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CPSIA – Tell me What You Think

With the CPSIA Amendment (ECADA) stalled for the moment, it’s a good time to reflect on where we are. I want to know what you think. As I see it, this is a case of the unstoppable force colliding with the immovable object. Guess where we are located? At the point of collision. On one side, you have the Republicans. They have always decently listened to our issues and tried to help. Only after the 2010 Midterm elections were they in a position to get things done. With the power of the House majority behind them today, they have taken the political risk and shown the political will to craft a reasonable, measured and, frankly, surgical amendment of the acknowledged defective CPSIA. Interesting sidelight : The legislative dynamic in Congress in 2008 seems long-forgotten. At that time, the Dems controlled both Houses and the dominant player was San Francisco’s own Nancy Pelosi. The CPSIA was negotiated during a time when she and her minions ran the show. True, there was a Republican President BUT owing to the media frenzy at the time, no one was willing to take the political risk of asking any questions. Congressional hearings were controlled by the Dems in both Houses and stage-managed them to achieve the right “tone”. Behind the scenes, the legislative negotiations between the parties at that time are best described as stiff-arms. The Republicans were jammed on many of the worst anti-business terms in the CPSIA and the sting never went away. This may be why they are so sympathetic to our cause today. Please keep this in mind when the consumer groups and the Dems cluck about the 2008 super-majority, bipartisan vote on the original bill. In fact, the Repbulicans would tell you that they had no choice. Sounds convenient, perhaps, but if you talk to them, you will quickly see that they really mean it. On the other side of this collision are the unscrupulous consumer groups and the Dems. This cabal works together for political advantage. The Dems, led by Henry Waxamn, see that they can use ECADA to score political points. They know that the Republicans don’t want consumer groups to send out letters to their constituents saying that the incumbent voted to endanger children with lead in toys. I know it’s sick, but that’s reality in Washington. This may give you some perspective on why people say Washington is “broken”. It is. The Dems want to score points against the Republicans, and the fact that we are being squished in the process is a cost they are willing to bear. Get it, your demise is a cost they are willing to bear, all for the “greater good” of politically endangering the Republicans. Remember, Members of the House are continually running for office. It takes true courage to do the right thing when you are exposed to Machievellian forces like Mr. Waxman and his merry band of manipulators. For this reason, I am fairly pessimistic about the prospects of this law. You get the same sinking feeling watching the talking heads on CNBC discuss the deficit and war over the national debt limit and hearing our national leaders talk blandly about the consequences of default on U.S. Treasuries. No big deal . . . . The politicians are playing with our lives, but act as though it is some of kabuki theater, Model UN gone mad. Do you think they are looking for a good grade, rather than doing the right thing for America? I rule out that the Dems are totally ignorant of science. I rule out that they don’t understand the data on injuries or what it means for their law. I think they simply don’t care about these things. Their profession is politics, and all that matters is the taste left the mouths of voters. A bill easing up on businesses over lead in children’s products has political weaknesses that the Dems prefer to exploit. The needs of our community are a secondary consideration. A distant second, too. So . . . what do you think? What do you recommend in this hot stove league? Can we do anything about this tragi-comedy, can we save products, companies, markets and jobs before the consequences of inaction suffocates them all out of existence? Let me know. Thanks.

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CPSIA – Tell me What You Think

CPSIA – ECADA Mark-up DELAYED

The mark-up of the long-awaited CPSIA Amendment (ECADA) has been postponed by the House Committee on Energy and Commerce until after Memorial Day. There was purported a time conflict issue with business pending before the committee. This gives time for the two sides to work to a resolution of their differences. It being Washington, however, don’t hold your breath. The Dems continue to be under Mr. Waxman’s thumb and there is no telling what will dislodge that pressure.

