Well, I've been saying it for a long time....until you can truly be heard and speak in such a way that the standard Joe or Jane can understand, they will NOT hear you, nor will they take time out of their precious day to try to understand you. See this blog entry: Uninformed
I admit it. I'm still trying to decipher the whole deal, but I have the basics down, after reading that entire document.
This is why I love my friends and family - they won't even take MY word for it. Even after breaking it down, a few came back and said "I checked Snopes and they said......" or I listen to C. Howard's show, and he said everything was fine, and I believe them." It makes us all look harder and find all sorts of interesting pieces of information.
In their quest for fast information they failed to note that Snopes referenced only thrift shops and blindly passed over the liability the wording still holding them accountable and they also failed to see a little blurb indicating this legislation was not written with small business in mind on the other website.....that's right, it wasn't, but that does not simply mean it does not apply to small businesses! lol.
It is yet another uninformed (which really isn't meant as an insult because it can admittedly be hard to be informed) viewpoint. This is what is truly being battled....those having a blind faith in their government to do what is right to protect them and just believing the shared synopsis, and in this case it is, "We'll protect your children from tainted products." only. They are also running on limited time, so if you don't provide the links and routes for them to read themselves, they probably won't.
You should never publicly criticize someone or another group unless you've done your homework and are sure you have the full facts.
At any rate, I posted a comment. Not sure if it will appear there or not, as it remains an uncommented-upon blog entry currently.
I basically indicated that 2 of the many issues are the unnecessary testing of products known to not contain lead or pose a threat such as those in the natural products sector and the redundant testing of components unnecessarily raising consumer prices, just for a start. If the poster wants to pursue it further, they should; if not, then they won't. I clarified that it is NOT about American small businesses wishing harm to our children in lieu of making a buck.
Showing posts with label CPSIA. Show all posts
Showing posts with label CPSIA. Show all posts
Jan 29, 2009
Jan 26, 2009
Food for Thought....Reap What You Sow?
We were discussing consumerism and companies who design products to fail quickly so that you have to buy another sooner.....
In discussing it with my husband, he shared with me an article he read in National Geographic about where all of our electronic waste goes. I wanted to read it. I found it easily enough on a search of my own. Click the link and be sure to click the other links within this article, such as the Photo Gallery link.
While I don't buy the latest cell phone models, printers, monitors, etc. because I am the woman who should be embarrassed of her outdated equipment that she begrudgingly finally had to buy for business. I have bought 1 new of each when the other failed. I tried to find out how to properly dispose of these items. I decided to allow my toddler to use the old cell as a toy. I still have the old printer; I just need to find someone to fix it so that I can pass it down to my kids. The 4 giant monitors I had, however, was another story.
Those monitors and 2 CPUs had been sitting in my storage room for years. I thought I might be able to use them as servers someday...a technology I'm not all that in the know about. One computer was in my ownership alone for 15 years and was one that I had received free when a business I worked for shut down. I had worked with that computer for 3 years prior to it becoming my own personal computer. It had also suffered a motherboard failure at the hand of lightning and I paid $1000 to get a new one installed (that's how much that cost way back then). It started out as a Compaq 486 but turned into something else entirely with new disc drives, 3.5", etc. throughout its lifetime. The monitor went on it and my brother-in-law gave me one of his, but even larger...so large I could barely pick it up. When I needed access to speedy internet access, my cousin gave me his brother's old computer (he had passed away), and the monitor that came with it; this one was in my possession for about 7 years and was about 10 years old. I can't even tell you where the 4th monitor came from. I remember one starting to blink, so someone had to have given it to me.
Now we fast-forward to where my home business is now successful and requires more--I order a new computer with 2 monitors with a dual-monitor function to help my production and I now needed something to accommodate CDs and all of the new equipment I need that requires more from my computer, as well as the serial ports versus the USB ports. lol. I now needed fancy sound cards, etc. Then I needed to be mobile so I needed a laptop so I could take a vacation and still work, as I don't get any days off. I've had the desktop for 8 years now and the laptop now for 7.
Last year it was time to get the old equipment out of the storage room, "clean house" so to speak. I contacted my garbage service, as I had heard it was illegal to dispose of computer monitors in the trash. They told me that they weren't supposed to pick them up, but that if I put them in the trash, they would take them. I asked them what they did with them, and they told me that they put them in the landfill. In amazement, I shared that I was told that was what we should be trying NOT to do. Some conversation followed with a giggle--what else can you do? She said "You'd be amazed at what we take that we aren't supposed to." I called my City to see if they had a hazardous material pickup date for these things - they didn't know anything. I called computer repair shops too. I can't remember who else I called that day, but many, many sources. I was somehow referred to a charitable organization. Success! They said they DO take used monitors. I dropped a "Well, at least someone else can actually use them." comment out of relief my search had finally ended, but he replied with "Oh no, we don't actually resell them or donate them, we give them to XXXX. I think they have a recycling program or something." Oh brother. I opted for saving them until our Spring Cleanup Day where people drive around and pick through the items on the curb and find treasure in another woman's trash. I kept the cords in the house and put a sign up indicating they should ring the bell for the cords, as some people cut cords off of the items you put out there. Someone took one of the CPUs that I had removed the hard drive from, but that was it. I finally took the remainder to the place accepting donated monitors. I figured I did my best.
Finding and reading this article in the midst of trying to keep us with what CPSIA really means.....it suddenly hits me.....Do We Reap What We Sow? It implies that at least some of the lead in items from overseas is from our electronic waste that made it back to us in the form of products -- could it have been a material from one of MY monitors poisoning a child in ANY country? I pray that it was not.
It makes me wonder whether it is the country as a whole that reaps what it sows....afterall, they just keep buying newer and better models for items there is really nothing wrong with, no? They allowed this practice of dumping toxic electronics in other countries, no? At least some manufacturers believe it is better to build products planning them to expire and to be irrelevant more quickly so we "need" to replace them sooner. What is the price of convenience? Was it not convenient enough the model prior? Are we, even those who believe the CPSIA law is nothing but a good thing, actually hypocrites? Is it okay to destroy other countries and entire villages, their residents, their children--just not our own?
