The Consumer Product Safety Commission has formally requested comments on the Consumer Product Safety Improvement Act. (If you're new to this issue and are wondering why anyone would be commenting, read this post about German toy company Selecta stopping U.S. distribution of their toys and this post on steps you can take to save natural and handmade companies.) Specifically, the CPSC says they're looking for 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.

Answer them all or pick your favorite, and don't be afraid to do so from the perspective of a consumer, if that's your position in all this - this affects you as well, and you have every reason to comment! Download the PDF comment instructions and share your views with the agency before these laws go into effect.

[Via]

The word is out: The Consumer Product Safety Improvement Act has cast such a wide net that many small businesses and natural toy companies are threatened with financial ruin by testing requirements that need to be overhauled if they are to be applied to them at all. Livelihoods, work-at-home arrangements, and the availability of handmade and natural products for our children are at stake. Here are five things you can do today to help force Congress to address the mess they've made before the law goes into effect on February 10, 2009.

1. Familiarize yourself with needed reforms. The Handmade Toy Alliance has proposed the following reforms to the CPSIA:

• Exempt toys made or imported in quantities under 5,000 per year by companies making or importing less than 50,000 total items per year, as well as toys made entirely in the U.S. and other countries with a strong safety regimen of their own (Canada, EU), and pair this with mandatory registration by companies and random auditing with stiff penalties (the way the EU does it).


• Assume that natural materials (wood, wool, silk, bamboo, cotton, and uncoated textiles) and food-grade materials (wood finishes made from beeswax and certain oils) are lead- and phthalate-free, and don't require them to be tested.


• Allow manufacturers to accept third-party test results for raw materials, and require company testing of products based on manufacturing levels rather than specific time frames.


• Don't require batch labeling for small runs of products not made from molded plastic, and don't require manufacturing dates to be a part of any labeling, as small batch toys are costly to label in this way.

You can read their full proposal on the Handmade Toy Alliance's website.

2. Tell your local news outlets that this is a local story. Look up Etsy sellers in your city or town, then call your local TV station or newspaper, ask for a business reporter, and tell them that you could help them identify at least X number of sole proprietors in your community who are about to be driven out of business if the law isn't changed. If you have a locally-owned toy store that carries natural toys, mention this too - they'd be a great interview for the same story. Local news desks are overworked and understaffed; if you can connect the dots on a timely topic you will probably see a story.

3. Make some phone calls. Phone calls are better than form letters, and if you get the person on the phone you might actually get some useful information you can share with others through the grapevine. Here are four calls you should make:

• Call your current U.S. Representative. Republicans and Democrats claim to care about nurturing small businesses, but new testing requirements encompass product areas highly unlikely to pose a risk for newly-banned chemicals. The new law needs to clearly articulate feasible and logical standards for small businesses and companies that already meet international (EU) standards.Tell them how you feel about what will happen to many of the SAHM, small businesses, and natural companies that are already doing their due diligence to ensure product safety. Find out if they've been voted out or are still in for the next session; if they'll be replaced, ask by whom and if you can contact them at the same number. You can find out who yours is and how to contact them here.


• Call Nancy Nord. She's the acting head of the Consumer Product Safety Commission, and she needs to hear from you. To reach her, call 301-504-7923 and ask for her; if she's busy, leave a brief, polite, but firm message.


• Call the CPSC ombudsman's office. The number is 888-531-9070.


• Call your Senator. Tell them you aren't pleased with the way the House wrote this bill or the fact that the Senate passed it in its current form, and that it is in dire need of reform before it sinks small businesses under exorbitant testing costs for products that are made using natural materials. You can locate contact information for your Senator here. If they're being replaced, ask them how to get in touch with their successor.

4. Join the conversation. Find Twitterers discussing the matter by searching for the #CPSIA hashtag. Browse new blog posts about the CPSIA and point others to them by giving them a bump on whatever social sharing or bookmarking software you use. (Links for giving a bump to this article are at the foot of this post - if you like this info, help spread it around!)

5. Sign some petitions. We believe that petitions are among the least effective steps you can take - the less effort it takes to make your voice heard, the less seriously your effort is taken by those you hope to impact; and signature rates inevitably underrepresent the number of concerned citizens, often vastly so - but it can't hurt, so here's one petition and here's another.

I mentioned something in passing in our plastics conference call yesterday that I figured I'd better follow up on.

At ZRecs we have always maintained - both to concerned consumers and to companies making unsubstantiated claims about the safety of their products - that our goal as consumers and as a society should be to reduce our overall exposure levels to many chemicals, knowing that we will never completely eliminate them, at least not within our lifetimes. The production, use, and waste cycle of these products ensures that chemicals like these are present not only in a huge array of products, but in our environment as well. It is quite likely, for example, that there is some (very small) amount of BPA in your tap water.

