Good news for the small children's manufacturers, handmade toy and clothing makers, etsy crafters, and everyone else about to be driven out of business by the exorbitant cost of the CPSC's expansive lead testing regulations that go into effect next February: I'm not in charge of rallying troops to contact their congressional representatives and the CPSC, and I'm not in charge of researching and propagating concrete ideas for fixing the CPSIA rules before they go into effect. Because I've been busy dropping the ball.
But a lot of people are mobilizing--and there are plenty of things to be done right now that can have a real impact on keeping safe handmade and small-scale children's products in the market. Here are a couple of places to go:
So what's a creative solution? One of the biggest complaints of handmade and small-scale producers is the CPSIA's requirement to test every children's product for lead, even if it's made from materials that are known to be lead-free [like organic cotton or wool, or oak], and even if they are made using commercial materials [like yarn or fabric] that is known to be lead-free. DT's source says:
The CPSC has issued a request for comments regarding using component parts testing vs final product testing to satisfy the third-party testing requirements. [sure enough, here's the pdf, jan. 30, 2009] Although I haven't seen anything in the "save the handmade toys" blogs about this, it's possible that this is a plausible way to save at least *some* of the industry. Sadly, I do not know enough about margins on things like yarn, felt, etc, to know if this would simply put the cost overboard, but here's what I'm envisioning:Alright, creative people, start gettin' creative! But call your congresspeople too, just to be sure.
- handmade toy alliance/etsy etc and others gets involved in the comment process and gets some approval for component testing for items that are some combination of unique ("OOAK") or handmade, or where less than 10 of the same item are made, or are made by a business with gross revenue of less than X, etc.
- some providers of yarn, wool, felt, cloth diaper PUL, cutesy fabrics, etc etc, and makers of all kinds of other popular crafty things have their items tested (spreading out the cost over larger lots), and then sell those "certified" components to the crafty population who can then use that to meet their third-party testing requirement.
Okay, so I can already see the issues with this (e.g., it doesn't fix the other CPSIA things like lot numbers; it could make these components so expensive it still puts handmade peeps out of business; and technically, every component would have to comply in order to pass the testing), but it's something they might want to explore.