Update 11/5/09: Thanks to some readers who have been following this closely and who broadcast their findings on Twitter, I’ve learned that on Nov. 3, the Consumer Safety Products Commission issued a Guidance Document that in part reads “The Commission intends to solicit further input … at a public workshop to be held with stakeholders and Commission staff on December 10 and 11, 2009 at the Commission headquarters in Bethesda, Maryland.” You can download the 12-page PDF here (it’s the first item under the “What’s New” header). I’m glad to see that the voice of small businesses will get a chance to be heard, and will keep you updated as new info arrives. —HG
The National NeedleArts Association (TNNA) recently sent a letter to members about how the U.S. Consumer Protection Safety Improvement Act (CPSIA) of October 2009 directly affects how the needlework and crafts industries sell their goods, particularly to children.
“We cannot suddenly say that our products are ‘not for use by children 12 and under’ and still try to teach children to knit, crochet, needlepoint and cross stitch,” states the letter, which was sent by TNNA’s five-member CPSIA committee. “We can’t say children 12 and under are only allowed to use certain tools but not others and still expect them to take needlearts seriously. We must involve ourselves and our businesses in the effort to amend this poorly written, misguided legislation and keep it from destroying our businesses.”
The committee urges industry professionals to download and view a PDF of the Statement of Policy: Testing and Certification of Lead Content in Children’s Products. As stated in the letter, the committee is concerned with the following:
- “Textiles (including yarn, fabrics and it sounds like needlepoint canvas, although not specifically named) have for the most part been exempted. While the list does not specifically include, it also does not specifically exclude metallic fibers. And while there is no metal in most metallic fibers, there are metallic fibers that contain aluminum, gold and silver – but without question no lead.”
- “Wood, paper and other cellulosic products have been exempted. This does not include finishes or paints put on wood.”
- “Printing inks with CMYK technology (this is what color laser printers use) have been exempted. Other inks have not been. Screen-printing has not been exempted; hand-painted canvases were not mentioned.”
- “Surgical steel, stainless steel and precious metals have been exempted. However, if a solder or other component is used, that is not exempted. Aluminum was not included on the list.”
- “The labeling requirements have been relaxed somewhat to allow manufacturers to create labels that are appropriate for their products. The CHA memo is not specific as to those requirements and this issue should be researched by those it affects before deciding on a label format.”
- “Phthalates are not discussed specifically in this memo. Phthalates are used to make plastics flexible and can be found in many products in needleart stores.”
Think about the metal tools, plastic accessories and other items you use — and sell — every day. As the letter points out, “Every manufacturer, distributor and shopowner will be held responsible if they are found to contain lead or phthalates above the acceptable levels. The testing that will be required on many of these items will substantially raise the prices. How many of the items you sell can tolerate a $1,500 testing fee for each production run? How much will that raise your price?”
The letter concludes by pointing out the obvious — no one wants to see any child or adult put at risk from dangerous contents in a toy or other item. But on the other hand, no one wants to see a responsible business put at risk from a narrow interpretation of this law. The committee asks for a call to action from members to contact local legislators and demand an amendment to this law that makes its interpretation less anti-business.
Even if you’re not a TNNA member, please voice your concerns. You can find out who your local Congressional representatives are by clicking here.