This actually makes me relieved to know that those very children and adults who are literally killing themselves stripping the barely valuable components to fetch a dollar to feed themselves and their families probably don't have a TV or exposure to the hypocrisy of what we are worrying about right now.
I absolutely hate it when this usually proud American feels like an ashamed American. We've apparently been shipping toxic products by the tens of millions a year to other countries and now we're all upset about it being done to us when some of those products complete a cycle we've actually started - it started with us and is ending with us, and now we're mad about it? I'll keep fighting the battle to stop unnecessary and redundant testing, although now with a little voice in the back of my head.
I know this doesn't apply to every toxic product in question here, but it still bothers me to think that even one child has suffered because of what WE have allowed to happen elsewhere. I am angry it happened to "us," but I'm also angry it has happened to others as well. I believe that needs to stop as well.
In discussing it with my husband, he shared with me an article he read in National Geographic about where all of our electronic waste goes. I wanted to read it. I found it easily enough on a search of my own. Click the link and be sure to click the other links within this article, such as the Photo Gallery link.
While I don't buy the latest cell phone models, printers, monitors, etc. because I am the woman who should be embarrassed of her outdated equipment that she begrudgingly finally had to buy for business. I have bought 1 new of each when the other failed. I tried to find out how to properly dispose of these items. I decided to allow my toddler to use the old cell as a toy. I still have the old printer; I just need to find someone to fix it so that I can pass it down to my kids. The 4 giant monitors I had, however, was another story.
Those monitors and 2 CPUs had been sitting in my storage room for years. I thought I might be able to use them as servers someday...a technology I'm not all that in the know about. One computer was in my ownership alone for 15 years and was one that I had received free when a business I worked for shut down. I had worked with that computer for 3 years prior to it becoming my own personal computer. It had also suffered a motherboard failure at the hand of lightning and I paid $1000 to get a new one installed (that's how much that cost way back then). It started out as a Compaq 486 but turned into something else entirely with new disc drives, 3.5", etc. throughout its lifetime. The monitor went on it and my brother-in-law gave me one of his, but even larger...so large I could barely pick it up. When I needed access to speedy internet access, my cousin gave me his brother's old computer (he had passed away), and the monitor that came with it; this one was in my possession for about 7 years and was about 10 years old. I can't even tell you where the 4th monitor came from. I remember one starting to blink, so someone had to have given it to me.
Now we fast-forward to where my home business is now successful and requires more--I order a new computer with 2 monitors with a dual-monitor function to help my production and I now needed something to accommodate CDs and all of the new equipment I need that requires more from my computer, as well as the serial ports versus the USB ports. lol. I now needed fancy sound cards, etc. Then I needed to be mobile so I needed a laptop so I could take a vacation and still work, as I don't get any days off. I've had the desktop for 8 years now and the laptop now for 7.
Last year it was time to get the old equipment out of the storage room, "clean house" so to speak. I contacted my garbage service, as I had heard it was illegal to dispose of computer monitors in the trash. They told me that they weren't supposed to pick them up, but that if I put them in the trash, they would take them. I asked them what they did with them, and they told me that they put them in the landfill. In amazement, I shared that I was told that was what we should be trying NOT to do. Some conversation followed with a giggle--what else can you do? She said "You'd be amazed at what we take that we aren't supposed to." I called my City to see if they had a hazardous material pickup date for these things - they didn't know anything. I called computer repair shops too. I can't remember who else I called that day, but many, many sources. I was somehow referred to a charitable organization. Success! They said they DO take used monitors. I dropped a "Well, at least someone else can actually use them." comment out of relief my search had finally ended, but he replied with "Oh no, we don't actually resell them or donate them, we give them to XXXX. I think they have a recycling program or something." Oh brother. I opted for saving them until our Spring Cleanup Day where people drive around and pick through the items on the curb and find treasure in another woman's trash. I kept the cords in the house and put a sign up indicating they should ring the bell for the cords, as some people cut cords off of the items you put out there. Someone took one of the CPUs that I had removed the hard drive from, but that was it. I finally took the remainder to the place accepting donated monitors. I figured I did my best.
Finding and reading this article in the midst of trying to keep us with what CPSIA really means.....it suddenly hits me.....Do We Reap What We Sow? It implies that at least some of the lead in items from overseas is from our electronic waste that made it back to us in the form of products -- could it have been a material from one of MY monitors poisoning a child in ANY country? I pray that it was not.
It makes me wonder whether it is the country as a whole that reaps what it sows....afterall, they just keep buying newer and better models for items there is really nothing wrong with, no? They allowed this practice of dumping toxic electronics in other countries, no? At least some manufacturers believe it is better to build products planning them to expire and to be irrelevant more quickly so we "need" to replace them sooner. What is the price of convenience? Was it not convenient enough the model prior? Are we, even those who believe the CPSIA law is nothing but a good thing, actually hypocrites? Is it okay to destroy other countries and entire villages, their residents, their children--just not our own?
This actually makes me relieved to know that those very children and adults who are literally killing themselves stripping the barely valuable components to fetch a dollar to feed themselves and their families probably don't have a TV or exposure to the hypocrisy of what we are worrying about right now.
I absolutely hate it when this usually proud American feels like an ashamed American. We've apparently been shipping toxic products by the tens of millions a year to other countries and now we're all upset about it being done to us when some of those products complete a cycle we've actually started - it started with us and is ending with us, and now we're mad about it? I'll keep fighting the battle to stop unnecessary and redundant testing, although now with a little voice in the back of my head.
I know this doesn't apply to every toxic product in question here, but it still bothers me to think that even one child has suffered because of what WE have allowed to happen elsewhere. I am angry it happened to "us," but I'm also angry it has happened to others as well. I believe that needs to stop as well.
Jan 22, 2009
Lead or Not?- Item in Question #2
I bought these for my 3-year-old as a stocking stuffer for Christmas this year. I got it out of the $1 bin at my local Target without a second thought.
