Here are the other document submitted thus far. I have already provided you links to the written testimony of the seven witnesses and my oral testimony.
- Opening Statement of Chairman Waxman
- The Honorable Inez Tenenbaum, Chairman, Consumer Product Safety Commission,
Statement for the Record - The Honorable Nancy Nord, Commissioner, Consumer Product Safety Commission,
Statement for the Record - The Honorable Anne Northup, Commissioner, Consumer Product Safety Commission, Statement for the Record
- The Honorable Denny Rehberg, Representative, Montana At Large, Statement for the Record
- Ms. Devra Singer, Product Development Assistant, Funtastic, Houston, Texas, Statement for the Record Entitled "Call for Testimony: A Personal Account of the CPSIA’s Crippling Effects on Our Small Business"
- Mr. Sean Hilbert, President, Cobra Moto, LLC, Statement for the Record
- Mr. Ed Moreland, Vice President, Government Relations, American Motorcyclist Association, Statement for the Record
- Mr. Michael Gale, Executive Director, Fashion Jewelry Trade Association, Statement for the Record
- Economic Analysis - Handmade Toy Alliance
This is provocative reading. I hope you aren't the only ones who read it . . . .
I really like the common sense in the Nord and Northup letters. In particular, I want to draw your attention to one statement by Commissioner Northup: "Forcing a component-by-component petition for exceptions does nothing to enhance safety, and it converts the Commission from a safety oversight agency (like the FAA) into a product approval agency (like the FDA). Rather than spend most of its time and resources removing unsafe products from the market, the agency would devote its efforts to approving perfectly safe products before they go on the market. That switch would also slow the pace of consumer product innovation by increasing the cost and lead time for companies to bring new products to market—which effect itself carries negative safety ramifications." [Emphasis added]
Ms. Northup's got it totally right and you should be worried that this style of regulation makes sense to ANYONE. This is at the heart of the precautionary principle, that the government becomes your partner in making your business decisions. Frankly, I trust companies more than I trust the government, especially these days. I will take Toyota over NHTSA and David Strickland any day. The House Energy and Commerce Committee is not done with this "great" idea, either. Next up is their "reform" of the Toxic Substance Control Act. This is the new scheme of regulation of chemicals that takes all the really great and highly successful notions from our beloved CPSIA (which applies to only TWO substances, lead and phthalates) and rolls it out to more than 30,000 chemicals and all mixtures containing those chemicals. I will need to sharply increase my blood pressure medicine to even read that draft legislation. You will read more about this toxic legislation in coming weeks.
Another interesting nugget is from the HTA economic analysis:
"Total number of manufacturers potentially affected by the CPSIA in the United States 52,544***
Total number of wholesalers potentially affected by the CPSIA in the United States 125,624***
Total number of retailers potentially affected by the CPSIA in the United States 511,240***
Total number of businesses potentially affected by the CPSIA according to the NAICS 689,408***"
The analysis goes on to surmise than 5 million individual products are affected by the CPSIA. I believe that this estimate is low by a factor of ten, but that's just one man's opinion. The author then concludes that the (presumably annual) cost of traditional testing is $5.6 billion. That's a nice way to honor the memory of the child who died in Minnesota after swallowing a lead jewelry bangle, isn't it? I can't think of a better way to spend $5.6 billion annually. . . .
Can any rational person doubt the severity and breadth of the economic damage in light of these data?
Keep your eyes on this space for more testimony. More will filter in over the next couple weeks.
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2 comments:
I have a close associate who has been a dance teacher for over thirty years. She does what is customary for dance teachers and orders recital costumes, which she then distributes to her students. I fail to see how this wouldn't leave her liable for the safety of the rhinestones, glitter and sequins on every costume part from feathered headdress to bedazzled shoe.
I mentioned this over a year ago. She is a past chapter president of one of the national dance teacher associations so she asked for guidance. And heard nothing in response. I'm still waiting for the season where suddenly all the dance costumes are either oddly drab, vastly more expensive or available primarily in sizes for older dancers.
Terrific source of information and opinion.
And a lot to go through. Perhaps bottom line it to begin, for easy access by more readers, the body of the info, and then a summary at the end.
And I think the compelling argument is spending $5.6 billion per year, that is $56 billion per decade, to prevent one death.
Is this economic sense. How else is life/health valued in the justice system.
What results would this investment yied, how manyi lives saved or suffering ameliorated if put into other preventive research or action?
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