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CPSIA – ECADA Mark-up DELAYED

CPSIA – Dem CPSC Commissioners Shamefully Protest ECADA

In yet another display of partisanship and, frankly, SCIENTIFIC IGNORANCE, the three Democratic CPSC Commissioners issued a harshly-worded warning over passage of the pending CPSIA Amendment (ECADA).  While I dimly recall Inez Tenenbaum pledging early in her CPSC career to be a force for cohesion on the Commission, all pretenses of bipartisanship have been dropped by the Dem Commissioners nowadays.  This latest letter-in-tandem mocks the notion that the Commission is capable of working together.  The letter further casts doubt on the Dem Commissioners’ ability to process scientific information or manage scientific processes.  These people control a federal regulatory agency.   This is YOUR government at work . The Dem letter came on the same day as the latest volley from the desperate consumer groups (CFA, Consumers Union and the like).  As in their past missives, this letter twists facts, avoids truths and presents the fully misleading impression that the Republican majority are in the process of trashing the very structure of safety administration in this country.  Be still my heart, it’s not true, unfortunately.  You’d never know it from them. Perhaps the two letters have the same author, who knows?  Anyhow, here’s a few comments on the Commissioners’ letter: a.  “The current draft of ECADA fails to adequately protect the health and safety of American children. . . .” RW – The Commissioners do not back up this outrageous assertion but notice that it lingers in the air. The three Dems on the Commission, including the Chairman, are accusing the Republicans of harming children.  Pretty serious charge, right?  So . . . can they show with injury statistics or case histories that the extremely modest changes being made by ECADA are linked to injuries?  No, they CANNOT.  So . . . can they prove that the presence of lead-in-substrate at ANY level has EVER been associated with childhood injury from interaction with children’s products?  If they could, that might provide support for the purported NEED for the standards they so staunchly defend.  No, they CANNOT. I don’t know how we can accept this kind of behavior from people appointed to positions so high up in our government. b.   “ECADA Rolls Back Marketplace Progress on Lead”. RW – Note the cute wording of this warning.  You have to read it carefully to get the point they are making.  They say that this amendment changes how the marketplace will deal with lead.  Yes, Adler and Co. are talking about “dosing” again.  Remember the howler they sent in April accusing manufacturers of a desire to increase the “doses” of lead inflicted on children.  Frankly, that offense has never been remedied.  At the time, people associated with the House Subcommittee mumbled about calling the three Commissioners in to defend their ridiculous and slanderous accusation but it never happened.  Here it is, again.  It’s an outrage. The Dem Commissioners go further into obfuscation-land when they refer to a “recent Commission hearing” on the feasibility of implementing the 100 ppm lead-in-substrate standard.  Ummm, I was on the third panel in that hearing, I gave testimony, too.  The Commissioners tell about SGS testimony that out of nearly 90,000 tests performed by the lab, an inspiring 96.29% of metal components were under 100 ppm.  Cool!  Sounds like a slam dunk, right?  Well, perhaps the selective memory Dem Commissioners may recall that I gave SIMILAR testimony, indicating that our company data shows that 1.7% of our tests (46 out of 2701 recent passing tests) fall between 100 ppm and 300 ppm lead-in-substrate BUT we cannot predict which parts or products will be affected.  In other words, it’s random and uncontrollable.  I also gave this same testimony in writing as part of my comments on the 100 ppm standard. This has very dramatic implications for our costs and the predictability (financability) of our results – the Commissioners heard me and they know this.  You’d never know it, however. It’s worth noting further that the CPSC requested my presence at this hearing.  They called me and asked me to spend my own money to fly to Washington to testify on this subject.  Do you think this means they wanted to hear what I had to say . . . so they could ignore it??? The Commissioners go on to shriek about the “large exception” for metal component parts in “outdoor recreational products”.  Whoa, scary – right?!  In fact, maybe not.  If the Dems were paying attention, they would realize that ECADA simply codifies THEIR OWN WORK – the standards applied to metal are from a stay the Commission itself approved for metal components in February 2009.  Perhaps the Commissioners should read this Federal Register notice to bone up.  I guess having approved literally thousands of pages of rules and whatnot relating to the CPSIA, the Commissioners can be forgiven for not remembering their own work.  