What do you think? Lead threat or not? Should this item be tested or not? I think children's eating utensils should be tested.
Questionable Item #1
Jan 19, 2009
CPSIA Touching Many...Racquet Girls Plans to Adapt to Sustain Business
Mary Diaz of Racquet Girls recently indicated that while the original vision for her company was to offer hip, fashionable, and modernized athletic wear geared for children, tweens, and teens, she now fully expects to have to include a disclaimer clarifying her garments are not intended for children under 12.
With her products not being intended for use by children 12 and under, she will have to focus on the appropriate sizes for teens 13 and older instead.
Mary's fabrics are basic 100% cotton and cotton/spandex blends. Her surface decorations include embroidery, screenprinting (from a professional screenprinter), and fabric appliques. She had originally planned to use some heatseal rhinestones, but dropped those designs in anticipation of the additional costs the CPSIA testing requirements impose. If testing requirements for her athletic fashions designed for adults are more reasonable, she may be able to implement her plans for using further embellishments.
Mary said, "I've also considered altering Racquet Girls should CPSIA go forward. My size range right now is for 7- to 14-year-olds, but I may have to change it to 13-18 and specifically state that the products are not meant for children 12 and under.
Looks like mothers with children 12 and younger are going to be having a VERY difficult time finding boutique-type clothing and toys for their children. Only the big-box retailers will be able to afford the testing."
Mary has followed and is also following all available avenues to bring reform as well, i.e. petitions, sending letters, etc.
If you decide for yourself that this product poses no threat to your child(ren), regardless of their ages, please read my post discussing what you can do!
My non-tennis-playing 9-year-old daughter just looked over my shoulder and announced she wanted this outfit. She is 9, which means this outfit will be deemed hazardous to her health next month unless subjected to extensive testing for each color and print found within this garment--the threads, the labels, the cotton/spandex (green, navy, white, and polka-dotted pieces), and the decorative screenprinted design.
Make sure to visit www.RacquetGirls.com to see all of the adorable outfits they have to offer!
Lead or Not?
Soooo, now that there has been all this talk of lead and phthalate testing, I find myself pinpointing questionable items as I look at all things and try to imagine the extensive testing on the items already in my possession (Legos and Transformers--all those shapes and parts--I can't even imagine how much more expensive these items will become, as they are already expensive. I don't even know for certain if these items will require testing or to what degree....I just keep analyzing everything. Will every single shape and color of Lego need testing, or would it just be based on which batch of resin & color is used rather than every single shape?)
Today, my 3-year-old found a necklace that was given to my oldest last year, who at that time was 10. It was given to him by his great grandmother. No special story behind it really, and I had never really given it any thought. They frequently hand over little items they think the kids will enjoy. My 3-year-old likes to wear it whenever he comes across it. He doesn't put it in his mouth though either, and my 11-year-old doesn't really wear it. He likes to hang it from his mirror in his bedroom in a pack-rat sort of way.
Personally, I don't think ANYthing with lead in it, other than that contained in electronic devices, should be found in ANYthing for either me or for my kids. Shouldn't we fight against putting it into ANY jewelry, paints, etc. at all?
What do you think? Toss it and bum out the 11-year-old, as I'm inclined to believe this thing is loaded with lead. It could really only be made out of copper, but it sure feels heavy to me. Do I want to go purchase a lead-testing kit that is rumored to be inaccurate? Nope. Is it safe to keep around because I watch my kids, i.e. I don't just leave it on my 3-year-old unsupervised simply because it has a small part on it. Is there a risk from touching it? Thoughts, comments? Personally, I think there should be NO lead in jewelry, for adults or children, and I think children's jewelry in particular should be tested.
Jan 14, 2009
Act to Bring Reform to the Negative Effects of the CPSIA Lead-Testing Regulations
I'm asking that as many people as possible circulate the following information via e-mail ASAP to reach as many people as possible. Thanks for your help if you are so inclined.
This is important to note: The following information is in no way a call to reform the current Consumer Product Safety Information Act legislation in a way that promotes harm to, encourages harm to, or ignores those who do in fact harm our children by way of lead-tainted or phthalate-tainted products. I no more wish harm to my children in any way, shape, or form via exposure to harmful products than you do. Once you are sure you have an understanding of this, please continue reading on, and if you find yourself in agreement, I ask that you cut/copy and paste the letter at the end or write your own covering any of the below topics that concern you personally and send it onto your congressman/woman and senators to help save small business from the CPSIA. Please also take a moment to read the “What You Can Do” section.
Raise your hand if you thought “Well, it’s about time someone protected our kids from this idiocy!”—Me raising my hand. As usual, there’s much more to it.
February 10, 2009, is being called National Bankruptcy Day. Companies with hundreds of thousands and even millions of dollars worth of inventory will see their current inventory become illegal on February 10, 2009. They cannot possibly afford testing of all current inventory. Stores are also prohibited from selling any untested goods in their existing inventory as well. See: National Bankruptcy Day
The current CPSIA wording is too broad and will actually hinder American-based innovation and close small businesses due to testing and retesting on the same product components at various stages of the manufacturing process, the destruction of one-of-a-kind items, unnecessary testing on items unlikely to contain lead in the first place, and due to the exorbitant costs involved with testing multi-component items.
This country desperately needs to promote and encourage innovation and small business rather than making it difficult. Small business drives our economy. Many of these small businesses’ products were created as THE healthy and safe alternative that the business owners wished to have available to their own children, an alternative to the very products that were harmful. The legislation, as it is currently worded, throws countless more businesses “under the bus” equating to many more economic casualties than presently.
The CPSIA is a piece of legislature drawn up quickly in response to the lead-tainted products infiltrating our borders from China last year. As with most quickly-formed Acts, the big picture and the ripple effects of enacting this law will result in undesirable and far-reaching negative consequences for ALL of us—those with and withOUT children – US as CONSUMERS and our economy.
