The Handmade Toy Alliance tries to take a moderate and reasonable approach toward reforming a law that is itself neither moderate nor reasonable. Its recommendations:
- 1. Component-based testing…
- 2. Exemptions from testing…
- 3. Harmonization with European Standards…
- 4. Exempt permanent batch labeling…
- 5. Revisit the retroactivity of the CPSIA…
3 Comments
Many of these are sound suggestions, especially the ones about harmonization with the EU standards and eliminating retroactivity, but I still think the best strategy is to repeal this law and start again. As Learning Resources Inc has noted, the paperwork for component testing would be a nightmare for any complex product (they break down the components of a relatively simple educational cash register – it’s staggering.) Another problem is that the CPSC’s exemptions and rulings are not and will not be binding on the 50 states’ attorneys general, so no one conducting interstate commerce will be able to rest easy.
There are interesting new articles in the Washington Post Health section: (http://www.washingtonpost.com/wp-dyn/content/article/2009/03/23/AR2009032301764.html) and in the Tampa Bay/St. Petersburg paper: http://www.tampabay.com/news/health/article985784.ece, both on books. Check out the comments for both – think they capture the sentiments of ordinary people when they learn about this law.
And what about the issue that 12 year olds are included in a purported solution for a problem that affects pre-schoolers?
And what about the incredibly stringent exemption requirements? The law as written is designed to make such exemptions virtually impossible to obtain, especially with the minimal staffing that Congress (not Nancy Nord, Congress) has yet to fund for expansion.
Start over.
Brilliant suggestion. Start over!