Ouch! The Dem Commissioners may be on a mission and play a bit fast and loose with truth and accuracy . . . but when they say “ECADA would allow more lead back into our children’s products”, it must be considered a LIE made by knowing people.  There is ABSOLUTELY no support for this statement and their pathetic arguments are paper-thin and obviously fallacious.  Perhaps they think we are all stupes and will believe whatever they put on paper. THESE PEOPLE ARE PUBLIC SERVANTS.  THIS STANDARD OF SERVICE IS UNACCEPTABLE.  IF CONGRESS WON’T FIX THE LAW, THEY SHOULD CONSIDER DE-FUNDING THIS AGENCY UNTIL IT STOPS ITS ROGUE ACTIVITIES.  MR. WAXMAN ISN’T CALLING THE SHOTS ANYMORE.  MR. BOEHNER, PLEASE HELP ME. c.  The Dems protest the curtail of mandatory testing, without acknowledging that the standards will still be in force and enforceable.  How will manufacturers know they are in compliance?  Duh, they will test.  The Dems know this.  Still, they intone:  “Unfortunately, this proposal will take us back to the days of not knowing what is in a children’s product – and discovering dangers only after untold numbers of children are exposed to risks of harm”.  Perhaps, perhaps.  But don’t you think we should evaluate this claim of the prospect of future loss by looking at past losses?  Oh no, can’t do that because the advocates cannot produce any victims.  Hmmm. Perhaps more disgusting is to receive a letter dated May 25, 2011 with this little sugar plum in it:  “We have previously acknowledged the need for some targeted relief from the third-party testing requirements of CPSIA for small crafters and small businesses . . . .”  These guys are so great, they really FEEL our pain.  Sadly, busy as they are, they have not gotten around to developing this relief since the law passed in August 2008, three years ago.  That said, I bet it’s on their “to do” list! d.  The Dems point to a provision in ECADA that they allege “would allow child care centers to provide extremely old cribs that do not meet the new safety standard for our most vulnerable population”.  Again, the words used are intended to cloak the Commissioners in white and place black hats on Republicans pushing for ECADA.  In my view, that’s very very misleading.  As far as I can tell, they refer to Section 5(b) of ECADA .  Why not read it yourself and see if you agree with them or with me? e.  It’s late at night and I have a flight in a few hours, so I am not going to waste much time on their absurd protestations on the public database.  Blah blah blah. Apparently, they deem it essential that you be able to read stuff like this: Gas Grate Cleaner   36 yo man thought that he was making iced tea and poured powder from the container of Elco Gas Grate Cleaner. when he tasted it he realized that it was not tea, felt burning in his throat and went to the hospital emergency room. he was admitted overnight and discharged in the morning. NOTE TO SELF:   Don’t make tea out of grate cleaner. Happy Harvest Canned goods    Happy Harvest canned goods which contain corn, peas, mixed vegetables sold by Aldi have a can design that is not stackable. Both sides of the can are made equally making it impossible to stack on top of eachother such as other cans are able to do. . . . When one can is moved where they are stacked closely to each other, it creates a chain reaction and most of the cans fall.  This was the case today when my wife was retrieving something from the pantry and my fifteen month old daughter followed her in. When my wife moved an item, two Happy Harvest cans fell and one of them struck my daughter on her head causing a big bump. It could have been a lot worse. This is very unsafe as the stacking of cans become unstable and can fall at anytime. My daughter was the victim of this poor can design. [Emphasis added] NOTE TO CPSC:   A mandatory safety standard for can stacking is long overdue.  Who knows how many 15 month old toddlers are at risk because you are sleeping on the job – get to work! RW – My sources tell me that the Dems are not going to support ECADA – none of them.  This is utterly irrational but is also consistent with their past practice of travelling in a pack and blindly supporting the consumer groups.  You, the taxpayer, are the big loser at the Dems’ hand.  They have heard you . . . for three years-plus . . . and just DON’T CARE.  They just DON’T CARE about your petty problems, and more profoundly, are not curious or even mildly interested in rational, data-driven criticisms of the basis of the CPSIA.  Anything that reflects badly on their consumer group allies may safely be ignored. If the Dems stand their ground and don’t pass ECADA with bipartisan support, there is a distinct possibility that the Senate will not act at all on this CPSIA amendment.  In other words, this terrible law is likely to stand pat without amendment. That’s your government at work.  I am going to give some more money to Republicans myself.

