We recently spoke to a candidate for a customer service position here who works for a nationally-prominent brand of toys. This brand is a division of a large and well-known company, and is renowned for its high quality and expensive products. You have heard of this brand. What we were told was that they are suffering from widespread backorders owing to the CPSIA. The explanation we were given is that the factories were refusing to take risk under the new law and that the brand itself was cancelling a wide range of accessories sold with their principal products. [This brand is well-known for the nicknacks it sells to accompany its flagship products.] The accessories cannot carry off the testing costs, largely because they are low -volume items, and neither the famous brand company nor the factories will bear the new testing costs. No doubt some of the problem is also an inability to meet the demanding new standards.
The candidate did NOT tell us that these discontinued products were unsafe or had ever hurt anyone. Hmmm - no apparent issue with safety, amazing! And you thought the new law was NECESSARY to keep everyone safe. It turns out that a number of these products are found in my home and I can say from personal experience that they are of the finest quality and deserve their reputation for outstanding design and strong educational content. Shame no one will be able to buy them anymore.
Boy, Mr. Waxman has really made life better for everyone! Obviously, there's no reason to change THIS law.
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I work for an environmental testing lab and we had a client come in today requesting testing for phthalates for the batches of plastic that they produce. So I've been poking around learning more about this whole thing.
I'm curious: If all of the raw materials that go into your end products (plastics, metals, paints, etc.) undergo the required testing does that permit an end product producer to claim that their product is clean?
Because it would seem to me to be a lot simpler and smarter to add a quality control step to raw material producers than to end product manufacturers.
LabCarl, first of all, thanks for joining the discussion. You are asking logical questions. It's a shame that this law does not respond to logic. As a matter of fact, on or before November 14, the CPSC is due to put out a first draft of its rules on component testing. They have been promising to issue it since February. Take your time, guys. That rule may incorporate some of your ideas. Taken in the context of the entire law, however, those rules may not provide real relief. It's a longer subject.
As for your literal question, since the 6 or 7 illegal phthalates are additives not found in nature, the offending chemicals would only be there if you add them. Thus, if you test raw materials and find them compliant, your final product MUST be compliant. The phthalates testing standard (you can find my comment letter on the new standard in my September posts) requires testing every component. Thus, under their rules, we have no way to enjoy the logic of your suggestion.
I wish words like "simpler" and "smarter" were more relevant in the post-CPSIA world. They're not. And the really big problem is economic, not compliance with standards. Having set up rules demanding super-expensive tests to confirm that we are not lawbreakers, Congress will instead put us out of business.
I keep thinking that I should make a big order of math manipulatives and science kits that aren't likely to be available in a year. But then I get depressed over the number of children's books that are being declared hazardous. I think that maybe some crafting might ease the stress, but that reminds me of all the handcrafters who have given up on their small production lines.
Ack.
Please keep at this. I've written a couple of times to my rep and senators, but get mostly irrelevant form letters in reply. We're a military family stationed overseas, so calling them means trying after 10 at night or before 5 in the morning. Maybe pulling an all nighter is in order.
interesting what lab carl is saying. the labs seem to have the same logical response and they don't understand the testing many of us have asked them to do. sure they will make money but i had one gentleman say - are you sure about THAT? - testing THAT doesn't make any sense.
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