Letter to Moore: Jennifer of Chapter One Organics
March 22, 2009
Dear Commissioner Moore,
I am writing in response to the letter you wrote to Representative Dingell
that was posted to the CPSC website on March 20, 2009.
While I realize your letter was directed to Representative Dingell, I am
writing to share with you my concerns about your letter. I own an organic
cotton baby clothing business that is impacted by the CPSIA. Specifically
in this paragraph I am in disbelief at the way you address businesses
affected by CPSIA, “Congress has entrusted this agency with a large and
important mission. The passage of the CPSIA was a huge vote of confidence
for the agency and despite the hue and cry of some in the business community
who will never be happy with the closer scrutiny and accountability required
by the Act, it is a major accomplishment of the last Congress, and one that
your leadership was instrumental in achieving.”
As a business owner who cares about child safety and who is affected by this
new law I will tell you that I am opposed to CPSIA, but not for the reason
you have mentioned. CPSIA is deeply flawed as Ms. Nord and the CPSC staff
outlined in their comprehensive letter submitted to Representative Dingell
on March 20, 2009. As a business owner and mother, I am constantly
accountable for my actions. We manufacture products that have been tested
in which all of our components test well below 100 ppm but yet this law will
require me to test our product continually for lead. The CPSIA does not
differentiate among the size of business, the materials used, the
commodities, the industries, the accessibility of parts, and so on…the
list is rather endless.
The majority of us in the business community would like to see a smart law
that is focused on products that pose risks and the CPSIA is clearly not the
answer. We are seeing huge losses being reported by small and large
companies and it isn’t because their products are toxic, it is because the
law does not work.
It is astonishing to me that after six months of dealing with this, your
response to Representative Dingell’s questions didn’t even scratch the
surface of the issues regarding this law and instead seemed completely
politically driven. As a tax payer, I resent that you are unable to work as
a team with Ms. Nord. In the private sector we often have to work in
imperfect environments. If we don’t design, create, solve problems and
implement, we don’t produce products, money, or jobs.
Let me reassure you that I would not have spent the past four to five months
of my life and money to figure out why and how to comply with the CPSIA if I
were not accountable. We don’t mind complying with laws that work but the
CPSIA doesn’t work.
I would like to get back to what I was doing five months ago which was
building a business, creating a safe organic product, and employing women in
need. Furthermore, I would rather not be spending my time or money to
travel to Washington on April 1 for the Rally and Congressional Briefing
with my colleagues but, if I don’t, I may not have a business to continue
I mean no disrespect but I would truly appreciate it if you could put aside
your politics and not wait to realize that there are devastating
consequences to this law that aren’t in the name of safety and aren’t a
result of businesses not wanting to be accountable. If our businesses are
forced to wait for your world to be perfect, our citizens lose jobs and
businesses close their doors.
Thank you for your time.
Chapter One Organics, Inc.