The CPSC apparently published a new definition of "Children's Products" last Tuesday in the Federal Register to no fanfare whatsoever. This little morsel clocks in at only nine pages but it goes in the heap with the other 579 unread pages of miscellania spewed out by the CPSC in the last month. Everyone - quit your jobs so you can keep reading this stuff!
Ah, but the fun doesn't end there. Try to find this document on the vaunted CPSC website. It's not under "What's Hot?" and it wasn't mentioned in a press release. Until last week, even finding the definition of "Children's Product" on the site involved quite a bit of hunting and pecking. They remedied that by creating a new category under "CPSIA by Topic" but who would know it's there? You have to sense its presence and then go find it. This is "Where's Waldo?", CPSC-style.
And the final "kicker" - the definition changed from the last publication of this rule on March 19. Since that time, there has been a Commission hearing and much industry chit-chat over the original definition approved by the CPSC Legal Department. Supposedly, this (unread) new definition reflects changes that I am told I will like. The CPSC Legal Department approved this new and revised definition, too. And the conformed or redlined copy for me to read? Nowhere to be found.
What a lovely way to spend my time. Reading rules, digesting rules, commenting on rules, rereading rules, trying to figure out what's changed, reviewing my last analysis, connecting all the dots, reworking our internal processes again and again and again . . . .
This is the CPSC's full employment plan. They may be able to solve the unemployment problem all by themselves! Thanks for everything, guys.
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3 comments:
Wow -- Let us know if you find a mark-up with the changes. This is insane! My favorite part is fighting with suppliers, distributors and (now) licensors about what consitutes a "children's product"? We have have a different view. Thanks again for all that you do.
Oh yeah, that CPSC statement clears up *so* much. I have two words for them: HELLO KITTY. I would love for them to "clarify" for me whether a pink women's T-shirt in size X-Small with a Hello Kitty logo on it is a children's item. It's in a color "commonly associated with childhood," in a size "that would not be comfortable for the average adult" (given that the average adult woman is about a size 14), and it bears a cartoon image that "contribute[s] to its attractiveness to children 12 years of age or younger"... and it would make an excellent Christmas gift for both my sister-in-law and my 12 year old daughter.
"Commonly associated with childhood" you say? What in the HECK does that mean in today's society? We've got little girls running around in matching outfits with mom (and mom's not looking like she's four!), little "corporate" outfits (yes, children wear black as much as pink and blue these days!), all manner of fake tattoos, oh, and let's not forget the thong underwear - uhhh - I don't mean to be rude, but, basically, you name it, CHILDREN are wearing it. So - it's anybody's guess what is and is not a product "commonly associated with childhood." So...perhaps it would be far more sensible simply to ban...EVERYTHING ON THE PLANET (that would save a LOT of time in the reading of the convoluted rules dept., now wouldn't it?)!
But, then, they don't really care about the children with this little obstacle course of a law. NAH! As long as it has honest, loving and hard-working parents like us out chasing our tails instead of hiring and producing products that are perfectly safe, as we ALL know...!!
Ah, well...Americans voted for change. I guess big government is their idea of a good time... *sigh*
P.S.
Oh, and on the size issue, one could argue that the Hello Kitty shirt would be quite comfortable as a bra for the kind of woman that this administration might already be well on its way to regulating (i.e. one who really should "share the wealth" - after all, we should ALL be "equal" and any uncommonly large endowment of such a woman could be considered a natural form of currency, right? - sorry, couldn't resist the snarky remark, as I'm sure you all understand, as this law has driven us all to the brink of insanity by now, eh?).
Keep up the great work Rick!
Tristan Benz
Maiden America
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