The new Consumer Product Safety Improvement Act (CPSIA) set to go into effect February 10, 2009 will require all products for children to be tested for lead and other toxins. Protecting children from toxins is a noble cause, but this law is poorly written. It requires that manufacturers submit every model of their products for toxicity testing, at an average cost of $500 per test. Testing must be repeated whenever a model is changed or when a new material is incorporated into the model.
For big business, this is not a huge concern. You make a million units a month, and send a dozen or so samples out for testing. The cost of the testing is insignificant in the cash flow of millions of units.
For small manufacturers, particularly makers of traditional hand-crafted clothes, furniture, and toys, the cost of mandatory testing low-volume products is prohibitive. If your grandmother knits baby blankets to sell at the local craft market, she will be required to pay for a $500 toxicity test for each style of blanket she makes, and for each batch of yarn that she uses. If she makes and sells doll dresses at $10 apiece, she’d have to make 50 more dresses after the CPSIA goes into effect to cover the cost of one toxicity test. If she can make 30 dresses from one bolt of fabric, she’ll never recover the cost of the testing that must be repeated for each new supply of material.
The CPSIA law is backwards. It may have been written with the best intentions, but it is a knee-jerk reaction to recent tragedies caused by toxins contained (willfully added, in some cases) in high volume imported goods.
Since a product is no more toxic than the materials that went into making it, toxicity monitoring should be done at the materials supply level, not the finished product level. CPSIA should be changed to follow the model of the FDA’s organic food certification standards – if a manufacturer uses materials and processes that are certified as meeting toxicity standards, then the products made with those materials and processes should be inherently certifiable as in compliance. Manufacturers who cannot certify their supply chain to US standards should be subject to mandatory finished product testing. This removes the burden from small manufacturers to test every product if they use only certified materials and processes, but still protects the consumer in the end.
Many materials used by home crafters are already certifiable as non-toxic, such as natural and synthetic yarns, thread, most fabrics, and several species of wood. There are a variety of paints and stains for wood toys already certified non-toxic by the FDA. None of these common-sense materials that have been in use for generations are considered acceptable by the new CPSIA law.
I’ve been a home crafter of a wide variety of stuff since I was old enough to rub two sticks together. I don’t currently sell home crafted children’s products, but I certainly do not want my future crafting options (or my neighbors) to be put out of business by an outrageously shortsighted “protection” law that does nothing but protect big business from competition by home crafters and microbusinesses and destroys a cottage industry at home and abroad.
Objections and criticisms of the new CPSIA law can be voiced to the Consumer Product Safety Commission until January 20. You can reach the CPSC by email at Consumer Product Safety Commission’s Office of the Secretary, Sec102ComponentPartsTesting@cpsc.gov . Comments can be faxed to CPSC at +1 301 504-0127 or sent by postal mail to:
The Office of the Secretary,
Consumer Product Safety Commission,
Room 502, 4330 East-West Highway,
Bethesda, Maryland 20814 US.
Comments should always be captioned: ‘Section 102 Mandatory Third-Party Testing of Component Parts’
You should also write to your own congressional representatives and senators to request urgent changes in the CPSIA to save handmade crafts industry. Use the sample letter