To: <puptcrit-AT-puptcrit.org>
Date: Tue, 16 Dec 2008 14:18:37 -0600
Subject: [Puptcrit] "new" rules for the CPSIA legislation


I am forwarding portions of emails that I have received pertaining to the 
new legislation that might effect those of us who build products that can be 
played with by person less than 14 years of age.  I do not pretend to know 
much about this issue.  But there are others that seem to think that we need 
to take a closer look at this.

Here is are the excerpts:
" I posted a comment re: toy regulation on the petition site. I was 
wondering
> if the new regulation law was to address imported toys only or was a 
> blanket
> law  covering everyone  and the kitchen sink including small businesses 
> here
> that produce safe soft toys for children?
>
> Anyways, About.com has some info on this area as the department of 
> consumer
> protection visited Toy Fair this year.
>
> http://collectdolls.about.com/od/dollsattoyfair2006/tp/toyfair2008trends.htm"

The response:
"it applies to everyone. That's the terrible part of it. As it
is written now there are absolutely no exceptions and it's up to the
manufacturer to do the testing (ie...it doesn't matter if the
materials one uses were tested beforehand).

So not only does it put people making art dolls/bears/etc on thin ice
but it will completely shut down all the cottage industries where
people are making Waldorf/Steiner dolls, childrens clothing,
hand-carved wooden toys, etc.

In addition to how it affects small businesses there are responsible
overseas manufacturers who have already stated they intend to stop
selling to the US after this goes into effect. I chatted with the
owner of my ex-workplace, which is now largely a high-end toy store,
and she says they will no longer be able to stock a good portion of
what they have now and all children's items, across the board (all
stores, not just there) will go up by at least 20% in price.

She was able to explain things to me a bit better. As it turns out,
all the US had to do was to match the already very strict European
guidelines and everything would have been fine. But instead the US
apparently had to 'one up' everyone and go completely overboard
creating a situation that not only will shut down thousands of little
cottage industries but result in large scale layoffs from the retail
through distributor and manufacturing levels.

Anyway, if people are concerned I encourage them to write to their
reps, even if it's just via the form letter that's been offered here
before. Petitions are all but useless as far as getting a message to
the people who can make changes; written ones are typically roundfiled
and electronic ones ignored. If you are concerned, please write!"

Another:
"I just wanted to let you know what my product manager for our doll
manufacturer responded to my question about the age situation for selling 
our
new 7" jointed "Kinder Kid" dolls.

Below is his answer to my question.  I asked about the "age 12 and
above"...but he said...well, you can read it.
I plan on following up on this and having them put all the necessary
information on our packaging and doing some research on an "independent 
safety
test lab".
I found the second paragraph quite interesting.  Seems the government 
doesn't
even know what's what....Duh! Same old same old!"

Reply:
"According to the US ASTM F963 toy safety standard, the definition of toys 
is
any plaything designed, manufactured or marketed for children under 14 years
of age. Therefore, your  "Kinder Kids" should be marketed for ages 14 and
above in order to classify them as 'collectible doll' for adults. We suggest
you to add the warning printing on the packaging, like "Choking Hazard: Not
suitable for children under 14 years". The information of the distributor
(your company) and country of origin should be included on the packaging, 
too,
to fulfill the law in US.

Since there is still a lot of things regarding the Consumer Product Safety
Improvement Act not being declared/explained clearly yet, we would suggest 
you
to contact the independent safety test lab there to clarify your
responsibility if any."

So have any one on pupcrit heard anything about all this?

Lucky Stradley
Hubbell, Nebraska

lrc-AT-gpcom.net

http://luckystradley.blogspot.com/
~~last update 11/2/2008~~

http://www.picturetrail.com/13luckyme
~~picture trail last updated 6/9/2006~~

http://community.webshots.com/user/beenlucky
I am trying this site out for listing pictures.
~~last update 7/13/2006~~

Always Lucky...well most of the time!





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