Correction 12/5/08
Thank you Kathleen for correcting the information I have published. The situation is worse. The CPSC is asking for UNIT testing, not just component testing. Here’s the information on the difference and a link to Kathleen Fasanella’s blog.
Component testing is preferable for two main reasons.
- This saves money and time if you’re repeating fabrications and inputs over several styles -as you should be for continuity purposes and meeting minimums for purchasing.
- It achieves the safety intent of the law best.
Unit testing is not preferable for two reasons:
- It’s wasteful. If you’re using the same exact inputs in your products across styles, it’s dumb to retest the same zipper that is identical in each unit.
- It is less safe, circumventing the intent of the law. Let’s say you melt down a widget or whatever to reduce it into constituencies for testing. The total weight of the product is calculated in comparison to the weight of lead or phthalates so maybe the product is deemed within guidelines -but that doesn’t mean it’s safe. For example, let’s assume the major attributes of the product -like a flat screen tv- are inaccessible to a child and won’t be touched by them but the on and off button is and it’s completely constructed of lead. Should this product pass? Under current guidelines of unit testing it would but it shouldn’t. It would not pass with component testing. In other words, it is more important to test inputs as those can be weighted with respect to accessibility by the child.
-Kathleen Fasanella
http://www.fashion-incubator.com/archive/cpsia-unit-vs-component-testing/
I’m writing to you to express my deep concern for the impending enforcement of the new Consumer Product Safety Commission Improvement Act. While I realize that product safety, especially for children, is of utmost importance, this particular legislation is reactionary and holds potentially devastating economic ramifications.
I personally operate a very small business selling baby carriers and other baby accessories – some made by American companies and some imported from Europe. Under these new regulations, small manufacturers (and crafters who sell as a side business) would be required to submit each piece or lot to prohibitively expensive government approved third party testing. From what I understand, each test would cost anywhere from $100-400, for each COMPONENT of the of the carrier, doll, clothing, cloth diaper, etc.. That’s a test for thread, buttons and each fabric. Considering the fact that each piece is made from completely different fabrics, it would effectively eliminate the ability of small manufacturers, and those trying to make a little extra money for their families, to do business legally in the US.
I have read the CPSIA and there is no exception for quantities made, where the garments/products are made or anything else. To me, this means that grandma selling handmade baby blankets at the church bazaar is selling contraband if she is unable to produce the required safety certificate. It means that for artisans and small business in America one thing… unless you are a multi-million dollar company, you have no right doing business in the U.S. So much for the American dream.
February 10, 2009 is being dubbed “National Bankruptcy Day” by many experts in the apparel and toy industry. I expect that if this legislation is allowed to be enacted, it will affect everyone from port workers to parents looking for legal products. Millions of pieces of merchandise will be destroyed because it can’t be legally sold, causing not only environmental problems, but impacting charities that can’t accept donations without a safety certificate.
As you can see, this legislation is dangerous. I imagine that it was originally written with good intention. However, I can only hope that you will take action in defense of hard working American business owners and help us continue our ethical practices of making and distributing safe products. Please help to defend entrepreneurial America!
Sincerely,
Larissa Wright-Elson
McKinley Kid