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CPSIA – Dem CPSC Commissioners Shamefully Protest ECADA

CPSIA – AAP’s Campaign of Lies on CPSIA Amendment (ECADA) Continues

Not quite out of town yet, Cindy Pelligrini and her AAP associate have promulgated another letter today with more lies and misstatements about lead and the CPSIA. It is worth observing that there is no doubt, and never has been any doubt, that lead is a neurotoxin and is capable to harming children.  I think that’s a given.  The AAP letter gives considerable air time to remaking this point over and over again.  Got it, thanks.  What the AAP cannot do, and never has done, is prove a LINK between the presence of lead-in-substrate in children’s products (shoes, educational products, books, ATVs, pens, bikes, t-shirts, shoes and so on) with actual injuries.  Nada, nothing.  Instead, they emphasize the “danger”, sometimes lapsing into fantastic arguments calculating “losses” based on assumed and undocumented injuries, but NEVER do they address the subject of causation or nexus. A good example of AAP tall tales is from their May 11 letter: “The potential impact of lead in children’s products is real.  For example, in 2007 and 2008, over 9.8 million pieces of children’s toy jewelry were recalled for excessive levels of lead.  If just one-half of one percent of these items caused lead exposure in a child, 49,000 children would have been affected.  If each of those children lost one IQ point – which can occur at levels of exposure below 100 parts per million – the economic burden of that lead exposure would be at least $409 million just in lost lifetime income. Health economists estimate that every time average blood lead level increases by a small amount across the children born in any given year, $7.5 billion is lost in potential earnings for those children.” But the AAP cannot deliver up even one such victim.  All such calculations are therefore pure fantasy.  Or should I say pure ignominy? Today’s letter is no better.  See below with my annotations in red .: May 24, 2011 The Honorable Fred Upton Chairman Committee on Energy and Commerce U.S. House of Representatives Washington, DC 20515 The Honorable Mary Bono Mack Chairwoman Subcommittee on Commerce, Manufacturing and Trade U.S. House of Representatives Washington, DC 20515 Dear Chairman Upton and Chairwoman Bono Mack: As experts in the field of pediatrics, environmental health, and toxics, we would like to express our deep concern over the consideration of legislation that would have the effect of permitting more lead in toys and children’s products. [ This is a LIE - ECADA does not permit "more lead in toys and children's products".] Lead is a potent toxicant that can have a range of adverse effects on children’s brains and bodies. Low lead levels cause a wide array of negative effects, including cognitive, motor, behavioral, and physical harm. Even at very low levels, lead has been demonstrated to cause the loss of IQ points in children. [ AAP citations call into question cause and effect, noting the many factors involved including self-selection.] Children with elevated blood lead levels are more likely to experience attention deficit and reading disabilities, and to fail to graduate from high school.  [They are also more likely to live in poverty, in older housing, in inner cities and eat paint chips.]  Researchers have identified associations between lead exposure and increased aggression, commission of crime and antisocial or delinquent behaviors.  [Ditto]  Other effects include abnormal balance, poor eye-hand coordination, longer reaction times, and sleep disturbances. At high levels, lead can be fatal. [Can the AAP show me an example of ONE CHILD who died or was injured from lead-in-substrate EVER?  Apparently not - four Congressman tried to get the same information during the April 7th House hearing without success.]  Lead accumulates in the human body and is stored in the bone, so multiple low-level doses can quickly result in harmful levels. For all of these reasons, our nation has for decades pursued a multi-faceted strategy of reducing children’s exposure to lead from all sources, including air, paint, soil, food, water, and the full range of consumer products. [The AAP cites a CDC publication  in their May 11 letter on lead in which the CDC points to lead in paint, interior dust, exterior dust and dirt and lead in tap water.]  To date, science has not been able to identify any safe level of lead exposure for children. In 2008, Congress passed legislation that recognized the devastating effects of lead on children’s health and strictly limited lead content in toys and other children’s products. The Consumer Product Safety improvement Act protected children up to the age of 12, thereby covering the full period in which the vast majority of children will experience both rapid brain growth and the behaviors that increase lead exposure. [Human factors experts at the CPSC have long acknowledged that mouthing behavior ends at about age three.  Mouthing behavior over age three is unusual and considered age-inappropriate, meaning that it is the responsibility of parents and caretakers to monitor and manage such behaviors to the extent they occur.]  The law also phased in limits on lead content, with the final stage of that limit scheduled to take effect this August. That restriction of no more than 100 parts per million of lead in children’s products is expected to all but eliminate the possibility that exposure to a single product could cause the loss of one IQ point. [The AAP's assertion that there is a "possibility" of a loss of an IQ point from an interaction with lead-in-substrate in a children's product is purely conjectural and without basis in fact.  Their persistence in advancing this argument without proof must be considered evidence of an intent to deceive.]   These provisions represent critically important protections for children’s health and are a vital component of a comprehensive strategy to reduce lead exposure from all sources. [Interestingly, neither the CDC nor the EPA take this position.  In fact, the EPA notes:  "First and foremost, the Agency faces the difficulty of determining the level at which to set the standards given the uncertainties in information on cause and effect --what environmental levels in which specific medium may actually cause particular blood lead levels that are associated with adverse health effects. The Agency has tools, which are only generally consistent, that show that certain increases in environmental lead levels are associated with certain increases in blood lead levels. Given the range of uncertainty shown in its analysis supporting the establishment of a hazard level under this rule, EPA has developed a technical analysis that considers hazard standards for dust and soil at the lowest levels at which the analysis shows that across-the-board abatement on a national level could be justified. EPA recognizes, however that for any levels of lead in dust or soil judgment must be exercised as to how to treat the medium, and interim controls as well as abatement could be effective . . . . Thus, if EPA were to choose standards that are too low, the public could be unable to distinguish between trivial risks at the low levels of lead from the more serious risks at higher levels. This could result in clean up for little to no health benefit, or conversely, it could result in almost no clean up because persons would question the credibility of the ‘hazard' determination."] Given the extreme difficulty or impossibility of eliminating children’s exposure to lead in our air, soil, water and food, it becomes even more imperative to limit lead from those exposures we can control, such as children’s products. [Having never provided any nexus between trace levels of bound-in, insoluble lead-in-substrate in children's products and any known health risk, this sentence is either a lie or intentionally misleading.  The AAP could resolve all such matters in its favor if it ever proved its case.  Over the past four years, it has failed to do so.]  We urge you to maintain strict limits on lead in all parts of toys and products meant for children up to the age of 12 years. Signed by 100 “experts”

