Date: Tue, 16 Dec 2008 18:01:08 -0500
To: puptcrit-AT-puptcrit.org
Subject: Re: [Puptcrit] "new" rules for the CPSIA legislation


I think it is reasonable for our government to respond to recent lead
containaments from China.  US products haven't been a problem so in a
time when we need to help small business lets not pile on costs for
testing that will drive many small toy makers out of business who at
the end of the day most likely hve been producing safe products.  How
about tax deductions for testing or subsidized testing, and allowances
for pre-tested materials.  Or at least a moratorium on testing until
we find a way to help small businesses through this dilema.

On Tue, Dec 16, 2008 at 5:38 PM, Michael Dowell <moodooguru-AT-gmail.com> wrote:
> I believe the law takes effect February, 2009.
>
> What do you think should be done in order to make the law more fair
> for small toy makers?
>
>
> On Dec 16, 2008, at 2:29 PM, Hobey Ford wrote:
>
>> 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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