The Consumer Product Safety Commission, which has good reason to be content right now, does not seem to be worried about the consequences to business or the ripple effects. Their budget was increased from $80 million in FY ‘08 to an authorization of $118 million in FY ’10, and the Commission is to receive $20 million to modernize its testing laboratory according to my Congressman’s website here.
An example of a product that will become illegal to sell on February 10, 2009, as innocuous as they are (as this would require 2 tests, costing around $300-$500 total, for the 2 different color yarns)from Curious-workmanship.com
Even the rubber stamps I bought for each of my kids, ages 11, 9, and 3, last summer to participate in a community scavenger hunt to stamp their books as we founds clues will be outlawed. As if I would dare dream of leaving a 3-year-old alone with an ink-covered stamp, let alone long enough for him to eat one.
Below is a list of the reasons revisions are needed to this piece of legislation, while still protecting our children by way of certification:
IT IS COST PROHIBITIVE TO RECEIVE COMPLIANCE TESTING FOR SMALL BUSINESS:
Is this a matter of someone trying to buck the system by whining about not being able to afford testing? Is it a case of Americans wanting perfection until it is expected of them as business owners, and at a cost? Is it a matter of American businesses being unconcerned about lead exposure in relation to our children? No, not at all.
“Small business drives the American economy,” said Dr. Chad Moutray, Chief Economist for the Office of Advocacy. “Main Street provides the jobs and spurs our economic growth. American entrepreneurs are creative and productive, and these numbers prove it.” and “Small business drives the U.S. economy by providing jobs for over half of the private workforce.” and “Office of Advocacy funded data and research shows that small businesses represent 99.7 percent of all firms, they create more than half of the private non-farm gross domestic product, and they create 60 to 80 percent of the net new jobs.” For a full statement view this article from the Small Business Administration. Many small businesses are entrepreneurial work-at-home crafters, artisans offering one-of-a-kind/unique items from clothing to furniture, specialty manufacturers, low volume specialty items for the blind, deaf, and disabled markets, and specialty educational items, as well as entrepreneurial innovators bringing new products to market.
Most of these companies purchase the components that they will assemble into a product of their own from other manufacturers who are required to test their goods for compliance before they sell them to the manufacturer. The manufacturer forming a product made from 5 other components, even those components that have already passed compliance testing, will be required to test them again, although individually now all at their expense. If a decorative T-shirt comes in 3 sizes – 1 of each size, and all of its components, must be tested. If they offered something as simple as towels in multiple patterns or multiple colors, each pattern and each color on the same item must be tested, as would the thread, any appliques, dyes used, etc. These companies tend to have smaller manufacturing runs of goods, with each run requiring testing, per component. One-of-a-kind products cannot be tested without being destroyed—it’s a one-of-a-kind product! Work-at-home parents with products to offer such as cloth diapers, crafters, artisans, and entrepreneurs who are inventing things such as new infant towels or burp cloths, as well as many other child-related products, planning on manufacturing on their own to get a start to pay for larger manufacturing runs will now not be able to afford testing whatsoever to get that start.
Part 1 Video
Part 2 Video
Part 3 Video
POSSIBLE SOLUTION TO REDUNDANT TESTING ON THE SAME COMPONENTS OF A PRODUCT ALREADY DEEMED COMPLIANT ONCE AT THE FIRST POINT OF SALE: Allow the use of certified components and component testing without retesting. Set the system up to promote compliance rather than assuming all products are tainted by dividing products that are compliant and those that are not. In the case of the business who wants to source products to make decorative T-shirts or Jeans with decorative threads, colors, dyes, snaps, zippers, patches, or appliques, allow them to easily choose a manufacturer who offers either “Certified Lead Free” materials or items identified as “Meets CPSIA Lead Standards.” (Did you know zipper pulls and metal snaps are already tested for lead? Why test them again just because someone used them on their product when that person made it a point to buy that component already meeting or exceeding the standards?) This manufacturer can then label their product accordingly, indicating which components meet or exceed the standards. Same for the paint that the furniture manufacturer chooses—why should they retest a paint that has already been through and passed the certification process?
The risk of making the end manufacturer responsible for proving their end product is compliant is that not all source manufacturers will be honest about whether or not their component is compliant – how is the end manufacturer supposed to know without testing PRIOR to assembling their product in the first place? Will they be able to get that $50,000 they just spent on that source material back from the supplier that turned out to in fact not be compliant? As the law is worded now, the $100,000 fines for noncompliance and federal prison terms will be directed at the end manufacturer of the end product, i.e. the wood-worker who thought he bought some compliant paint with which to paint his furniture, not the manufacturer of the sourced component, i.e. snaps, zippers, paints, dyes, or appliques.
THE “BUTTERFLY EFFECT/JOB LOSSES ACROSS THE SUPPLY CHAIN: Manufacturers of children’s products have clients, which are the retail stores, online stores, and boutiques. When they are forced to close down, their clients (the retails stores, online stores, and boutiques) will have less options for product replacement to keep their stores competitive, so they in turn may be forced to cut back or close down. The manufacturers also purchase their source materials from other manufacturers, and with fewer orders from them, prices will rise and there will be further job cuts and cut backs. This results in loss of jobs and business closures across the supply chain. These manufacturers and retailers also retain the services of accountants, web designers, advertising firms, marketing firms, public relations firms, etc.—more loss.
MORE EXPENSIVE PRODUCTS/DIMINISHED PRODUCT CHOICES/LIMITED PRODUCT AVAILABILITY: Not only will the source manufacturer who already tests their products to be CPSIA compliant have to raise their prices to cover their overhead, so will the end manufacturer utilizing those materials to form their own product, either both before and after they manufacture—once to ensure the materials they purchased are in fact compliant, but again to prove to the CPSC that each component of their product is in fact compliant—or after. This means you could possibly be looking at double to triple the overhead increase in pricing you currently pay. This does not take into account the overhead increases in the cost of doing business from higher insurance premiums to protect against the destruction of items should a mistake be made and noncompliance is the ruling, if even a mistake, the extensive legal fees involved in fighting such a battle, the $100,000 fines and possible federal prison terms involved, etc. As jobs are lost and companies cut back, prices will go up from Point A to Point B.