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CPSIA – AAP’s Campaign of Lies on CPSIA Amendment (ECADA) Continues

CPSIA – ECADA Manager’s Amendment

Here is the Manager’s amendment to the CPSIA Amendment (ECADA).  [Essentially changes offered by Mary Bono Mack.] The changes apparently include changes in lead in jewelry (age limits), removal of testing requirement for inaccessible components for phthalates, removing toys from outdoor recreational products and adding “class of products” to functional purpose exclusion process.

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CPSIA – ECADA Manager’s Amendment

CPSIA – ECADA (CPSIA Amendment) Full House Committee Mark-up Tomorrow

Representative Mary Bono-Mack introduced the CPSIA Amendment (ECADA) yesterday.  The bill is known as H.R. 1939  and was co-sponsored by Fred Upton, Chairman of the House Committee on Energy and Commerce.  The mark-up will begin at 4 PM EST on May 25 with opening statements.  The vote on the bill is likely to occur on Thursday at 10 AM EST. The majority staff memo supporting the bill can be found here . Fingers crossed!  We need the poker game to end with bipartisan support for sensible reform of a misconceived bill that has damaged uncountable companies and marketplaces.  Safety is NOT a zero sum game.  Mr. Waxman must table the issue and let this bill move forward with his support.

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CPSIA – ECADA (CPSIA Amendment) Full House Committee Mark-up Tomorrow

