with a label law and let the consumers choose what they want to buy.  In this time of financial struggle, the last thing that we want to do is put MORE small businesses out of business.  This will be VERY BAD for the economy.  Also many people are turning to second hand childrens retailers to provide warm clothing and shoes for their families that they would otherwise not be able to afford.  The way the law is written, these businesses would have to close and Goodwill, Salvation Army and other smaller thrift stores would have to close this portion of their stores.  This past Christmas, I had to, for the first time ever, buy my kids presents at the Goodwill.  I found some great toys and some nice clothes.  My kids are young so they didn't even notice.  Christmas was saved!

    My main concern lies with home businesses that create special one of a kind items such as knit hats and mittens, handmade clothes and toys, all of these businesses posted to the right of this screen will be lost forever if something isn't done to change the law!

    Many of these business owners are single moms just trying to make ends meet.  This would mean more homelessness, more poverty, more hunger, more food stamps, more welfare, more pain.  Less creativity, less happiness, less money, less food on the table, less healthcare for kids of these business owners.

    Needless to say the impact would be very extreme in a very negative way.  Please change this ridiculous law! 

    Suggested by Jillette Henson on 01/23/2009 @ 09:30AM PT

  3. Jon Christopher

    How to fix the CPSIA?

    As a concerned parent of two, I want my children to be safe above almost all else. 

    It seems clear that CPSIA is not only failing to accomplish this, but is burdening product producers with a disproportionate amount of attention to tests which solve problems contributing a much smaller percentage of harm compared to other issues. An analogy might be to require every shipment of every food product sold to undergo extensive salmonella testing because of an outbreak due to Jalapeños from Mexico. Do we now force testing on every shipment of every batch of salt or pepper?

    The focus of CPSIA - particularly regarding this discussion, is the intention to solve known issues with chemicals in children’s products. Thus far, it does not address the many other child-safety product issues which are contained within the range of other standards such as ASTM (USA), BS (UK), EN (Europe), etc.

