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You do NOT want a small business exemption
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Lisa DOWNTOWN JOEY
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PostPosted: Sat Dec 20, 2008 5:40 pm    Post subject: Reply with quote

Love the NAM proposal!
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Shannon F
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PostPosted: Sat Dec 20, 2008 6:24 pm    Post subject: Reply with quote

That is GREAT! I just read it all the way and it is very well written. After reading that, I realize even moreso just how wide reaching this law is. There are things mentioned there that I had not even thought about! I really wish the Handmade Toy Assoc would have been on board with this.
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blizzard77
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PostPosted: Sun Dec 21, 2008 5:35 pm    Post subject: Reply with quote

That addresses all my concerns, as well. Plus a lot more! Nice.

Question: what is the likelihood that the CPSC simply moves the effective date from Feb 10 to later in the year instead of addressing the core issues immediately? I fear if that happens there will be even more confusion. Is there any provision to prevent delay rather than action?
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Kathleen F.
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PostPosted: Sun Dec 21, 2008 5:45 pm    Post subject: Reply with quote

Good questions blizzard. I think we all agree the next best step is to work on an appropriate response to the request for comments. See the intro, we've broken it down by question. We could use some help with it. The sooner we can submit the better. In fact, the oftener we submit the better. The deadline is Jan 30. Even if they turn around and issue new guidelines within two weeks, it's going to cost some people plenty and thus, why the sooner we submit something workable, the better.
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PostPosted: Mon Dec 22, 2008 10:48 am    Post subject: WOW that would help so much Reply with quote

Kathleen F. wrote:
Cross posted

After a careful reading, I am going on the record that we support the proposal submitted by NAM (National Association of Manufacturers) to the CPSC. As I've long argued is necessary, it is broad and inclusive.


OMG that is so well written. If they would JUST amend those particular thing it would help tremendously. That would help big and small manufactures alike. The children's apparel would be saved, yes they would still have to test buttons and zippers things like that but if would save soooo many companies from going bankrupt.
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annika
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PostPosted: Mon Dec 22, 2008 12:33 pm    Post subject: Reply with quote

If the NAM proposal pretty much sums up exactly what we feel, is it wise to simply send in comments that say "We agree wholeheartedly with the NAM proposal and hope it will be implemented as written"?
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Kathleen F.
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PostPosted: Mon Dec 22, 2008 4:38 pm    Post subject: Reply with quote

Actually, I'm suggesting we each print it out and mail it to the address on the letter head.
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Mary Beth
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PostPosted: Fri Dec 26, 2008 1:02 am    Post subject: Reply with quote

And we probably want to urge that a Ruling be made on each and every issue. But we also want to request that our separate concerns be considered. We don't want to leave out these special concerns of our own.

For example I will be urging that what I make is different from "toys" in that "educational materials" are used under the supervision of a specially trained adult. Etc, etc, etc. So that's just one small possibility. I don't hang my hat on this distinction. But it's something that is important in the usage of the products that might warrant a new category, "educational materials"

If we all speak to our own special issues (as well as referring to and attaching the NAM Request) we are causing our many issues to be reiterated and in volume.

A Petition for exemption based on size (under 5000 units per year) just serves up an easily reachable news story with no need for the regulators and consumers to study and think. That's why the media has gloomed onto the Size Petition and hasn't discussed anything else about this horrendous law. As a result no one in the media has given the CPSIA 2008 much serious consideration.

We want people to think, to apply these broad regulations to each situation, to digest the goals of the regulators and reconcile those goals with the reality of staying in business today in our economy.

Long story short, I think it's important to give every reason under the sun that this law needs reconsideration and to make it real for the reader, make it accessible, and make it specific to your situation. Tell them what this law requires you, the manufacturer/importer/retailer to do and why you shouldn't have to do it that way. Offer solutions that would be easier and make for sense, like component testing not item testing. We have to educate the regulators. That's all there is to it.
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Sarah Reid
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PostPosted: Fri Dec 26, 2008 7:42 pm    Post subject: Reply with quote

Mary Beth wrote:
For example I will be urging that what I make is different from "toys" in that "educational materials" are used under the supervision of a specially trained adult.


I'm trying to decide if this makes a difference? At first I thought, "wow, that's a great distinction," but now I'm not sure why it matters, in terms of lead content/testing. If it does, I'd be all in favor because everything I make (diapers, carriers) are intended to be used BY adults but for children.