CPSIA – A Malefactor Exits Stage Right

In the sad, pathetic CPSIA saga, several players have taken up their chips and moved on.  Some, like David Strickland, found other industries to prey upon and destroy (good job with Toyota!).  Others have just disappeared in the mist. I have not heralded the departure of Congressional staff who have played a role in ruining our businesses – they were just doing their jobs, if incompetently. But now one of the true movers and shakers behind the CPSIA has chosen to find other things to do.  And I am speaking of the notorious Cindy Pelligrini of the American Academy of Pediatrics.  Cindy’s last day to create havoc at the AAP is June 3rd; after that, she takes her act over to the March of Dimes.  [What is the lead content in dimes anyhow?]  Cindy deserves special mention, right up there with the Queen Bee herself Rachel Weintraub, as responsible for the mess we all find ourselves in. I have discussed Ms. Pelligrini in this space numerous in the past.  -  Here is Cindy Pelligrini ghosting federal testimony and intercepting questions for its purported author, the estimable Dr. Dana Best.  Dr. Best is a real live doctor.  Ms. Pelligrini told me she holds a degree in political science. .  . .  -  Here is Cindy Pelligrini arguing against risk assessment because it would be too BURDENSOME on the CPSC .  I practically weep over her compassion for the regulators!  She also is the one who promoted the notion of background “contamination” of lead at 40 ppm (as if the presence of a naturally-occurring element is contamination), lower than the lead content of the dirt in Mr. Obama’s garden.  [ Ibid .]  -  Here’s Cindy Pelligrini and the AAP misquoting or misstating the data from their own cited sources on lead poisoning .  I guess the truth is what you make of it.  -  Here is Cindy Pelligrini admitting that she is using the CPSIA strictures to achieve a different end that has nothing to do with lead poisoning , namely the tacit ban of youth model ATVs.   Is manipulation and distortion less offensive if you brazenly admit it? Wow, that’s a hard act to follow!  The pressure’s on Rachel now . . . . As a fitting tribute to Ms. Pelligrini, I offer up quotes from scholarly articles cited in a May 11, 2011 lead scare email she authored with an AAP associate. Most of the citations were not provided with links, perhaps to make this exercise more difficult.  Sorry, Cindy, I cracked the code!  Here are a few nuggets: a.    “Multivariable analysis indicated that residence in older housing, poverty, age, and being non-Hispanic black are still major risk factors for higher lead levels. . . . Risk of lead exposure by year housing built defined as follows . . . 1999–2004: low risk, built 1978 and later; medium risk, built between 1950 and 1977; high risk, built before 1950.”   Jones RL, Homa DM, Meyer PA, Brody DJ, Caldwell KL, Pirkle JL, Brown MJ. Trends in Blood Lead Levels and Blood Lead Testing Among US Children Aged 1 to 5 Years, 1988–2004 . Pediatrics, Mar 2009; 123: e376 – e385.  [Apparently, old homes come equipped with children's products with dangerously high lead content.  How could there be any other possible explanation for this data?!] b.    “CDC is conducting several activities to focus efforts on preventing lead exposures to children. First, beginning in 2003, CDC required state and local health departments receiving funding for lead poisoning prevention activities to develop and implement strategic childhood lead poisoning elimination plans. Second, CDC and its federal partners, the Department of Housing and Urban Development and the Environmental Protection Agency, launched new initiatives to control leadbased paint hazards in the highest risk housing, addressing where successive cases of lead poisoning have been identified. Third, CDC and other federal agencies are developing a systematic and coordinated response to identify and eliminate nonpaint sources of exposure (e.g., lead jewelry, food and traditional medicines, and cosmetics). . . . The most common high-dose sources of lead exposure for U. S. children are lead-based paint and lead-contaminated house dust and soil.” Advisory Committee on Childhood Lead Poisoning Prevention.  Preventing Lead Poisoning in Young Children.  A Statement by the Centers for Disease Control and Prevention .  August 2005.   [What, no reference to children's products?!  Does the CDC know what it's doing?  Come on, there's no safe level for lead . . . .] c.  See my blogpost of May 11 for an analysis of this article. Self-selecting factors may explain the data on lead poisoning, not the hazard itself.  Hmmm.   Chen A, Dietrich KN, Ware JH, Radcliffe J, Rogan WJ. IQ and blood lead from 2 to 7 years of age: are the effects in older children the residual of high blood lead concentrations in 2-year-olds? Environ Health Perspect. 2005;113(5):597-601. d.     “Lead can be found in high concentrations in three media to which children may be directly or indirectly exposed: paint, interior dust, and exterior soil or dust. This section discusses the distribution of lead in these media and their relationships to one another and to blood lead levels (BLLs) in children (Figure 2.1). Lead in tap water, generally a lower dose source of exposure, is also addressed.” Centers for Disease Control and Prevention. Managing Elevated Blood Lead Levels Among Young Children: Recommendations from the Advisory Committee on Childhood Lead Poisoning Prevention . Atlanta, GA: Centers for Disease Control and Prevention.; 2002.  [Again, the CDC screws up - no apparent awareness of the plague of contaminated children's products.  So dopey, good thing we have the AAP and CFA to ensure that the 100 ppm lead standard is imposed on lead-in-substrate in children's products.  It's a mere detail that no one has EVER produced a single victim of lead poisoning linked to lead-in-substrate in any jurisdiction at any time anywhere in the world.] e.  Article discussing the later consequences of lead poisoning. Does not discuss sources of lead poisoning. “Residual and unmeasured confounding are always of concern in observational studies where all possible covariates cannot be assessed and those available are not measured with equal precision. . . . The inclusion of neuropsychological variables examined in this sample such as measures of executive functioning, attention, and IQ may have amplified the predictive vigor of the models. . . . The possibility that early exposure to Pb may lead to a higher risk of antisocial behavior in later life through its effects on neuropsychological functions is interesting and will be the subject of future analyses of these data. Variables independently associated with measures of antisocial behavior included maternal intelligence and lower birth weight. The association with lower parental IQ was not unexpected and a few studies suggest that delinquency is related to medical complications at birth.”   Dietrich KN, Ris MD, Succop PA, Berger OG, Bornschein RL. Early exposure to lead and juvenile delinquency. Neurotoxicol Teratol. Nov-Dec 2001;23(6):511-518 [Emphasis added] [In other words, lead might explain the social dysfunction of some kids. Then again, so might many other uncontrollable variables well-beyond the ability of this study to analyze or even detect. Clear as mud . . . .] f. A classic “garbage in, garbage out” study, this article argues that a loss of an IQ point results in a corresponding loss of about 0.1 years of schooling. If, however, you note the conclusions or suspicions in the article referenced above in par. c above, you may conclude there may well be other factors at play, such as family income or poverty, age of housing, neighborhood setting, other family dynamics (such as educational background), and the basic intelligence of the kids affected by lead poisoning. Kids presenting as lead poisoned may be the least likely kids to be successful in school for other reasons separate from lead poisoning – in other words, lead poisoning might be a symptom of a larger problem, not the problem itself. The article does not sonsider this possibility. Salkever D. Updated Estimates of Earnings Benefits from Reduced Exposure of Children to Environmental Lead. Environmental Research , 70:1-6: 1995. I could go on and on – Ms. Pelligrini and her associate provide bundles of citations all making similar points. Ms. Pelligrini leaves behind a record replete with misleading conclusions and head fakes. In the process, she accomplished little for kids but managed to ruin many businesses, drive entrepreneurs into other markets, kill jobs and eliminate valued products that kids, families and schools needed and wanted. She had a willing accomplice in the Dems who employ populism to get reelected. Damn the science, we need to make kids safer . . . even if we have no idea what that means! As I noted earlier this year, Walter Lippmann, founding editor of The New Republic and winner of the Presidential Medal of Freedom1964, once cited the components of wartime mythmaking as “the casual fact, the creative imagination, the will to believe, and out of these three elements, a counterfeit of reality.” Counterfeit of reality, that’s our Cindy. Cindy, we’ll miss you! Not.