DIGESTIVE TESTING=DESTRUCTION: The term “digestive testing” refers to the fact that the testing process itself can destroy the very products being tested. One-of-a-kind and unique products will not survive. THE ANSWER: XRF testing should be adequate to test for lead content, a nondestructive testing process, and if the product fails this testing, then, and only then, should it be moved into the digestive testing category.
ELIMINATE OR REDUCE TESTING ON ITEMS THAT POSE NO REAL THREAT: Testing should focus on those items that usually contain lead and offer exposure hazards such as metal zipper pulls, pearl-looking or opalescent buttons, vinyl (often stabilized with lead), crystals, and paint—things that children can actually touch that infer exposure from hand-to-mouth actions or that they may actually ingest, but not items such as: wood, papers, undyed fabrics, etc., which currently also fall into the products requiring testing.
SAY GOODBYE TO CRAFT SHOWS/FAIRS: Independent crafters of items such as pageant gowns, flower girl dresses, decorative little girl outfits for dressup, books, homemade items, crafts, wall art, etc. will not be able to afford testing to prove compliance, as they sell in very small volume. It will be illegal for them to sell those items, unless they could prove the component materials they used were in fact compliant instead.
DONATIONS TO CHARITY AND SECOND-HAND SHOPS: While the CPSIA legislation was recently amended to exempt these types of resale shops and charitable organizations, they also included wording indicating these people should avoid selling any items known to contain high levels of lead or suspected items – how can they tell? How do they avoid making a VERY costly mistake? The answer to many is to go out of business entirely. The risk is too great.
ANTIQUE/TOY COLLECTORS: E-bay and collectors groups everywhere will be prohibited from selling antique items geared for children age 12 and under and antique collectible toys unless they are tested. Since testing can destroy the items…..
LIBRARIES/BOOK STORES, INCLUDING SCHOOL AND PUBLIC: Are currently attempting to get clarification as well. They will either have to scrap every book on their shelves or refuse to admit or sell to anyone under the age of 12.
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BRIEF BACKGROUND/HISTORY ON CPSC & RESTRICTIONS ON LEAD: Here’s an article indicating the U.S. Consumer Product Safety Commission made it illegal in 1978 to use any paint containing more than 0.06 percent lead for residential structures, hospitals, and children's products. – so why are we having this issue today? Due to lack of enforcement capabilities or subpar testing compliance protocols? How are they going to accommodate the huge chunk of goods requiring testing today? Is the answer to simply put most small business out of business? See: Why Add Lead Paint to Anything?
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A QUICK LOOK AT SMALL BUSINESS STATISTICS EXPANDING UPON THE ABOVE:
“Small businesses – defined by the government as having 500 or fewer workers – are a key portion of the country's commerce food chain. They account for more than 99 percent of all employer firms, according to federal statistics, pay nearly 45 percent of the country's private payroll and produce almost a third of the nation's export value.
That means when they hurt, everyone feels the pain. Closures affect communities, where friends are co-workers and customers, and the cost-cutting creates a hard-to-stop cycle. Charitable donations wilt. Storefronts sit empty. Cities and towns get less tax revenue, and have to cut their budgets. And people wind up spending even less as those who are unemployed – or those who worry they will be – trim their own budgets at the expense of other businesses, large and small.
While falling sales and the credit crunch have made headlines, the small business owners left standing are facing problems as varied as the businesses they run. Manufacturing is slowing. Layoffs are looming. Financing is hard, if not impossible, to come by. Vendors are being skittish about extending credit for inventory. Rents are rising. And profits are falling – or vanishing altogether as sales slip.”See full article here.
Article describing negative effects when small businesses fail.
WHAT CAN YOU DO:
1. Register at Change.org, wait for your confirmation e-mail, go back via the link or by copying and pasting the link into your browser and then login. Click the white Ideas link at the top right corner of the screen and then click the Top Rated Ideas link lower on the page. Choose to vote for the “Save Small Business from the CPSIA”. Hurry on this one though. Voting ends tomorrow, Thursday, January 15.
2. Write your United States Congressman and your senator and share your concerns. You can use the sample letter in #4 and tweak it to make it your own or formulate your own letter. You can locate the name, address, and telephone number for your congressman here and by typing your zip code into the “My Elected Officials” box to the left of your screen. When the results appear, you want to contact the person listed under Representative for your congress person, and the state senators are listed accordingly.
3. Contact the Consumer Product Safety Commission here backing up the changes recommended by the National Association of Manufacturers 15-page plan, which can be viewed here.
Sample: I would like to see component testing mandated at the level a manufacturer, crafter, small business, independent artisan, or entrepreneur can purchase CPSIA-compliant materials that meet or exceed the new standards rather than seeing the end-manufacturer utilizing those components have to retest them again. I do not want prices to unnecessarily rise due to redundant and unnecessary testing. I feel that one-of-a-kind items should also be eligible for XRF testing rather than digestive testing procedures, and I would like to see less resources put toward the testing of items that pose no real lead-exposure risks, such as wood, paper, and undyed fabrics.
4. Write a letter to your local paper, see sample below:
In 2007, large toy manufacturers who outsourced their production to China violated the public's trust - selling toys with dangerous lead content, toys with unsafe small parts, and toys that made kids sick.
The Congress passed the Consumer Product Safety Improvement Act (CPSIA) in 2008, which bans lead and phthalates in any item geared toward children ages 12 and under that also requires permanent labels on each item with a date and batch number. This even includes goods known to not contain lead such as paper, wood, and undyed fabrics, threads, yarns, etc. Small business cannot afford to retool equipment to accommodate this demand for multi-component items for each run.
The far-reaching impact of the new CPSIA legislation wording is so broad that it means many negative things on the horizon for us over and above simply feeling relief that our children are finally being looked after, which admittedly was my first thought, being the mother of 3 children.
