Monday, September 20, 2010

CPSIA - REMINDER, Comments due on 100 ppm soon!

767 days have passed since ANY Democrat in Congress did ANYTHING to help us on the CPSIA. There are only 43 days left until Election Day.

I wanted to remind you that comments are due on the latest effort of your government and your CPSC to put us all out of business, namely the reduction of the lead standard to 100 ppm. I have previously analyzed this call for comments in this space and have nothing new to add.

As I noted in my last post, the call for comments rules out most sensible replies to the proposed reduction such as
  • The cost is unaffordable and will render our products too expensive to produce
  • The new limit is suitable for mass market products but will make specialty market products impossible to manufacture (too bad for us, I guess).
  • The new limit is needlessly disruptive.
  • The new limit substantially increases our liability exposure.
  • The new limit creates yet more ways for the CPSC to interfere with our businesses.
  • The new limit creates more externalities and randomness in our business results (another "profit prevention" initiative).
  • The new limit will have absolutely no impact on human health but will have tremendous implications for business health.

All irrelevant.

If you can't come up with anything to say to save your business under this provision, I still encourage you to send in a comment. Perhaps if we drown them with comments about the unfairness to small business, they might at least pause for a moment before sending us into business oblivion. You can always just thank them for putting you out of business. A "thank you" always goes a long way, just like your Mom used to tell you.

Yeah, thanks CPSC. It's been a great ride . . . .

1 comment:

Chris said...

These comments are already due? They can't even tell us what this applies to yet! And judging from the last few rules they put out for comment, I seriously doubt that anything anybody says will make one shred of difference.

In case you missed it, the meeting for the pending decisional matter Final Interpretive Rule - Definition of Children's Product has been postponed once again. Apparently they have more important things to do.