NAM - National Association of Manufacturers have come together in a petition addressed to Todd Stevenson Director, Office of The Secretary U.S. Consumer Product Safety Commission. The 15 page petition is well put together and I would urge everyone involved or concerned about the new regulations to read it. The following is a portion from page 5 -

“For example, a garment manufacturer may use fabrics like cotton and cotton thread with no or very low total lead to make thousands of SKUs of children’s t-shirts. Absent an exemption, the garment producer may have to test each different SKU for lead – testing the identical material thousands of times. Or, a garment maker might purchase 100,000 zippers and use the zippers in a variety of children’s apparel, perhaps involving 10,000 SKUs. Common sense tells us that it must be acceptable for garment manufacturer to rely upon the zipper manufacturer to certify compliance on all of its zippers, rather than to needlessly require the zipper and each other of the multiple components used in various garments to be tested 10,000 times because it is used in 10,000 different garments. Absent clear guidance to the contrary the statutory language could be interpreted to mandate 10,000 different tests. These are the types of practical problems that manufacturers, importers and retailers face and that have enormous cost implications at a time when we are faced with the deepest economic recession in decades. Testing costs, in turn, will be passed on to consumers.”

This petition provides more examples like this pertaining to jewelry, shoes, paper products, books and more. We need answers and I hope this petition will aid in obtaining those answers. This petition is backed by the following organizations:

American Apparel & Footwear Association
Association of American Publishers
Book Manufacturers Institute, Inc.
Fashion Jewelry Trade Association
Juvenile Product Manufacturers Association
National Association of Manufacturers
National Association of Printing Ink Manufacturers
National Retail Federation
Retail Industry Leaders Association
Printing Industries of America
Specialty Graphic Imaging Association
Toy Industry Association

You can read the petition in it’s entirety here - Petition for Rulemaking under CPSIA Section 101

Special thanks to Kathleen from Fashion-Incubator for Tweeting the petition so that we could read it.

This entry was posted on Sunday, December 21st, 2008 at 12:36 am and is filed under Happy Panda. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.