CPSIA: Tracking labels update

Amended: Links to entries explaining the details of complying with the tracking label requirements appear at close. Scroll down if that’s all you need.

As many well know, the matter of tracking labels required under CPSIA has been cause for great concern. In fact, the CPSC has received well over 500 pages of comments (pdf1, pdf2, pdf3, pdf4) protesting the inordinate costs and difficulties of compliance, particularly as this would not increase children’s product safety. Last Monday, the CPSC announced (pdf) the commissioners would be voting today to consider an emergency stay of enforcement of the tracking label requirement. Unfortunately, the vote has been delayed until May 13th, one day after the public hearing on tracking labels scheduled for May 12, 2009 between 1-3 PM EDT. If interested, the hearing will be broadcast live.

Enforcement trends:
There have been 23 apparel related recalls from Jan 1 till now as compared to 8 for this time period last year. Other than the 300% increase in enforcement, two items are noteworthy. The first is that there is an increase in small lot recalls. There’s little doubt many of you have hoped to escape notice but the direction of the agency is clear; smaller enterprises cannot presume to escape enforcement action.

Second, it is shocking that there are continued recalls over draw cords. Drawcords, drawstrings and ties in children’s clothing have been banned since 1996. If firms like Gap and Burlington Coat Factory have recently had to recall items they’ve been selling, one would be very wise to assume one is not compliant unless the guidelines are closely studied. See this entry for more information including photos of specific examples.

Other CPSIA news:
On Tuesday, President Obama announced his nomination of Inez Tenenbaum to serve as chair of the CPSC, replacing Nancy Nord. Robert Adler was also nominated to a commissioner post. Nord will retain position as a commissioner thus bringing the total to four (there are five commissioner posts). It is rumored one commissioner will be resigning from the CPSC but this is not anticipated to occur until after the nominees are approved by the Senate. Obama also announced a dramatic increase in agency funding (71%). The increase in funding is actually good news; the mission of the agency has been severely hampered by a dearth of funding and chronic under staffing.

The Subcommittee on Investigations and Oversight (House Small Business Committee) will have a hearing on Thursday May 14, 2009 10 AM EDT, accepting testimony from small businesses on the difficulties of complying with CPSIA. It is said one can view the hearing via live webcast but I cannot find a link. I’ll update this entry with more information when I have it.

Lastly, the CPSC has released a Handbook for Resale Stores and Product Resellers (pdf) which also requires compliance from ordinary citizens who resell or distribute used children’s products in any manner including donations and garage sales. Many are upset about the latter and at the risk of being a target of reprisal, I think caution is warranted. One example is baby cribs, many recalled cribs are sold at garage sales. An additional problem is the resale of cribs which are missing hardware, rendering them unsafe.

Related entries:
CPSIA tracking and labeling requirements
CPSIA: Printable labels for August requirements
What is a sketch sheet?
What is a BOM (Bill of Materials)?
What is a cutting ticket?

There are 3 comments. Leave a comment

Leave a comment

Your email address will not be published. Required fields are marked *