Everyone needs to write their congressman and state representatives expressing that the wording be narrowed so that unnecessary testing on items known to pose no lead risk, such as wood, paper, and undyed fabrics, does not occur and so that repetitive testing does not occur.
The law deems any inventory prior to February 10, 2009, noncompliant and illegal to sell with penalties of $100,000 and makes it a federal offense. The inventories that companies and stores currently have will cost too much to test. Therefore, many businesses are already planning for their demise. February 10, 2009 is being referred to as National Bankruptcy Day.
The extremely expensive repetitive testing is going to ruin small business and put them out of business, as it will crafters, independent artisans, entrepreneurs, antique/collectible dealers, etc. It will also unnecessarily raise prices of goods for all consumers, as well as schools and disabled individuals, unnecessarily and diminish product selection. One-of-a-kind items will no longer exist, as testing will destroy them.
Small business makes up approximately 99.7% of all business, providing more than half of the nonfarm gross domestic product, and creating 60-80% of net new jobs. We need to ensure that these small businesses can buy sourced, already-compliant components, with which to make their own product by way of encouraging the SOURCE manufacturers to certify their products, i.e. either certified lead-free or certified as meeting the new standards. Forcing them to retest components of their product that have already been individually tested is wasteful and unnecessary, as the end manufacturer will have to retest every component of their item to prove THEIR compliance. For example, a decorative baby onesie will need to have the t-shirt material, the thread, decorative thread, snaps, appliques, dyes, colors, and patterns all tested, despite them all being tested for compliance upon purchase to assemble them INTO a decorative baby onesie. Should this onesie be offered in multiple colors, each color will need to be tested. Each SKU, each size/style, will need to be tested.
We need to find a way to keep our children safe while ensuring compliance in the most effective way and keeping our economy, our small businesses, thriving. Remember, almost every tainted product that prompted this legislation came from China!
This is important to note: The following information is in no way a call to reform the current Consumer Product Safety Information Act legislation in a way that promotes harm to, encourages harm to, or ignores those who do in fact harm our children by way of lead-tainted or phthalate-tainted products. I no more wish harm to my children in any way, shape, or form via exposure to harmful products than you do. Once you are sure you have an understanding of this, please continue reading on, and if you find yourself in agreement, I ask that you cut/copy and paste the letter at the end or write your own covering any of the below topics that concern you personally and send it onto your congressman/woman and senators to help save small business from the CPSIA. Please also take a moment to read the “What You Can Do” section.
Raise your hand if you thought “Well, it’s about time someone protected our kids from this idiocy!”—Me raising my hand. As usual, there’s much more to it.
February 10, 2009, is being called National Bankruptcy Day. Companies with hundreds of thousands and even millions of dollars worth of inventory will see their current inventory become illegal on February 10, 2009. They cannot possibly afford testing of all current inventory. Stores are also prohibited from selling any untested goods in their existing inventory as well. See: National Bankruptcy Day
The current CPSIA wording is too broad and will actually hinder American-based innovation and close small businesses due to testing and retesting on the same product components at various stages of the manufacturing process, the destruction of one-of-a-kind items, unnecessary testing on items unlikely to contain lead in the first place, and due to the exorbitant costs involved with testing multi-component items.
This country desperately needs to promote and encourage innovation and small business rather than making it difficult. Small business drives our economy. Many of these small businesses’ products were created as THE healthy and safe alternative that the business owners wished to have available to their own children, an alternative to the very products that were harmful. The legislation, as it is currently worded, throws countless more businesses “under the bus” equating to many more economic casualties than presently.
The CPSIA is a piece of legislature drawn up quickly in response to the lead-tainted products infiltrating our borders from China last year. As with most quickly-formed Acts, the big picture and the ripple effects of enacting this law will result in undesirable and far-reaching negative consequences for ALL of us—those with and withOUT children – US as CONSUMERS and our economy.
The Consumer Product Safety Commission, which has good reason to be content right now, does not seem to be worried about the consequences to business or the ripple effects. Their budget was increased from $80 million in FY ‘08 to an authorization of $118 million in FY ’10, and the Commission is to receive $20 million to modernize its testing laboratory according to my Congressman’s website here.
An example of a product that will become illegal to sell on February 10, 2009, as innocuous as they are (as this would require 2 tests, costing around $300-$500 total, for the 2 different color yarns)from Curious-workmanship.com
Even the rubber stamps I bought for each of my kids, ages 11, 9, and 3, last summer to participate in a community scavenger hunt to stamp their books as we founds clues will be outlawed. As if I would dare dream of leaving a 3-year-old alone with an ink-covered stamp, let alone long enough for him to eat one.
Below is a list of the reasons revisions are needed to this piece of legislation, while still protecting our children by way of certification:
IT IS COST PROHIBITIVE TO RECEIVE COMPLIANCE TESTING FOR SMALL BUSINESS:
Is this a matter of someone trying to buck the system by whining about not being able to afford testing? Is it a case of Americans wanting perfection until it is expected of them as business owners, and at a cost? Is it a matter of American businesses being unconcerned about lead exposure in relation to our children? No, not at all.
“Small business drives the American economy,” said Dr. Chad Moutray, Chief Economist for the Office of Advocacy. “Main Street provides the jobs and spurs our economic growth. American entrepreneurs are creative and productive, and these numbers prove it.” and “Small business drives the U.S. economy by providing jobs for over half of the private workforce.” and “Office of Advocacy funded data and research shows that small businesses represent 99.7 percent of all firms, they create more than half of the private non-farm gross domestic product, and they create 60 to 80 percent of the net new jobs.” For a full statement view this article from the Small Business Administration. Many small businesses are entrepreneurial work-at-home crafters, artisans offering one-of-a-kind/unique items from clothing to furniture, specialty manufacturers, low volume specialty items for the blind, deaf, and disabled markets, and specialty educational items, as well as entrepreneurial innovators bringing new products to market.
