From CPSIA

CPSIA Updates 10/22/09

I should have been dating these entries all along. Here's the latest, newest first.

The CPSC is conducting a hearing on November 10th regarding the establishment of a Public Consumer Product Safety Incident Database. Requests to present oral comments are due by November 3rd. On one hand, many are leery of the prospect of a database as it is unclear how whistle blowing will be weighted and processed. On the other, some people will use the resource to report vendors who willfully ignore the CPSIA statute and thus enjoy unfair competitive advantages. Like everything else associated with the law, the database is controversial.

The CPSC has released the latest version (pdf) of the statement of policy governing testing and certification of lead content in children's products. It is much the same as before but with three differences:

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Will you need to do a recall?

I'll bet most of you think you'll never need to worry about a recall. Ten bucks says 95% of you won't even read this but I can only hope I will never have to say "I told you so". Hopefully most of you will never need to worry about it but it's best to be prepared. This entry applies to anyone who makes or sells products in California and children's product producers nationwide.

Here's the context (if you're not making kid's products, don't leave yet). This morning I was visiting a children's retail site and noticed coats with drawstrings for sale. Shocking, no? If you don't know why ties and drawstrings are a huge problem, catch up now. Since I am friendly with the proprietor, I asked her about it and mentioned the problem. She was horrified to say the least and immediately pulled those items from stock. I was surprised she didn't know so I asked her if the manufacturer had advised her. At first she said no but then after poking around a bit, she found an email advising her of the problem. She also said the email did not emphasize the liability, that these products were illegal.

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CPSIA: Children’s apparel exemptions

If you make kid's products and have somehow missed the CPSIA party, catch up here. Start at the bottom entry and work your way up. For others who've kind of sort of kept up, the CPSC released a new ballot on the final lead rule (pdf) last Thursday which provided details and proposed exemptions to lead testing. I know what you're thinking, it's a ballot and not final. That it will pass is essentially a foregone conclusion. So the question is, is this a good thing or a bad thing for apparel producers of kid's clothes? Judging from consensus, it's not a complete solution but we (apparel) are a whole lot better off than other segments of the children's products market.

Before getting into exemptions, I must reiterate that testing of individual components is technically not permitted under CPSIA. We were granted a stay effective through February 2010 but it's not a permanent change. I mention this because judging from the content of this 94 page document, it seems obvious that a change in testing requirements to favor component testing is being seriously considered. Here's the money quote (emphasis is mine):

The Commission is aware that there are many questions regarding component part testing and certification for lead content given that any children's product may be made with a number of materials and component parts. The questions regarding testing and certification are significant because not all component parts may need to be tested if they fall under the scope of the exclusions approved by the Commission... The Commission intends to address component part testing and the establishment of protocols and standards for ensuring that children's products are tested for compliance with applicable children's products safety rules, as well as products that fall within an exemption, in an upcoming rulemaking.

The reason I mention this before talking about exemptions is because exemptions are itemized per component. Many analysts are interpreting the focus on components as indication that policy changes will permit component testing in the future, hopefully before the expiration of the stay in February. Caveats dispensed with, here's the skinny.

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CPSIA: Another tracking label update

As some of you already know, the CPSC posted a Statement of Policy (pdf) which includes Commissioner comments that outline the interpretation of the tracking label requirement as well as an updated FAQ. Perhaps surprisingly, many decisions are left in the manufacturer’s best judgment. Likewise, the CPSC mentions an “education period” although compliance is expected if it comes to a potential recall. Above all, it seems apparent the Commission does not intend to penalize manufacturers who have erroneously interpreted the guidelines provided any errors or omissions were made in good faith. That doesn't mean you're off the hook just because you're small. Tenenbaum said specifically:

...small volume manufacturers and crafters have expressed concern that they cannot feasibly comply with the statute because their production patterns do not lend themselves to lot, batch, and run labeling systems. To this end, the Commission agrees that small volume manufacturers or crafters need not create a labeling system incorporating the use of lot, batch, or run numbers so long as such manufacturers can keep adequate records of the components used in their products. The goal of the labeling statute is to enable manufacturers and consumers alike to ascertain pertinent information about a children's product in the event of a recall, not to implement a rigid and uniform labeling standard that applies to both small and large manufacturers in the same way. In developing and implementing a tracking label system, small volume manufacturers and crafters should also consider the business and recordkeeping practices of their peers.

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CPSIA articles index

Amended 7/28/2009

This entry is simply an index of all CPSIA related entries posted on the site over the past several months. I've been meaning to do this for awhile. Entries are listed newest to oldest. I'll update this as needed, changing the publication date if needed to keep it at the top of the category search returns.

