Thursday, January 15, 2009

Children Product Law.. a third part joke?

Can I just say what the fuck?  I found out about this today and I'm completely speechless.  How are small business suppose to deal with this?  Third part regulation on this is a fucking joke.  How is this even going to be regulated or policed by a third party in the first place?  Is this part of a micro-management bureaucratically wet-dream?  I'm all for keeping kids and children safe.  I would not be striving for environmental sustainability in the first place if I did not give a shit about my fellow human being or the world we line within.  This is on par with giving Robert Murdoc control of the FDA.  It does not make sense and is completely ridiculous.

Request for Comments and Information*

Mandatory Third-Party Testing for Certain Children’s Products

Section 102 of the Consumer Product Safety Improvement Act


The Commission staff invites comments on Section 102 of the CPSIA, Mandatory Third-

Party Testing for Certain Children’s Products. The staff requests comments specifically on

third-party testing of component parts.

CPSIA section 102(a)(2) imposes testing requirements to support certificates of compliance

for “children's products'' as defined in section 235(a) of the CPSIA (to be codified at section

3(a)(2) of the Consumer Product Safety Act). Ninety days after the Commission issues those

requirements for a given product or category of products on the rolling schedule specified in

section 14(a)(3), the certificate for the product or products in question manufactured after that

date must be supported by testing performed by a third-party laboratory whose accreditation

has been accepted by the Commission absent the Commission's exercise of its authority to

extend such a deadline by an additional sixty days in certain instances. Given the schedule

for implementation of the third-party testing requirements, the staff is interested in comments

and information regarding:

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.

The conditions and or circumstances, if any, that should be considered in allowing

third-party testing of component parts.

The conditions, if any, under which supplier third-party testing of raw materials or

components should be acceptable.

Assuming all component parts are compliant, what manufacturing processes

and/or environmental conditions might introduce factors that would increase the

risk of allowing non-compliant consumer products into the marketplace.

Whether and how the use and control of subcontractors would be affected by

allowing the third-party testing of component parts.

What changes in inventory control methods, if any, should be required if thirdparty

testing of component parts were permitted. Address receipt, storage and

quality control of incoming materials, management and control of work-inprocess,

non-conforming material control, control of rework, inventory rotation,

and overall identification and control of materials.

How a manufacturer would manage lot-to-lot variation of component parts, in a

third-party testing of component parts regime, to ensure finished consumer

products are compliant.

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.

Comments must be received by the Office of the Secretary no later than January 30, 2009.

Comments may be filed by email to Comments

may also be filed by facsimile to (301) 504-0127 or by mail or delivery to the Office of the

Secretary, Consumer Product Safety Commission, Room 502, 4330 East-West Highway,

Bethesda, Maryland, 20814. Comments should be captioned “Section 102 Mandatory Third-

Party Testing of Component Parts.” Interested persons will also have additional opportunities

to comment following publication of any notices of rulemaking proceedings in the Federal

Register which are commenced under this section.

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