Another example, and one most people aren't yet aware of, is paper products. The one I mentioned specifically on the call was toilet paper.

As it turns out (post-call research on my part) the source of BPA in toilet paper appears not to be that it is added deliberately to the product, but that a lot of toilet paper is made from post-consumer sources that include lots of recycled thermal printing paper (credit card receipts). Dresden University did a study examining BPA turning up in wastewater streams and traced it back to toilet paper as the culprit. We first learned about this study here and here.

Environmental regulators consider sources like this disconcerting because endocrine-disrupting chemicals like BPA and phthalates can wreak havoc on marine ecosystems. Ultimately, it's sources like these that are the reason you probably have BPA (at extremely low concentrations) in your tap water, too.

The same thing goes for other kinds of recycled paper, too. When we add up all of the sources we now know of, BPA can be found at smaller levels, and less clear exposure levels, than the children's products we have been talking about for some time. These products include:

• Credit card receipts


• Recycled cardboard pizza boxes and paper


• Beer and wine (vats are lined with a BPA-containing resin)


• Rubbermaid polycarbonate-lined baking tins used by Subway


• Soda cans and food cans


• Baby food jars (lids) and formula packaging (metal cans, glass jar lids, and paper packaging foil seals)


• Many non-polycarbonate plastics (including the color-changing plastics used by Sassy and others), in addition to PC

Consumer advocates and reporters like us often avoid raising topics like this for a few, closely-related reasons:

1. Consumers often have difficulty managing their feelings about a given chemical, and think in terms of eliminating individual ones rather than chipping away at the overall chemical load of known harmful substances.


2. We believe not all sources are created equal. BPA is found in many of these products at extremely low levels. Most of these also expose us to BPA in far less obvious ways, if at all, and more research is needed on the dose/effect relationship of different levels of BPA and other endocrine disruptors.


3. We don't want people to feel powerless, or like the changes they make don't make a difference, because, to the best of our understanding of an emerging area of scientific scrutiny, they do make a big difference.

That said, we consider toilet paper to be a specific source of concern, for reasons a polite blogger should probably avoid getting into. Suffice to say that exposure is certain and frequent.

I also mentioned on the call that I don't believe there is currently enough scientific data to warrant fears about melamine tableware, or about chemicals leaching from #1, #2, and #5 plastics. A few isolated studies and alerts have come out on each of these but we believe a lot more rigorous data collection is needed before calling for any changes to regulation or to consumer habits. We may post more specifically about this if there is interest, or wait until we see more data and do so then.

I also discussed how our ability to test for these chemicals at lower and lower levels is steadily advancing, and that the scientific and regulatory community is going to face some challenging questions regarding what constitute acceptable levels of different chemicals. We'll write about that again in a future post.

I'll be participating in a panel discussion and open conference call on Thursday to discuss plastics safety. It's hosted by Healthy Child, Healthy World, and here's the description of the event from HCHW's blog:

Join us for an open, non-judgmental conversation about plastics (we all have our Achilles’ Heel). Janelle from Healthy Child Healthy World will be giving a quick background on the issue; Jennifer from The Smart Mama will share her Journey to Glass; Jeremiah from ZRecs will talk about assessing the risks and benefits of plastics, and how bloggers can influence corporate behavior and affect change in the marketplace; and Beth from Fake Plastic Fish will discuss the impacts on the environment and living without.

You're welcome to join us, because after we each talk for a bit we're going to focus on questions and discussion points from whoever is on the line. A few words of advice:

• DON'T call in and ask me about the safety of a particular bottle, bath toy, or other item you do or don't see in the ZRecs Guide. You will get a blank stare, and blank stares translate very poorly via phone.


• DO call in and ask me about whatever else you want relating to plastics - thoughts on a particular plastic type, recent issues in the news, mainstream media coverage of a plastics issue, or about a position we've taken, or haven't taken, here on Z Recommends. I like being grilled.

I'm going to spend the time I have the floor talking about what I believe the precautionary principle should mean when it comes to plastics in our daily lives, and about how bloggers can make companies change by doing research and reporting. Others on the panel know a thing or two about this, so I'm hoping we all get to do some serious dialoguing. Yep, not a real word.

You can call in at 10 a.m. PT/1 p.m. ET at (218) 339-3600, then punch the access code 1036416 to get in on the conference call. And if you call in and ask a question, mention you're a reader and what your name is. I'd love to put a voice to a name!