I believe that the CPSIA legislation as it is written needs serious changes and/or amendments.

Based on my reading of this legislation, the point is a good one, but implementation of this "feel good" law could devastate small and micro businesses.

From what I understand, all end users must test all components they use in products they sell for children under the age of 12 years old. Many micro and home business owners produce one of a kind and small runs of products to be distributed to targeted markets. Most of the tests are expensive and some are destructive. Many of the components they use are inherently lead and phthalate free.

On it's face this law seems reasonable. We ALL want our children to be protected. However, when one looks closer one will see that this is a nightmare of expensive, duplicate testing of products that should already comply before these products hit the distribution chain.

As a specific example, a micro business of a husband and wife who use commercially available yarn, ribbon, wood and paint to make home decor items for children's rooms would soon have to test those products even though those products contain no lead or phthalates. Why should the overly burdensome requirement of duplicate testings be put on end users?

Since many micro businesses already produce safe toys and other products in direct response to dangerous imports from China and India it seems that this legislation needs to target large manufacturers and importers, not end users of components. Those manufacturers and importers should be responsible for compliance BEFORE their products hit the distribution chain in the US.

As a further example, if one company makes yarn and that yarn is distributed to craft stores such as Michael's or Hobby Lobby why should the 10,000 end users each be responsible for testing that yarn when yarn already contains no lead or phthalates.

Honestly, this law is poorly written and needs to be amended to make sense in the real world.

Even libraries and schools are concerned because the language of this law seems to indicate that books would need to be tested. That is completely unreasonable.

Thrift stores and places like Goodwill Industries would also be adversely affected. Many families rely on aftermarket outlets like thrift stores to purchase gently used clothes and toys. The loss of that resource could be devastating for families.

With so many already losing their jobs, it seems to be counterproductive to put small and micro and home businesses out of business because of a poorly written law which should have been aimed directly at manufacturers and importers.

By the time products reach the distribution chain they should already comply and end users should be able to use those products in good faith.

Thank you
- by samiam iamsam