    The requirement of CPSIA is so far reaching on a few narrow issues as to be disproportionate.
    What are all these producers and retailers complaining about?
    According my understanding of the CPSIA, every material in every child product must be tested for lead and phthalates. This testing cost totals approximately $400 per instance. A stuffed teddy bear for example, might consist of an outer fabric in three colors (brown, white feet, black nose), thread, filling, eyes. In this case, 6 materials will total $2400 for tests for a single model. In order to perform these tests, which require destructive testing of the final product, at least a dozen will be required, perhaps hundreds if the thread is actually tested according to the requirements (which need a certain quantity of material taken from the final article to be tested properly.) In another example, phthalates, which are primarily used to make PVC softer and gained notoriety due to use in soft plastic "jelly" feel teethers, or in soft plastic dolls, are now a required test for all materials including materials that traditionally have never used any hazardous phthalates.
    Using the above example, if a producer has 10 models of teddy bear, all of the above tests would need to be repeated, even if all models use identical materials! Component testing (such as testing the material or thread separately from the final product) is not allowed. This means that the materials used in the construction of an article cannot be approved separately from the final article. All tests must be performed using final end products and the test for a material in one product cannot be used as evidence for the exact same material in another product.
    What effect will this have?
    If you are the producer of small crafted wooden cars, which consist of a painted block of wood, two metal rods for axels, and wood wheels, you will be constrained to limit yourself to one model, if you can afford that! Depending on the colors, sizes, or shapes you decide to make, you could be facing thousands of dollars of tests for each car (hint: you can have any color you want, as long as it's black.) You'll need to remove any details such as painted headlights, windows, or other features, as each color will increase your testing costs for every model.
    Even large producers are not immune. If you offer children’s chairs with dozens of pad colors and patterns so that parents can match their decor, testing costs can range in the 10's of thousands or more. …An electronic toy for a 10 year old? Do you know how many materials are in there? Good luck with testing!
    The testing costs are high, and required for every material including materials that have never had lead problems or phthalate problems. If I make 10 different wooden cars from one block of material, what is the logic that suggests I must test each of those pieces of wood separately?  
    Some suggested solutions:
    1. I disagree with the notion that small producers should be exempt from keeping my child safe. However, given that their limitations proportionally limit the reach of the potential harm, it does not make sense to irrationally damage small producers. (Even large producers were small producers at the beginning. The impact of creating this costly barrier to entry for small businesses will not only kill small business, but also those which through innovation and entrepreneurship would be our future large businesses.) It makes sense to dictate that the small businesses must limit the lead and phthalate content by using approved materials such as those with specifications which limit such content, and moderate expensive testing requirements at the product level. It is easier for a raw material producer to specify limitations of chemicals used in producing a raw material. They can then spec that batch of material for child use. Also, it is more productive for them to test as they could test a batch of metal used to make a million zippers, whereas with CPSIA each teddy bear maker must test each zipper on each batch of every model (even if the zippers are identical in every way. And because there is so little metal in a zipper, a producer would have to provide dozens of toys so the laboratory could gather enough material to properly do the test.) Those using or supplying their own natural or organic materials could issue a statement such as "no lead or phthalates were added in the production and supply of this material." Do not disproportionately constrain small producers which often are the innovators. Today, these are people creating educational products, using eco friendly sustainable materials, safer organically produced materials, etc. Moderate requirements to the reach of the potential harm.
    2. Inaccessible materials should be required to limit lead and phthalate where they can cause harm, but requirements loosened when such harm is beyond reasonable accessibility guidelines (such as non-accessible wiring inside of an electronic toy.) Moderate requirements to the reachable potential harm.
    3. Where testing is required, only known base materials to cause harm should require testing. There are certain materials which contribute a vast majority of the known issues, such as PVC and phthalates, and lead in paint. If testing is required, it makes sense to limit it to materials where those chemicals are used instead of also requiring tests on materials where they have never been problematic. Moderate requirements to the materials which cause potential harm.
    4. Where materials are accessible, the requirement should be proportional to use. For example, products intended to go in a child’s mouth should have a higher burden than a mobile which hangs from the ceiling. As all parents know, all accessible materials to an infant go in their mouth including everything in your kitchen cabinets. However, articles intended to be in use or proximity of a child (say 30% or more of the time, such as a crib) might require testing, whereas the producer of a child’s piano might require that the accessible materials are specified by his suppliers to be within permissible limits of lead/phthalate. Moderate requirements to usage and exposure to potential harm.
    5. Other onerous requirements should be mitigated with reasonableness. For example, labeling requirements where the label overcomes the product should have alternative methods available for meeting the intention of the requirement. Where tests are needed for materials, certainly there can be a limit as to which materials. A large piece of fabric, might make sense. Thread used in stitching? A small piece of velcro used to fasten? Hard to rationalize... Moderate requirements around reasonableness and the likelihood of potential harm.
    Virtually every country in the world has a general requirement that "products sold must be safe for their intended user". For example, I'm quite certain that using a high concentration of radioactive Uranium is not allowed in children’s toys. However, CPSIA does not require a radioactive test for every material on every product. The sense of reasonableness, and occurrence of problems should cause us to solve actual problems instead of throwing blanket requirements on every producer and every material.
    Fear is a powerful motivator, and few topics can motivate parents more than discussing their own child’s safety. Blanket requirements however, can increase risk, sometimes dramatically due to the diversion of expenditures and attention from other real issues. Any business has limited time or profit based on the amount consumers are willing to spend and the costs of doing business. Requirements such as CPSIA will limit consumer choices, and only the largest and most profitable will be able to comply as it is currently enacted. Even the largest will need to severely restrict their product range and offering. Few tears will be shed (at least by parents) if Barbie looses a few outfits in her lineup. But can you say the same when you cannot buy a musical instrument, or craft, or hobby supplies for your child’s interests and development? If a business contributes a disproportionate amount of unnecessary attention to lead/phthalates, there is a portion of that attention that is not focusing on stability against tip-over, breakage of crib slats, small part choke hazards, or other safety issues with much higher incidence of harm.
    CPSIA needs to be reformed to solve the problems it seeks to address without putting blinders on and hoping an onerous blanket solution will address product safety issues.

    Suggested by Jon Christopher on 01/23/2009 @ 09:05AM PT

  4. Cecilia Leibovitz

    I just learned that Amy Goodman will be speaking about her new book "Standing up to the Madness" (re individuals standing up to the government through grassroots movements and prevailing) through "The Big Read" at Essex High School, in Vermont on January 24. I sent the following story idea through the Democracy Now website. Does anyone have a direct Democracy Now connection/phone number so that I can follow up?Democracy Now needs to hear from all of us. Please contact them as well, and feel free to borrow from my text.URGENT: American's Children's Libraries in Danger

    I have been working through the Handmade Toy Alliance (HTA) since late November to fight for changes to the Consumer Product Safety Improvement Act (CPSIA), a law that is poised to shut down thousands of small American crafters and businesses. This law takes effect on February 10, 2009--just 17 days from now.

    The CPSIA was crafted in response to the lead toy recalls of 2007 (involving Hasbro, Mattel etc.). It mandates that *all* makers of children's items, test those items for lead at costs that can run into the thousands of dollars per item. This includes everything from books, to toys, to clothing, to bicycles, to public school education materials.Businesses such as mine, who offer ethically produced items as an alternative to mass produced, profit driven merchandise, are in danger of extinction. Furthermore, the executive director of the American Library Association has stated that unless books are exempted from the law, she will be forced to ask all American libraries to ban children under age 12, or remove all children's books from the library shelves on February 10th.For more information on this extremely time sensitive issue, I urge
    you to take a look at my Change.org.  initiative here-
    http://www.change.org/ideas/view/save_handmade_toys_from_the_cpsia
    and the latest ALA information here-
    http://www.wo.ala.org/districtdispatch/?p=1573

    Suggested by Cecilia Leibovitz on 01/23/2009 @ 07:19AM PT

  5. Childhood Boutique

    I called Chairman Waxman's office a few minutes ago. The number listed is actually the number to the Committee of Energy and Commerce. The operator can connect you directly to Chairman Waxman's office thought. The secretary asked for my message and I told her basicly what was written in Carol's post... that this legislation should be reconsidered and made more specific to protect small business owners and home based businesses. She told me that it's not likely that businesses like mine, a small boutique selling custom children's clothing, will be forced to close its doors Feb. 10th. She said that Chairman Waxman has sent out a letter today recommending that there be some changes in the form of product exemptions... for example.

