Wednesday, November 11, 2009

CPSIA - My Testimony at Public Consumer Product Safety Incident Database Hearing 11-10-09

I testified at the hearing about the new public product safety incident database at the CPSC yesterday (Nov. 10, 2009). The videos of my presentation are below for your convenience, in two parts.

Please note that this is the third time I have testified in front of the CPSC about the CPSIA (lead panel, tracking labels panel, database panel). I believe that out of the 30 presenters at these hearings, I was the only operating company that stood up and gave comments, besides a ladder company at this week's hearing and a software company shamelessly trying to sell tracking label software. I cannot do this alone. You will get out of this what you put into it.

There is a great chance to make a contribution at the upcoming IMPORTANT two-day workshop on the so-called 15 Month Rule at the CPSC on December 11/12. See the CPSC notice here. We need to have some bodies at this meeting. The CPSC wants feedback from the regulated community, from real people with pain points. If we want the CPSC to work with Congress to fix the law and to implement it in as sensible a way as possible, we need to provide direct feedback. Ask yourself whether it matters that no children's product company testified about the database besides Learning Resources after you watch my presentation. It's a pretty important subject, others should have been there to defend their interests. Get involved - we need your help.

Part I (5:19)

Part II (6:20)


Anonymous said...

I think one of the reasons these are so poorly attended is the bulk of those deeply affected by the CPSIA cannot afford the time or monetary expenses (or both) to travel to DC to speak.

Expenses aside, the upcoming workshops really have me confused. I simply don't understand how the CPSC expects small business owners to step away from their shops for 2 days at the peak of the seasonal sales, many of whom handle ALL aspects of their daily business. While some will be able to, I'm sure many more would be able to attend if the workshop timing was better.

In essence, many small business owners are being asked to close shop for two days (not including travel time) and lose those sales or risk not being heard and be forced out of business. The fact that more people have NOT been present to speak should really be a red flag to the CPSC. What a sad, sad time to be a small biz affected by CPSIA.

-John Greco

jennifer said...

Wow - amazing Rick. Thank you. John is right too about traveling to DC. Not only is it THE busiest season of the year but also how many times can we repeat ourselves?

My hope is that they take the info from the workshops and use it to go back to Congress. But there is the nagging side that wonders if these workshops are to help people figure out how to comply with a bad law.

I don't want to close the open door by saying that but this needs to go both ways and I don't think the CPSC or Congress understands how widely different all of our manufacturing processes are.

Steve Hansen said...

I like what you are doing but I agree that for those more than an hour drive from DC this is really asking too much to fly back for meetings. I am sending in written comments when I can but trying to get my clients and their trade assn to do so has been an uphill battle.

Seeing the videos is good and the fact that the CPSC is posting all written comments is nice. I like written comments as they become a part of the record just like the testimony. I have asked CPSC to post transcripts instead of just hours of video (as you can review it faster and word search it) and I have asked to be a beta tester of the new on line database. Until more companies retain us (as a group preferably) to do this work we cannot do any more than we are doing now.

Steve Hansen

Anonymous said...

After watching your testimony, I went back & watched the webcast of Monday's staff meeting. I was nothing less than horrified to hear that the Commission has heard none of the cries over testing prices! Really?! Rick, I know you have itemized sample invoices a number of times, as have others. Is it really so hard for the staff to call a lab & get a quote? Or better yet, simply look at the examples people have cited?
While I am glad we seem to be getting a bit more clarity, I am now, more than ever, concerned about those who ultimately could provide the relief we need. I cannot comprehend why there is so little understanding about the processes they are requiring.

April P.

Ermengrabby said...

Where are the insurance company representatives? Why aren't they up in arms. The insurance companies are going to be paying the costs of the litigation made possible by the data base.