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CPSIA – A Malefactor Exits Stage Right

CPSIA – The State of Illinois PAYS People to Do This

I live in a magical state.  Actually, a magical State – the State of Illinois.  Howdya like to have our balance sheet?  My State of residence owes $45 Billion in borrowings (up from $12 Billion in 2002), has $140 Billion in unfunded pension and retiree health care benefits, is behind on payment of $8 Billion in bills (despite raising personal income tax rates by 66% this year, and is likely to run a multi-billion dollar deficit this year again.  We have the second worst credit rating among the 50 States.  Slow on the uptake or just magical?  Ask California – they’re the only place worse than us.  We owe $8 Billion in unpaid bills – gag, this is civic humiliation. And how is our wonderful State, the Land of Lincoln, spending its precious few resources these days?  Well, a top priority is the lead labeling law.  Ah, that old chestnut!  Apparently, the scourge of lead has not been sufficiently snuffed out in Illinois.  The absence of injuries, the sharp drop in recalls, the asphyxiating federal requirements are all inadequate around here to keep kids “safe”.  Our civic leaders have already put in place the toughest and most unreasonable lead labeling law in the country, out Proposition 65′ing even the real Proposition 65.  Never content to leave “well enough” alone, they are going back to the well. So our paid public servants with apparently very little to do have chosen to revise AND TIGHTEN the Illinois lead labeling law.  See the attached working draft for your amusement (or nausea).  They are extending it to all coatings – get your tests a-ready! – and have added a notation in the “warning” label to indicate that the product actually complies with federal standards.  Yes, the ultimate mixed message – dangerous yet safe, all at the same time! – consumers will no doubt appreciate this extra effort by regulators.  The law is now much more complex and impenetrable, too.  Lucky us. And why did the estimable Lisa Madigan, our Attorney General, demand this change in law?  Gotta get elected right?  If kids aren’t made safer every day, whether science is involved or not, who needs the AG’s office?  No injuries motivated this change, just a basic lack of understanding of science and a passionate need to deceive the public. Lisa Madigan’s paycheck is among the bills that Illinois pays promptly, by the way.  My tax refund isn’t on the same list of priorities. Welcome to the Land of Lunkheads.  Illinois, you shining star!

