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

[Eric H]

The table of contents for all the questions in the RFC, including an explanation of what an RFC is can be found at [url=//fashion-incubator.com/phpbb/viewtopic.php?t=3534]Introduction and Table of contents: RFC Component vs unit and 3rd party testing[/url]

This section deals with the eighth question which is:

[jennifer]

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.

[Eric H]