(However, not all "educational materials" are used under the supervision of a specially trained adult. We homeschool, I have no special training for this, and we use LOTS of educational materials. Is competent adult a better term? Just thinking "aloud" here.)
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Miracle
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PostPosted: Fri Dec 26, 2008 7:51 pm    Post subject: Reply with quote

Quote:
If it does, I'd be all in favor because everything I make (diapers, carriers) are intended to be used BY adults but for children.


That's a real stretch to try and argue diapers are used by adults for children. Carriers... that could go either way. However, nearly all babies lick (or gnaw on) their carriers so I don't know how there could be an exemption for that--- even though it is worn by an adult.
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PostPosted: Sat Dec 27, 2008 10:45 pm    Post subject: Reply with quote

miracle wrote:
That's a real stretch to try and argue diapers are used by adults for children.


really? obviously, we are just seeing this from different angles, because I'm kind of surprised by that. My reasoning is that not too many babies use the diapers themselves. (Or perhaps my kids are just dumb? Neither one has ever changed their own diaper, nor washed them.) They are a product of convenience for parents.

Then again, I suppose one could say they're really no different from clothes, which would support your view. I just hadn't really thought about it like that, ever.
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J C Sprowls



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PostPosted: Sun Dec 28, 2008 10:04 am    Post subject: Reply with quote

Quote:
I just hadn't really thought about it like that, ever.

What matters is how the law defines it. And, if legal counsel consults with apparel and diaper manufacturers (e.g. Pampers) they will likely determine that a diaper is children's apparel or a children's healthcare product regardless who administers it (i.e. puts it on the child).
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Eric H
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PostPosted: Sun Dec 28, 2008 10:40 am    Post subject: Reply with quote

Anonymous aka wallypop wrote:
really? obviously, we are just seeing this from different angles, because I'm kind of surprised by that. My reasoning is that not too many babies use the diapers themselves.


This is absurd or you are not doing it right. Do you scoop up the baby poop off the floor or bed or clothing, put it in the diaper, and then put the diaper in the diaper pail? Or do you put the diaper on the baby? By your logic, we could probably exclude everything from the law: toys are bought by adults for children because children don't have jobs and money; cribs are used by adults to store their babies when they aren't playing with them; school science supplies are bought by school boards and used by teachers and kids only go to school because they have to; and so on.

The only conclusions that you leave me with is that you and the other denialists really believe this to be legitimate (and therefore this law is not nearly draconian enough), or you are intentionally being obtuse and directing your resentfulness about this law at us. This proves the point Miracle made at the head of this thread, and apparently has to keep making, about professionalism.
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annika
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PostPosted: Mon Dec 29, 2008 3:52 pm    Post subject: Reply with quote

miracle wrote:
Carriers... that could go either way. However, nearly all babies lick (or gnaw on) their carriers so I don't know how there could be an exemption for that--- even though it is worn by an adult.


There are definitely parts of a carrier that are accessible to gnaw on/chew and should be tested, but there are parts that are inaccessible when the carrier is in use--and I would argue that these parts should not have to be tested if they are effectively inaccessible (even if not interior, like foam padding) to the child when the item is used properly--which is worn by the adult to aid in carrying a child and not allowing the child to play with/manipulate the item when not being carried in it.
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Miracle
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PostPosted: Mon Dec 29, 2008 4:12 pm    Post subject: Reply with quote

annika wrote:

There are definitely parts of a carrier that are accessible to gnaw on/chew and should be tested, but there are parts that are inaccessible when the carrier is in use--and I would argue that these parts should not have to be tested if they are effectively inaccessible (even if not interior, like foam padding) to the child when the item is used properly--which is worn by the adult to aid in carrying a child and not allowing the child to play with/manipulate the item when not being carried in it.


I still don't think it's a valid exemption to fight for because, as we have seen, people come up with some crazy ways to exempt their items.

My point has been that some of the exemptions people want are so crazy, they actually do more to prove the point of why the law should be strict.

I don't even know that it makes sense to produce an item so closely used by a child and then argue certain parts of it shouldn't have to be tested. That, to me, might seem one of those circumstances where testing the complete piece is more sensible than components.

But anyhow, I don't even know that this law can be passed in a way that makes the OOAK/Handcraft industry happy, because it seems like the handcraft industry really only wants a way out. Not so much reasonable compliance.
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