Showing posts with label CPSIA. Show all posts
Showing posts with label CPSIA. Show all posts

Friday, July 17, 2009

A must read...

The New Atlantis has a great article on the impact of the CPSIA on books...

Here is the link: http://www.thenewatlantis.com/publications/keeping-books-safe

Thursday, July 16, 2009

Tracking Labels coming soon...

**UPDATE** the Washington Times is not a fan either -- see today's editorial...

Well, one month left until the Tracking Label provision of the CPSIA (Consumer Product Safety Improvement Act) becomes law, and yet there has been no guidance (as in ZERO) from the CPSC (Consumer Product Safety Commission) as to how companies should proceed.

Like so much else related to the CPSIA, this provision sounds good to begin with -- Products intended for children must have labels that clearly indicate to consumers the manufacturer, date and location of production, as well as lot and batch information. This is designed to make it easier to recall any tainted products.

There are lots of things wrong with the Label provision, as others have written about more clearly than I can... See:

Richard Woldenberg's posts on Tracking Lables

Wikipedia on Criticisms of the CPSIA

CPSIA Central

Overlawyered.com's piece on Tracking Labels

It is unimaginable to the Commission that the government could allow a major change to something so basic, without providing any guidance on how manufacturers are supposed to comply.

These labels are not only problems for importers from China -- it is just as big a problem for domestic companies, and along with the remarkably incoherent testing requirements is simply driving small companies out of business.

The saddest part is that none of this will make children safer. There were lots of ways to address risks to children, but in creating the CPSIA, Congress and the President (and it was President Bush who signed it), seem to have ignored every one of them in creating this law.

See the National Center for Policy Analysis for their take on the impact of this legislation. Or take a look at Overlawyered.com for their thoughts.

Fair warning, the more you read the higher the risk of spikes in blood pressure...

[...edited to include a good piece on tracking labels from Overlawyered.com...]

Tuesday, July 7, 2009

Consumer Product Safety (and the CPSIA)

Rick Woldenberg has written yet another compelling post on the impact of the Consumer Product Safety Improvement Act on his Blog.

Here is the link to today's article: http://learningresourcesinc.blogspot.com/2009/07/cpsia-how-to-solve-your-problems.html

Written in an AnswerMan format, the post highlights the contradictions and confusion surrounding the CPSIA.

Regular 108Warren Commission readers will recognize this as a familiar topic -- see my earlier post here -- and others will recognize the topic from other writings over the past few months.

For those of you who may have missed it, the Consumer Product Safety Improvement Act was passed by Congress and signed by President Bush in response to the rash of recall notices on products made in China during 2007 and 2008. It was passed in 2008, with provisions going into effect in staggered fashion throughout 2009.

This should go without saying, but 108Warren Commission is completely in favor of product safety -- particularly for children's products. Unfortunately this law does absolutely nothing to make children's products safer -- instead, because of its complexity and contradictory nature it hurts those company's that try to comply, and simply eases the way for the unscrupulous to compete with honorable companies.

The issues with this law are legion, and are better covered in other places -- see Amend the CPSIA, Overlawyered.com, CPSIA-Central, and many others...

What is particularly troubling is that despite the deep and thoughtful issues raised by the people who are affected by this law, there has been no response from Congress. The legitimate concerns are routinely ignored, or even worse, are tossed aside as carping. Even the Consumer Product Safety Commission has made it clear that the law, as written, is too restrictive, and does not allow the CPSC to use its institutional experience and expertise to actually make products safer for children.

Instead of working to resolve fundamental issues, Congress is ignoring them, and small businesses across the country are failing. Libraries and schools are restricting access to books published before 1985.

In the coming month, companies are going to be required to comply with another part of the CPSIA -- new tracking labels that identify the source factory (whether that is proprietary information or not), and batch and run information. While this sounds reasonable at first, think about how to put it into practice, and the problems start to jump out at you... Where does the label go? How large does it have to be? do I have to list my actual factory so that my competitors can go then go contact them directly? What about for small items -- how do I fit a label on something small... the list goes on and on.

And that doesn't even begin to cover the problem for folks whose business is crafting handmade items... Milagros Boutique has written a good piece on the impact: http://milagrosboutique.com/2009/07/06/imagine-no-handmade-items/.

Sadly, with just over a month to go before this provision is active, there is ZERO guidance on how businesses can comply with this law... Faced with these burdens, and in a down economy, this will push even more businesses into trouble, and will put more people out of work.

Friday, June 19, 2009

The Law of Unintended Consequenses strikes again...

This link is to a great piece in Roll Call on June 15th about the impact of the Consumer Product Safety Improvement Act (CPSIA), and the unintended consequences that this law has generated...

I have commented on this before a number of times -- the law is overreaching, under-informed, and will absolutely put a large number of small businesses out of business.

If you sell or make a product that could be marketed for use by children 12 and under, even if it is a reseller that is marketing to this group, this law applies. Not only that, but any violation is required to be reported within 24 hours, and may be criminal...

Worst of all, each state's Attorney General is now empowered to independently prosecute under this law.

Here is another link to the same piece in Roll Call...

And here is a link to another piece on CPSIA from CNN Money.

Lastly is a piece from Overlawyered.com -- a great site in general -- on the whole CPSIA debacle you can find here.