Date: Tue, 16 Dec 2008 17:29:49 -0500
To: puptcrit-AT-puptcrit.org
Subject: Re: [Puptcrit] "new" rules for the CPSIA legislation


That would be manageable.  I still think it is unfair to small toy
makers.  Do you know when the law take effect?

On Tue, Dec 16, 2008 at 5:17 PM, Michael Dowell <moodooguru-AT-gmail.com> wrote:
> Hobey,
>
> Here is the ballpark pricing I gathered from the lab I contacted.
>
> The tests you might need for Peepers might be very different from the
> tests required for plush toys.
>
> $75 each different material is a different component -- lead in
> substrates - the article itself (or what is under the coating)
> $70 per coating (for example if it's a button (or a glossy plastic
> toy) it will have a coating)
> $245 physical mechanical torque & tension ASTM F963
> $70 flammability per toy
> $85 doll's clothing
> $?? forgot to ask the price of the test for pthalates. Since peepers
> are plastic, you would probably have to test for this.
>
> Michael
>
> On Dec 16, 2008, at 2:08 PM, Hobey Ford wrote:
>
>> I heard this on the news the day the law passed.   I will certainly be
>> writing some letters.  If this goes through I wonder what the range of
>> cost it will be to have products tested?
>>
>> On Tue, Dec 16, 2008 at 3:18 PM, Lucky Stradley <lrc-AT-gpcom.net> wrote:
>>> 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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