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The endless loop of enforcement

 
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Kathleen F.
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PostPosted: Sun Dec 21, 2008 4:11 pm    Post subject: The endless loop of enforcement Reply with quote

This is an area to follow up on the points eric made in this thread and quoted below. We've been talking about it a lot, may as well make a set aside for it so we can keep the discussion off the other threads.

Quote:
...Far too many new entrants to the apparel industry lack process controls. They may begin with a tested component, but then freely substitute and cut corners. That is probably how many of the recalled toys came into the market in the past few years: foreign manufacturers felt that they could freely substitute.

Perversely, the first reason will probably draw even less professional competitors into the marketplace. The apparel industry is not difficult to enter. As smaller companies exit, price will increase and choice will diminish. New companies will be created to fill this opportunity, resulting in even less control... CPSC should engage in some kind of outreach to increase awareness and provide training.


My comments from Q.1

I've worked with endless designers. I can't say how many have made a change to a garment and would swear up and down that it wasn't a "real" change. But it is. I don't know the answer but leads us treacherously down a path toward requiring licensing as a demonstration of minimal competency of children's product manufacturers. I think this is preferable because experienced producers wouldn't be burdened with the costs of unit testing because their less experienced brethren didn't know and were spoiling the pot for everyone. It could be a very simple exam and tied to the RN database. Knowing who was compliant could be fairly simple. No RN number, not licensed.
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Esther
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PostPosted: Sun Dec 21, 2008 7:33 pm    Post subject: Reply with quote

I would be opposed to licensing as it adds another layer of bureaucracy and costs. Why should one product category require licensing and not others? How does one determine an appropriate cost of entry into children's products? Too high and small businesses are out. Too little and it means nothing. Let's not add any more barriers to entry. If the CPSC did provide training programs/public outreach that would alleviate many problems. Do a quiz at the end of the seminar and issue a certificate of completion. Big Box retailers provide training seminars on testing and compliance for their programs. A similar program could be established with the CPSC. But licensing. Let's not go there.
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Kathleen F.
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PostPosted: Sun Dec 21, 2008 8:42 pm    Post subject: Reply with quote

Esther wrote:
I would be opposed to licensing as it adds another layer of bureaucracy and costs. Why should one product category require licensing and not others? How does one determine an appropriate cost of entry into children's products? Too high and small businesses are out. Too little and it means nothing. Let's not add any more barriers to entry. If the CPSC did provide training programs/public outreach that would alleviate many problems. Do a quiz at the end of the seminar and issue a certificate of completion. Big Box retailers provide training seminars on testing and compliance for their programs. A similar program could be established with the CPSC. But licensing. Let's not go there.

Licensing doesn't have to be expensive. Think of a driver's license, most business licenses are inexpensive.

Here's the problem Esther, how is the CPSC going to do outreach? How are they going to do training? How/who will pay for it? But most importantly, how are they going to have the pull to require that people take these orientation classes?

Iow, they can't do any of these things. The only way they can is if there is first a requirement that a minimal standard of competency is attained. And there's all kinds of precedent for it. Licenses for the cafeterias of nursing homes and schools are different from that of restaurants.

I'm thinking of something much less complex than what you are. Sign up for an RN number and you're sent a pdf to read. After you read it, you take a simple test online. If you pass it (easy enough if you've read the pdf and if you print it out, you can cheat while taking the test), you get the RN number. And yeah, I know people will cheat. Duh. The point is, they are on notice that they're responsible for something and they are worlds more likely to know they need to review the material and we are all so much better off than someone who one day goes into Joann's to jumpstart her business and has no means of knowing anything. If people are required to have the RN for kids to sell stuff, who says it has to be punitive? They get a warning to get the RN within 10 days etc. It doesn't have to be draconian.

The best thing about requiring an RN of everyone is that there will finally be a way to contact people to tell them laws have changed. Right now, there is no notification system at all.
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Kathleen F.
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PostPosted: Sun Dec 21, 2008 8:47 pm    Post subject: Reply with quote

Moved Esther's comment from here
Esther wrote:
Perhaps the deeper philosophical question is how much control is handed to the government (their rules) versus can we police ourselves? Do we allow new entrants to make mistakes? Can we prevent new entrants from making mistakes?