Most of these companies purchase the components that they will assemble into a product of their own from other manufacturers who are required to test their goods for compliance before they sell them to the manufacturer. The manufacturer forming a product made from 5 other components, even those components that have already passed compliance testing, will be required to test them again, although individually now all at their expense. If a decorative T-shirt comes in 3 sizes – 1 of each size, and all of its components, must be tested. If they offered something as simple as towels in multiple patterns or multiple colors, each pattern and each color on the same item must be tested, as would the thread, any appliques, dyes used, etc. These companies tend to have smaller manufacturing runs of goods, with each run requiring testing, per component. One-of-a-kind products cannot be tested without being destroyed—it’s a one-of-a-kind product! Work-at-home parents with products to offer such as cloth diapers, crafters, artisans, and entrepreneurs who are inventing things such as new infant towels or burp cloths, as well as many other child-related products, planning on manufacturing on their own to get a start to pay for larger manufacturing runs will now not be able to afford testing whatsoever to get that start.
Part 1 Video
Part 2 Video
Part 3 Video
POSSIBLE SOLUTION TO REDUNDANT TESTING ON THE SAME COMPONENTS OF A PRODUCT ALREADY DEEMED COMPLIANT ONCE AT THE FIRST POINT OF SALE: Allow the use of certified components and component testing without retesting. Set the system up to promote compliance rather than assuming all products are tainted by dividing products that are compliant and those that are not. In the case of the business who wants to source products to make decorative T-shirts or Jeans with decorative threads, colors, dyes, snaps, zippers, patches, or appliques, allow them to easily choose a manufacturer who offers either “Certified Lead Free” materials or items identified as “Meets CPSIA Lead Standards.” (Did you know zipper pulls and metal snaps are already tested for lead? Why test them again just because someone used them on their product when that person made it a point to buy that component already meeting or exceeding the standards?) This manufacturer can then label their product accordingly, indicating which components meet or exceed the standards. Same for the paint that the furniture manufacturer chooses—why should they retest a paint that has already been through and passed the certification process?
The risk of making the end manufacturer responsible for proving their end product is compliant is that not all source manufacturers will be honest about whether or not their component is compliant – how is the end manufacturer supposed to know without testing PRIOR to assembling their product in the first place? Will they be able to get that $50,000 they just spent on that source material back from the supplier that turned out to in fact not be compliant? As the law is worded now, the $100,000 fines for noncompliance and federal prison terms will be directed at the end manufacturer of the end product, i.e. the wood-worker who thought he bought some compliant paint with which to paint his furniture, not the manufacturer of the sourced component, i.e. snaps, zippers, paints, dyes, or appliques.
THE “BUTTERFLY EFFECT/JOB LOSSES ACROSS THE SUPPLY CHAIN: Manufacturers of children’s products have clients, which are the retail stores, online stores, and boutiques. When they are forced to close down, their clients (the retails stores, online stores, and boutiques) will have less options for product replacement to keep their stores competitive, so they in turn may be forced to cut back or close down. The manufacturers also purchase their source materials from other manufacturers, and with fewer orders from them, prices will rise and there will be further job cuts and cut backs. This results in loss of jobs and business closures across the supply chain. These manufacturers and retailers also retain the services of accountants, web designers, advertising firms, marketing firms, public relations firms, etc.—more loss.
MORE EXPENSIVE PRODUCTS/DIMINISHED PRODUCT CHOICES/LIMITED PRODUCT AVAILABILITY: Not only will the source manufacturer who already tests their products to be CPSIA compliant have to raise their prices to cover their overhead, so will the end manufacturer utilizing those materials to form their own product, either both before and after they manufacture—once to ensure the materials they purchased are in fact compliant, but again to prove to the CPSC that each component of their product is in fact compliant—or after. This means you could possibly be looking at double to triple the overhead increase in pricing you currently pay. This does not take into account the overhead increases in the cost of doing business from higher insurance premiums to protect against the destruction of items should a mistake be made and noncompliance is the ruling, if even a mistake, the extensive legal fees involved in fighting such a battle, the $100,000 fines and possible federal prison terms involved, etc. As jobs are lost and companies cut back, prices will go up from Point A to Point B.
DIGESTIVE TESTING=DESTRUCTION: The term “digestive testing” refers to the fact that the testing process itself can destroy the very products being tested. One-of-a-kind and unique products will not survive. THE ANSWER: XRF testing should be adequate to test for lead content, a nondestructive testing process, and if the product fails this testing, then, and only then, should it be moved into the digestive testing category.
ELIMINATE OR REDUCE TESTING ON ITEMS THAT POSE NO REAL THREAT: Testing should focus on those items that usually contain lead and offer exposure hazards such as metal zipper pulls, pearl-looking or opalescent buttons, vinyl (often stabilized with lead), crystals, and paint—things that children can actually touch that infer exposure from hand-to-mouth actions or that they may actually ingest, but not items such as: wood, papers, undyed fabrics, etc., which currently also fall into the products requiring testing.
SAY GOODBYE TO CRAFT SHOWS/FAIRS: Independent crafters of items such as pageant gowns, flower girl dresses, decorative little girl outfits for dressup, books, homemade items, crafts, wall art, etc. will not be able to afford testing to prove compliance, as they sell in very small volume. It will be illegal for them to sell those items, unless they could prove the component materials they used were in fact compliant instead.
DONATIONS TO CHARITY AND SECOND-HAND SHOPS: While the CPSIA legislation was recently amended to exempt these types of resale shops and charitable organizations, they also included wording indicating these people should avoid selling any items known to contain high levels of lead or suspected items – how can they tell? How do they avoid making a VERY costly mistake? The answer to many is to go out of business entirely. The risk is too great.
ANTIQUE/TOY COLLECTORS: E-bay and collectors groups everywhere will be prohibited from selling antique items geared for children age 12 and under and antique collectible toys unless they are tested. Since testing can destroy the items…..
LIBRARIES/BOOK STORES, INCLUDING SCHOOL AND PUBLIC: Are currently attempting to get clarification as well. They will either have to scrap every book on their shelves or refuse to admit or sell to anyone under the age of 12.
