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Q.1 RFC Component v. Unit and 3rd party testing

 
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Eric H
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PostPosted: Sun Dec 21, 2008 10:41 am    Post subject: Q.1 RFC Component v. Unit and 3rd party testing Reply with quote

The table of contents for all the questions in the RFC, including an explanation of what an RFC is can be found at Introduction and Table of contents: RFC Component vs unit and 3rd party testing

This section deals with the first question which is:
Quote:
How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts of a consumer product versus third-party testing of the finished consumer product.


This is first question
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Eric H
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PostPosted: Sun Dec 21, 2008 12:02 pm    Post subject: Reply with quote

Third party testing of the finished product will definitely reduce the risk vs. component testing for two reasons. First, it will reduce the economic viability of many products. Fewer products means more of what remains will likely be compliant, and those that remain will be easier to police with fixed resources.

The second reason has to do with manufacturer competence. 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 more inexperienced/unprofessional competitors into the marketplace. The apparel industry is not difficult to enter, and we don't want it to be. 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. On balance, the component testing may be the best result, but CPSC should engage in some kind of outreach to increase awareness and provide training.


Last edited by Eric H on Sun Dec 21, 2008 8:01 pm; edited 1 time in total
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Kathleen F.
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PostPosted: Sun Dec 21, 2008 4:41 pm    Post subject: Reply with quote

Quote:
How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts of a consumer product versus third-party testing of the finished consumer product.

I can't speak for anyone else but I'm not sure I understand the question. I'm going to try to work my way through it here like so:
Quote:
the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts of a consumer product

I take this to mean, "if we allow 3rd party testing of component parts (rather than requiring 3rd party unit testing), how likely is it that non-compliant products will enter the marketplace?"

This is an interesting question. Due to the issues Eric mentions (and with which I concur) it is possible to have defective product enter the market place for the latter reason and also due to the matter of the nature of how we buy, meaning we buy prototypes of buttons or what have you that are not finalized themselves.

I think this problem is better addressed in two ways. First, we should be permitted to use vendor supplied certifications. Naturally, not all vendors will do it but then our option is to either buy from suppliers who do verify their products or to do it ourselves. After awhile, more vendors will do the testing or go under. Naturally, the prices we pay will be higher which will raise the cost of goods and retail prices. Be that as it may...

Second, it matters a great deal at which stage of the process components must be certified. Greatest protection for consumers would mandate component testing of items used in production units, not prototypes or sample units intended to sell the product.

A continuing problem is, new entrants to the field do not share process definitions or understand how ways they may process a fiber can alter its chemistry. It is common for a perfectly compliant length of goods to be compromised with an "after market" modification, by "embellishing" the goods with puffy paint (phthalates), roller paints (lead) or iron decals (phthalates/lead?). But then, I descend into this discussion here.


Last edited by Kathleen F. on Sun Dec 21, 2008 8:51 pm; edited 1 time in total
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Kathleen F.
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PostPosted: Sun Dec 21, 2008 8:50 pm    Post subject: Reply with quote

In this thread, we need to focus on a response to this question. I moved a comment that was OT from this central goal but that I really want to discuss over here. I think we need to talk about it so we have all the space to do it over there and keep this thread focused.
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Melissa McKeagney
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PostPosted: Sun Dec 21, 2008 9:37 pm    Post subject: Reply with quote

Not to get away from the original question, but as a DE of children's clothing, I never went to design school, and don't intend to do so. So I'm not sure that implementing classes would really work. I know there are many people like me who have taken an untraditional route to this business.

I like the idea of licensing the way Kathleen laid out in another post, might be a viable solution to basic safety and labeling requirements using RN numbers as a means of giving manufacturers the basic information. Unfortunately nothing the government does is ever simple, and I do think it might lead to unnecessary bureaucracy.

