1. Your letters are hitting the mark. PLEASE keep the letters on the Stay coming. The CPSC continues to believe that it can fix the law piece-by-piece with more rules and interpretations, and is ignoring the practical problems that you face. They MUST delay the lifting of the Stay until they either FINISH THE JOB or get Congress to restore sanity to safety administration. I am on record that they cannot fix this WITHOUT a change in the law. You need to make yourself heard.
2. Here's a shocker - there will be people at the workshop who are AGAINST component testing. For one, in a recent public meeting, YKK (a well-known zipper maker) has come out strongly against component testing on the grounds that it will encourage counterfeiting. To be frank, I have not seen or heard a comprehensive statement of their position and look forward to hearing it. My gut tells me that their principal concern is competition, not counterfeiting. Component testing is extremely beneficial to small businesses. Arguably, Big Business is only minimally affected by the CPSIA, at least in comparison to the impossible burdens borne by small business. Be prepared to argue your case.
3. The CPSC doesn't want to see their workshop derailed by a complaint session about the many problems with the law. I think that's a fair request. In any event, find the opportunity to stress the burdens that you bear and try to get them to focus on the challenges posed by COMPLEXITY. This issue is not something that the CPSC wants to fully acknowledge and seems bent on building more and more complexity into their system to compensate for the many, many flaws in the law. They need to know that it's a real factor that will have a serious impact on the effectiveness of this safety regime. Likewise, it is a killer in the marketplace, especially in relations with dealers and retailers.
4. Finally, don't forget to ask yourself today about SAFETY. This workshop is about RULES divorced from reality. As we argue endlessly about how many angels can dance on the head of a pin, ask yourself and remind the CPSC how much all of this has to do with SAFETY. We are getting lost in the weeds as we try to build a set of rules to accommodate a terrible and defective law. If we allow the fantasy to go forward that the new rules are somehow about safety (e.g., is a zipper tested by components or as a completed product safer one way or the other? OR are zippers known to be safe already?!), we are going to actually help them build the structure to kill us. We don't want to do that!
I will try to report from the workshop as time permits.
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