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BRIEF BACKGROUND/HISTORY ON CPSC & RESTRICTIONS ON LEAD: Here’s an article indicating the U.S. Consumer Product Safety Commission made it illegal in 1978 to use any paint containing more than 0.06 percent lead for residential structures, hospitals, and children's products. – so why are we having this issue today? Due to lack of enforcement capabilities or subpar testing compliance protocols? How are they going to accommodate the huge chunk of goods requiring testing today? Is the answer to simply put most small business out of business? See: Why Add Lead Paint to Anything?
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A QUICK LOOK AT SMALL BUSINESS STATISTICS EXPANDING UPON THE ABOVE:
“Small businesses – defined by the government as having 500 or fewer workers – are a key portion of the country's commerce food chain. They account for more than 99 percent of all employer firms, according to federal statistics, pay nearly 45 percent of the country's private payroll and produce almost a third of the nation's export value.
That means when they hurt, everyone feels the pain. Closures affect communities, where friends are co-workers and customers, and the cost-cutting creates a hard-to-stop cycle. Charitable donations wilt. Storefronts sit empty. Cities and towns get less tax revenue, and have to cut their budgets. And people wind up spending even less as those who are unemployed – or those who worry they will be – trim their own budgets at the expense of other businesses, large and small.
While falling sales and the credit crunch have made headlines, the small business owners left standing are facing problems as varied as the businesses they run. Manufacturing is slowing. Layoffs are looming. Financing is hard, if not impossible, to come by. Vendors are being skittish about extending credit for inventory. Rents are rising. And profits are falling – or vanishing altogether as sales slip.”See full article here.
Article describing negative effects when small businesses fail.
WHAT CAN YOU DO:
1. Register at Change.org, wait for your confirmation e-mail, go back via the link or by copying and pasting the link into your browser and then login. Click the white Ideas link at the top right corner of the screen and then click the Top Rated Ideas link lower on the page. Choose to vote for the “Save Small Business from the CPSIA”. Hurry on this one though. Voting ends tomorrow, Thursday, January 15.
2. Write your United States Congressman and your senator and share your concerns. You can use the sample letter in #4 and tweak it to make it your own or formulate your own letter. You can locate the name, address, and telephone number for your congressman here and by typing your zip code into the “My Elected Officials” box to the left of your screen. When the results appear, you want to contact the person listed under Representative for your congress person, and the state senators are listed accordingly.
3. Contact the Consumer Product Safety Commission here backing up the changes recommended by the National Association of Manufacturers 15-page plan, which can be viewed here.
Sample: I would like to see component testing mandated at the level a manufacturer, crafter, small business, independent artisan, or entrepreneur can purchase CPSIA-compliant materials that meet or exceed the new standards rather than seeing the end-manufacturer utilizing those components have to retest them again. I do not want prices to unnecessarily rise due to redundant and unnecessary testing. I feel that one-of-a-kind items should also be eligible for XRF testing rather than digestive testing procedures, and I would like to see less resources put toward the testing of items that pose no real lead-exposure risks, such as wood, paper, and undyed fabrics.
4. Write a letter to your local paper, see sample below:
In 2007, large toy manufacturers who outsourced their production to China violated the public's trust - selling toys with dangerous lead content, toys with unsafe small parts, and toys that made kids sick.
The Congress passed the Consumer Product Safety Improvement Act (CPSIA) in 2008, which bans lead and phthalates in any item geared toward children ages 12 and under that also requires permanent labels on each item with a date and batch number. This even includes goods known to not contain lead such as paper, wood, and undyed fabrics, threads, yarns, etc. Small business cannot afford to retool equipment to accommodate this demand for multi-component items for each run.
The far-reaching impact of the new CPSIA legislation wording is so broad that it means many negative things on the horizon for us over and above simply feeling relief that our children are finally being looked after, which admittedly was my first thought, being the mother of 3 children.
Everyone needs to write their congressman and state representatives expressing that the wording be narrowed so that unnecessary testing on items known to pose no lead risk, such as wood, paper, and undyed fabrics, does not occur and so that repetitive testing does not occur.
The law deems any inventory prior to February 10, 2009, noncompliant and illegal to sell with penalties of $100,000 and makes it a federal offense. The inventories that companies and stores currently have will cost too much to test. Therefore, many businesses are already planning for their demise. February 10, 2009 is being referred to as National Bankruptcy Day.
The extremely expensive repetitive testing is going to ruin small business and put them out of business, as it will crafters, independent artisans, entrepreneurs, antique/collectible dealers, etc. It will also unnecessarily raise prices of goods for all consumers, as well as schools and disabled individuals, unnecessarily and diminish product selection. One-of-a-kind items will no longer exist, as testing will destroy them.
Small business makes up approximately 99.7% of all business, providing more than half of the nonfarm gross domestic product, and creating 60-80% of net new jobs. We need to ensure that these small businesses can buy sourced, already-compliant components, with which to make their own product by way of encouraging the SOURCE manufacturers to certify their products, i.e. either certified lead-free or certified as meeting the new standards. Forcing them to retest components of their product that have already been individually tested is wasteful and unnecessary, as the end manufacturer will have to retest every component of their item to prove THEIR compliance. For example, a decorative baby onesie will need to have the t-shirt material, the thread, decorative thread, snaps, appliques, dyes, colors, and patterns all tested, despite them all being tested for compliance upon purchase to assemble them INTO a decorative baby onesie. Should this onesie be offered in multiple colors, each color will need to be tested. Each SKU, each size/style, will need to be tested.
We need to find a way to keep our children safe while ensuring compliance in the most effective way and keeping our economy, our small businesses, thriving. Remember, almost every tainted product that prompted this legislation came from China!
Jan 9, 2009
Save Small Business from the CPSIA!
I've been trying for weeks to find a way to formulate an informative post or e-mail that everyone can understand, everyone who believes the new CPSIA testing requirements are nothing short of awesome -- still working on it. In the meantime, for those of you who understand what it is and why you should be very afraid of it, vote! Get vocal! Find a way to make it applicable to an everyday consumer so they WANT to get involved!
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