CPSIA Forum on Fashion-Incubator, open to the public

Entries:
CPSIA: Another tracking label update
What is a batch?
CPSIA: Tracking labels update
What is a cutting ticket
What is a Bill of Materials (BOM)
What is a sketch sheet

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What is a batch?

This isn't about the batching we've been talking about, this is an entry I needed to put up a long time ago for people making children's products who need to comply with CPSIA. Several people contacted me saying they needed to order labels so I had to get back to it.

If you don't know what I'm talking about, you need to read CPSIA and tracking label requirements. As of August 14, 2009, all children's products are required to have a new label. For review, the purpose of the label is so consumers can determine:

  1. The manufacturer as we define it (legally, in other words, you)
  2. Location of manufacture
  3. Date of production
  4. Cohort information (a contractor -none if applicable)
  5. Batch or lot number (a number you assign)

The big sticking point is what is a batch? Normally, a cut order is a batch but this does not qualify under CPSIA. Under CPSIA, a batch is one lot that uses identical items which themselves have identical lot numbers. For example, if you're using the same thread, the same fabric and the same buttons or zippers the individual items of which come from their own complete batch as listed on the box they came in, then that is a batch. Each batch needs a unique identifying number.

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Free! Try StyleFile PDM/PLM software for 30 days

I've made no secret that I love StyleFile for creating technical packages and managing your production from soup to nuts so I'm very pleased Patternworks is now offering a fully functional 30 day trial of the program. To take advantage of this free offer, select "solutions" from the website or contact Gina to request your fully functional copy of the software. There's also several videos on site which you can view singly or download for viewing at your leisure. Not mentioned on site is a tremendous resource, the wiki. The wiki is the place to learn how to set up and operate the program.

Increasingly, a PDM/PLM program is a necessity to manage your production, particularly if you outsource work to others or provide services yourself. I've written about many PDM/PLM features (and StyleFile specifically) in What is a Bill of Materials (BOM), What is a tech pack and Giving instructions to a pattern grader. PDM software is practically a necessity these days if you're using a sewing contractor because your technical package complete with sewing specs defines the absolute requirements of your product which in effect becomes the sewing contract. But sewing is only a small part of it. You and/or your pattern service and sewing contractor can use it to manage patterns, textile testing, grading, inventory; all facets of the production process. The neat thing about StyleFile is it's designed to be used by manufacturers and service providers.

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CPSIA: Tracking labels update

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.

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What is a Bill of Materials (BOM)

A Bill of Materials (BOM) is a list of inputs that go into your product. If the sketch sheet was a broad overview of the style itself, the BOM is specific about the materials. Not only is it specific about each input, it is specific per colorway. In other words, if you have three colorways, you will need a BOM for each color. Perhaps you could think of a BOM as a list of ingredients. If it is not on the BOM, it doesn't go into the product. Here is a sample BOM report (pdf) made using the StyleFile software.

With the BOM (which you need for costing later on), you also need to track the vendor -and testing- of each input. Again, everyone needs to do this (shrinkage etc) but kid's producers more than anyone (which is why I said that the children's producers who survive will become the epitome of professional practices in the trade). Off to the side is another worksheet from StyleFile, the BOM editor (different from the pdf above). Clicking on an item in the left row, causes the header information to change (indicated by the arrow). You can see the full size form by clicking on the graphic.

If you're making up your own form, you will need to track the following items per "ingredient".

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What is a sketch sheet

This entry applies to everyone but most especially producers of kid's products. In writing the CPSIA tracking and labeling requirements, I find I need to backtrack a bit more than usual. I really don't want to be a nag but if you don't know how to do this already, you should seriously consider purchasing my book. There's a whole section on this vital process (pg 54-59).

A sketch sheet is much more than a piece of paper with your design drawn upon it; it is the first and most pivotal form you have. You may as well drag out a file folder because this is the first of many forms that will go into it. Start one folder for each style. My personal preference is to use a three ring binder, perhaps that will work for you. I use one binder per season. If styles are carried over from one season to another, I make copies to put them in the new book.

Off to the side is a hand drawn sketch sheet sample I did when I made this jacket for a friend (now my spouse). Because it was a private project, I didn't need a real form, just a record to keep me on track. I actually do fill out sketch sheets for personal projects and save them for later reference. There's also a larger version of this form available (73kb). Your form will need to be much more detailed and you can create one as a database form in Excel or other program.

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