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Q.8 RFC Component v. Unit and 3rd party testing

 
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Eric H
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PostPosted: Sun Dec 21, 2008 10:48 am    Post subject: Q.8 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 eighth question which is:
Quote:
Whether consideration of third-party testing of component parts should be given for any particular industry groups or particular component parts and materials. Explain what it is about these industries, component parts, and/or materials that make them uniquely suited to this approach.


This is the eighth and last question
Return to the seventh question
Return to the introduction
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jennifer
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PostPosted: Mon Dec 22, 2008 11:19 am    Post subject: Reply with quote

1. "textile industry" especially the organic textile industry should be considered if I am understanding the question. Textiles - especially organic textiles inherently have no lead after finishing and with organics the limit is much lower then the current legislation allows. Oeko-Tex and GOTS (global-standard.org) are just two.

There are many wholesalers and retailers of fabric. If the aim of the CPSC is to not kill small business - shouldn't fabric be certified before it is available for sale regardless of it is going to a small or large company? If this isn't allowed - is someone going to even buy fabric anymore who produces on a micro scale? This would allow even the smallest Etsy producer to stay in business to purchase pre-tested fabric.

2. commodity items - such as snaps, zippers, etc. because they are widely available at manufacturer level, wholesale and retail - we don't special order 300 snaps - they are made already - and most buy from that pool of existing "snap" inventory.

The added benefits: any raw goods manufacturing industry that hasn't been cleaning up their act will be forced to on a larger scale and these products will be available to small producers with out having to duplicate unnecessary testing.
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Eric H
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PostPosted: Mon Dec 22, 2008 7:17 pm    Post subject: Reply with quote

jennifer wrote:
There are many wholesalers and retailers of fabric. If the aim of the CPSC is to not kill small business - shouldn't fabric be certified before it is available for sale regardless of it is going to a small or large company? If this isn't allowed - is someone going to even buy fabric anymore who produces on a micro scale? This would allow even the smallest Etsy producer to stay in business to purchase pre-tested fabric.


Remember that this is -- so far -- only about children's stuff. No need to test goods intended for adults. So ... load those golf pants up with lead! And phthalates!
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