Sunday, November 29, 2009

CPSIA - Reaction to my Testing Guidance Comments

On November 11, I published my thoughts on the recently-announced Testing Guidance. These guidelines will be the subject of the upcoming two-day workshop at the CPSC on Dec. 10/11.

In my blogpost, I noted that children's products with paint require independent testing while painted non-children's products used in the home and around children only require a GCC, no testing. That makes NO sense to me, as explained in my blogpost.

I received a series of emails from a regular reader of this space, someone with a great deal of expertise in the CPSC and its practices. Let's just say, this person knows quite a bit more than me. Here's what my reader said in reply to this essay:

"I think the implication that children's products needed some special class of testing by someone other than the manufacturer was highly questionable to begin with. (Put another way, why should we distrust children's product manufacturers? Or in the alternative, is the risk from such products really so much higher that special safeguards were necessary? In truth, most of the serious injuries and deaths that led to recalls were because of defects and not because of non-compliance with rules that you could test for.)

. . . .

Unfortunately, there seems to be a national trend--including other agencies and state and local governments--of legislating requirements based on junk science disseminated by interest groups. This leads not only to incredible costs, or loss of product for consumers, but diverts the attention and resources of the agencies from their core mission of reducing deaths, injury, and illness. That is the ultimate irony here: that in promoting safety some of these presumably well intentioned people are in fact likely decreasing the public safety."

Score one for people that actually know what they're talking about! Couldn't say it better myself (although I have been trying for about a year).

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