    She said that there would not likely be changes for certain segments of business such as home based or small businesses, but that certain products may be granted exemptions.

    The response to this letter is expected within the next few days. She recommended that I continue to read www.energycommerce.house.gov  to keep up to date on the legislation.

    One other interesting note... she told me that the legislation itself would not likely be changed, but that recommendations for exemption will be made by the CPSIA agengy themselves.

    I urge everyone reading this to call and be informed. Call your local congressman as well.

    -Kelly Loubet
    Owner, Childhood Boutique
    Scottsdale, Az

    Suggested by Childhood Boutique on 01/22/2009 @ 12:06PM PT

  6. I wanted to clarify that I meant to contact your state's representatives to Congress.

    Suggested by R N on 01/21/2009 @ 08:57PM PT

  7. Carol Daly

    WE HAVE MADE PROGRESS!-- Today, the Committee on Energy and Commerce sent a letter to its Chairman, Henry Waxman, strongly urging that the beginning date for this legislation be delayed until such time as the law can be reviewed and refined.  It is now in the hands of Henry Waxman to make that decision -- help him make his decision . . . make a phone call to his office and let him know WHY this legislation should be reconsidered as written, making it more specific and protective of the small and home-based American business owner.  His office telephone number is 202 225-2927You may read the letter by clicking on this link to a pdf file.  The link is quite long, and came to me broken, so may break up in this transmission as well.  If so, just make sure you copy everything from the "http" all the way through "pdf" . . . and paste it into your browser window.  I think you'll find the letter very hopeful!!

    http://republicans.energycommerce.house.gov/Media/File/News/1.21.09_CPSIA_Letter_to_Henry_%20Waxman.pdf




    Suggested by Carol Daly on 01/21/2009 @ 08:18PM PT

  8. I believe, and I have heard others say this as well, that the only viable solution right now is to request for Congress to put a stay on the CPSIA so that there will be adequate time to address and fix all the many issues that have come up regarding small to medium businesses.  There also needs to be sufficient time to create clear rules and regulations regarding testing of products, especially for the small to medium businesses, so that people will actually know the law and be able to comply with reasonable standards.  There are only three weeks before February 10th, so I encourage everyone to contact your state representatives today! 

    Suggested by R N on 01/21/2009 @ 09:55AM PT

  9. Pam Crowson

    Here is something else I plan to do. I am getting all my information collected and added up for taxes purposes for the 2008 tax year. I plan to show them where I spent my money. Suppliers, USPS, UPS, FEDEX, Ebay fees, Etsy fees, etc... and this will be just ONE PERSON.  Not only will taking my work away cause my loss of income, it will also cause Ebay and Etsy tremendous losses on their income from sellers like myself, which in turn could lead to MORE layoffs (Ebay laid off back in the fall already), but money losses to the USPS and my shipping firms I use, and a major one would be my suppliers. All the hundreds and hundreds of dollars I spent this year on Ribbon alone!!!!  And I am just ONE person. I am not finished totaling my income/expenses for last year yet, but when I am I plan to send these totals off to those who can see how far reaching this law really is! 

    Just another idea ;)

    Pam
    www.rebekahsbowtique.com
       

    Suggested by Pam Crowson on 01/20/2009 @ 01:38PM PT

  10. Candice Mangum

    I hadn't seen the etsy "compliant" campaign.  It cracks me up and scares me all at once, but it's sure to get some attention from buyers!

    I do have to stress again, that we really need to not look at a "Made In the USA" approach.  I believe a straight certification from the supplier is most expedient.  But many fabric stores import their fabrics (especially wools and bamboo), stuffing, and yarn, from other countries (if I recall correctly, Jo-Ann Fabrics imports from Italy.)  According to Jo-Ann Fabrics, these items have all been tested, but still, they are not "Made In America." 

    To try to impose a "US only" approach will cause unnecessary hardship on many small businesses who depend on imported raw and processed materials - many from places like the EU, who have stricter regulations than the US!  Just from my familiarity with Jo-Ann Fabric's flannel selection (I use it myself) a quick look at a place like Etsy yields many many other buyers of the same material.

    Suggested by Candice Mangum on 01/20/2009 @ 01:33PM PT

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