Some of you know that CPSIA Section 103, which sets forth the new rules on tracking labels, is one my most loathed sections of the new law. Yes, that's quite an honor but Section 103 deserves the derision. Today comments were due on the CPSC information request on Tracking Labels. For those of you who are interested or love a special form of punishment, I have attached my comment letter for your consideration. If you still love tracking labels after you are done reading it, let me know. I will work on you . . . .
Rick
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3 comments:
I'm still holding out hope that CPSC will use their good common sense when writing the tracking label rules. My reading of CPSIA indicates that this section gives them more latitude to make sensible rules than the sections on lead testing. I could be wrong, though; I'm not a lawyer. But I get the impression that because they've already got enough to do, CPSC will make rules on labeling that are simple for them to enforce. Specifically I predict that they will exempt a lot of products that are impractical or unnecessary to label, such as many of the ones you mentioned in your letter: small parts, commodities, and products not solely for children's use.
My sons have Legos and I cannot even begin to imagine how a tracking label could possibly be added to some of them. I really hope CPSC makes some common sense rules on this, because I don't want to have to tell him Legos aren't available in the U.S. any more. He's already mad at me because I couldn't take the risk of selling his used Nerf guns on eBay. (Not because I think they have lead, but because I'm afraid my business could be jeopardized.)
I just read this article
http://finance.yahoo.com/news/INSIDE-WASHINGTON-Rude-apf-15091434.html?.v=1
There is a head-in-the-sand congressional agenda. The last few paragraphs could have been written regarding the CPSIA, just substitute Waxman for Geithner.
Rep. Dave Camp of Michigan, the top Republican on the tax-writing House Ways and Means Committee, said Geithner has yet to respond to concerns raised by committee members.
"So far we've got the, 'If we don't address this maybe it will go away' approach," Camp said.
I believe the biggest blow for us was the "2 year stay" for the motor bike and ATVs.
They were the media grabbers. The public was on the verge of finding out what all the kicking and screaming was about.
Now that they (motorbike/ATV industry)are pacified with a two year "binkey", the rest of us cry babies can only do that - cry ourselves to sleep, behind a closed door, unattended to.
Silence is golden.
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