So back to the question, which I take to mean what are the risks associated with component testing versus unit testing? In my opinion the risks would be substitution of similar components. I know I have done this in a pinch with buttons that are similar in color and style when I have run out of the original button. In a testing situation, if the button is from a manufacturer that doesn't provide supplier testing certs., then that product might be "unsafe" (seems to me a stretch, but one never knows). Fabric altering through silk screen, surface coating, etc., is another risk. The fabric may be perfectly fine, but what is done to the fabric may complicate the issue.

Melissa
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jennifer
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PostPosted: Mon Dec 22, 2008 10:49 am    Post subject: Reply with quote

I think in some cases that an end test of the product will make a product safer but not in all. What if you really are using the same fabrics and notions and labels from the same lot? I still don't see how testing the end product makes it safer unless they are maybe testing for construction. Even then - as in any manufacturing facility cars, bikes, toys, clothing - there might be a mess up.

One of the problems right now is that many of us small fish order snaps / notions from distributors and resellers. Do they know what lot these are from? So in the testing of an end product if you have 3 snaps on a onesie - they may very well be from 3 different lots.

I hope i am not confusing this question but it just isn't cut and dry for me.
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Vesta
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PostPosted: Mon Dec 22, 2008 2:54 pm    Post subject: Reply with quote

The reality is that caution is on their (the lawmakers') side. Unit testing is seemingly the safest way to know that the final product is X-free (lead, phthalates, whatever). However, even unit testing isn't foolproof, as one item in my "batch" could be using snaps from a shipment of snaps that were mixed at the supplier's end. Even though I test one of my finished items, another may have a different snap batch, even if I have been very diligent about tracking my batches.

[And btw, in a best practices setting, it is up to you to know if one of your items uses snaps from three different supplier batches, if you know that. That's the point of the lot tracking requirement, and ultimately part of what makes up effective lot tracking. There's been a lot of talk about "what makes a batch", and that's part of it.]

So I guess I would say that component testing is as good as unit testing, because even unit testing is not foolproof. And additionally, component testing is less onerous, more cost-effective, and therefore more likely to be implemented properly.

Then if component testing is combined with allowing certifications by suppliers, you have a sensible system. In fact, I would say that allowing certifications from suppliers would be part of ensuring the success of component testing, and therefore the success of this law accomplishing its goals. As K said, if we can get suppliers to include these tests in their basic processes, then we won't run across fabric with lead. Forcing only manufacturers to test for lead doesn't put enough pressure on the suppliers to change, IMO.

Finally, to get around the issue of switching suppliers/components at the last minute, perhaps there could be a requirement to test the actual components destined for production, not just sample components (unless they're pulled from the same supplier lots).

Sorry if this is meandering . . . I'm typing as I think.
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Eric H
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PostPosted: Mon Dec 22, 2008 7:08 pm    Post subject: Reply with quote

Those are good point regarding the pitfalls of unit testing. I think you're right to say they're about equal in terms of risk.

Those are also good points regarding pushing this to suppliers. That is going to have limited success, though (I think). For one thing, suppliers may not agree that each fabric, button, zipper, etc., is intended for the children's market, so why should they test? You are only asking them to incur costs that their competitors in the non-children's clothing market won't ("non-children's ..." as opposed to "adult clothing market" which doesn't sound right *ahem*). I would think that some things would be obvious:

Spongebob print flannel: children
brown tweed: not children

But where does blue denim go?

Damn useless US mills - you'd think they could help us to help them.
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Esther
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PostPosted: Tue Dec 23, 2008 8:42 am    Post subject: Reply with quote

The fallout of component testing could be very few choices. If the end product maker won't test and the supplier won't test or certify, then that material is out. Somewhere along the line someone will have to take the hit. I already have one supplier not talking to me because they won't supply GCC's.

With a drastic reduction in choices, we will see all the children DE's using the same fabrics. (Unbleached muslin, anyone?). Kind of a problem now since the DE's gravitate to certain prints and colors but surely an even greater problem later.
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Eric H
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PostPosted: Sat Dec 27, 2008 11:41 am    Post subject: Reply with quote

I thread-jacked my own thread with my conjecture about mills. The split is at http://fashion-incubator.com/phpbb/viewtopic.php?t=3670
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