I would say it is 100% impossible to make a 100% perfectly safe product no matter the experience. The same can be said about intended design and/or function. There are so many variables in the production of apparel that it would be difficult to control each step so precisely that it is 100% safe. There is something to the idea that it is only by making mistakes that we can learn and improve. If we don't allow mistakes to be made, then what? Mediocrity is surely the result.

Of course there is the emotional appeal of only allowing 100% safe products for your child (the plastic bubble phenomenon). A children's DE is at risk, regardless of experience, to create a product that has flaws. Some flaws don't necessarily indicate a lack of safety, such as fabric bleeding in the wash or a pocket stitched on askew. Now buttons that aren't stitched on securely could pose a safety concern, so what do we do there?

Training programs on quality control and auditing? I am thinking that design schools really need to return to childrenswear design training. I know there is an inherent problem with design schools and their lack of actual industry knowledge. The approach would have to be different than it's ever been before. The larger problem is that nearly all design programs have either ignored children's clothing or eliminated it from its curriculum. Design schools/training programs really need to return to an emphasis on quality control/standards and manufacturing processes. It would be nice to see some trade organizations pony up and offer affordable (and I mean less than $200) classes and seminars.
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Esther
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PostPosted: Sun Dec 21, 2008 10:12 pm    Post subject: Reply with quote

I realize there is a certain respect or prestige given to an individual who is licensed. But to what end? There are all kinds of licensed trades but they don't make us any safer. Mistakes are made all of the time by licensed individuals. To me the value of a license is worthless compared to experience and training. To require a fashion design or children's product licensing program will not achieve what is intended. I guess I'll stop arguing on that point as I think I have made my point.

In any event Congress has allocated a rather large sum of money. They should seriously consider using some of it in training seminars 2-3 times a year in regional locations. Why not put the state CPSC representatives to work? I didn't even realize those people existed until recently. They certainly have not made themselves known. What do they do all day? They should make themselves more available to business. They could help us do our jobs better. The CPSC rep could send you a packet of information related to your products, as you suggest. They could come in and review your business in it's early stages in regards to regulations or answer questions. That would be far more useful than a license.

I passed various certifications for librarian clerkship and it was done in a process that you describe. To be honest it has not helped me all that much and is considered rather worthless by degreed librarians. (IOW, it will not help improve my position). In fact attending annual librarian conferences has helped more with training than anything else except actual experience.
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jennifer
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PostPosted: Mon Dec 22, 2008 10:41 am    Post subject: Reply with quote

We have an RN number and were not notified of the CPSIA. It would be nice if they used it that way.
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Eric H
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PostPosted: Mon Dec 22, 2008 7:25 pm    Post subject: Reply with quote

Forget licensing. I'm not a fan, either.

Think of it as registering. When you apply for your registration number, you are registering. The bar should be very low -- competition is good, entry is good. When you apply for your RN, you pay a user fee, take a simple exam that shows you have some knowledge of what you are getting into, and you get your RN.

I'm an anarchist. But since I don't foresee complete repeal of everything back through corporate liability limits in my lifetime (I think the execs at Mattel would be a little more careful if it was their money on the line instead of their investors, and I also don't see Mattel or Nike getting that big without 150 years of corporate law behind them), then we're stuck with this mess. What causes the least amount of pain? I think the RN, plus drastic curtailment of the penalties. Instead of million dollar fines and jailtime, they ought to simply note that you don't have an RN and inform you that you need one. Get caught after that and get audited and sent to a more expensive (user-fee driven) training camp. Get caught after that and then they can start throwing the book, unless you can show that you did due diligence and a supplier upstream faked a test.
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J C Sprowls



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PostPosted: Mon Dec 22, 2008 8:14 pm    Post subject: Reply with quote

Now, this I can get behind: a written acknowledgment of accountabilities, plus a progressive discipline program.

The only problem is that by educating the registrants, you lose a revenue opportunity. That's actually how I perceive this legislation - a way to increase revenues by 'taxing' the business sector with the cost of tuition after-the-damage-has-been-done.
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Eric H
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PostPosted: Mon Dec 22, 2008 8:33 pm    Post subject: Reply with quote

You can't tax what doesn't exist.
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Esther
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PostPosted: Tue Dec 23, 2008 8:33 am    Post subject: Reply with quote

Very true that Congress (and most municipalities) look at tax as "revenue". Very infuriating when they try to raise revenue for their pet projects instead of serving the people.
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