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CPSIA – The State of Illinois PAYS People to Do This

CPSIA – CPSIA Amendment (ECADA) Mark-up Expected This Week

Rumorville has it that the mark-up of the CPSIA Amendment (ECADA) is due to occur this week at the full House Committee on Energy and Commerce this week.  The Dems continue to play a game of poker with our livelihoods over the CPSIA, which is apparently how things are done in Washington.  The mark-up is where the bluffs will be called.  Fingers crossed . . . . Despite our having made rational arguments for amendment of this law for almost three years now and presented bundles of data and evidence to support our pleas, the Dems continue to hold out, claiming that the meager changes to the CPSIA effected in ECADA will “endanger” children.  This pathetic reasoning is based on a ” zero sum ” analysis which holds that anything making life easier for businesses must necessarily endanger children.  In other words, safety is a “zero sum” game in which gains earned by one side must come out of the pocket of another.  Some kinds of negotiations are in fact “zero sum” games – like the negotiations over the price of a house.  If the buyer wins a $1,000 price concession, the seller gets $1,000 less.  Zero sum. Not all negotiations are zero sum, however.  If a customer asks me to deliver 1,000 units in 30 days, and I can deliver the units today (because I have them in hand), I lose nothing but the buyer gains. This is NOT “zero sum”. There are many such examples.  This kind of value-added change where one party gains but no one loses is known as a ” Pareto Improvement “.  Skilled negotiators look for opportunities for Pareto Improvements as a way to close gaps or to make any negotiation more valuable to the parties.  This option has been ruled out by smallmindedness among consumer groups who depends on favors from Dems to stay in this game. The notion that easing up on the lead-in-substrate rules or the excessive testing rules will necessarily endanger children is both offensive and ignorant.  First of all, this argument depends on allocation of the moral higher ground exclusively to the consumer groups and CPSIA zealots.  Please, spare me.  We in the children’s products industry have devoted our working lives to serving children and have as powerful a claim to making kids’ lives better as any consumer group.  I do not accept that consumer groups have greater integrity or are more virtuous than companies spending their own money and devoting their days and nights creating products to make kids lives better.  They can’t gain the higher ground simply by patting themselves on the back.  Consumer group claims of endangerment need more proof than their hearty self-congratulations. Second, their assertions just don’t make any sense.  The CPSIA rules are asphyxiatingly tight, far beyond what is required to make kids “safe” (whatever that means).  We all grew up without the benefit of the consumer groups’ meddling “insights”.  I believe a good percentage of you are able to read this blog without drooling all over your PC – perhaps we never needed all this protection in the first place.  Perhaps indeed. Assume for the sake of argument that we could figure out EXACTLY what level of protection was needed to keep kids “safe”.  Since there is room for doubt about the need for ANY of these protections (putting aside the Democrats’ need to create a basis for reelection), we can posit that the “correct” level of protection is somewhere between where it was when we were growing up and the current levels of CPSIA strangulation.  This suggests that an easing would not come out of anyone’s pocket but would in fact be a classic Pareto Improvement.  To put things in sharper perspective, let me diverge for a moment to discuss the Cubs.  The Cubs triumphant return to Fenway Park this week resulted in a 15-5 drubbing by the Red Sox.  Ouch.  Let’s say that the Red Sox took pity on the Cubs and stopped scoring runs at 13-5.  Would the Red Sox be any worse off for this “concession”?  No.  What if the score was reduce to 10-5 or 6-5?  The Red Sox still win the game.  The reduction in Red Sox runs does not affect the Red Sox adversely until they are reduced to 5 runs (tie game).  This is analogous to the changes proposed by the Republicans in ECADA.  Kids are kept safe but businesses are much less encumbered.  This is a win for our society.  I should point out that Republicans have children and families and care about kids and families as much as anyone else.  They also voted en masse for the CPSIA in 2008.  I find the moral higher ground arguments by the Dems and consumer groups to be fallacious and manipulative.  Do they really think they can contend that Republicans used to care about kids and now just care about businesses?  That’s akin to arguing that we are all idiots. We’re not.  I certainly hope Waxman and the Dems let this needed change pass with Dem support.  It’s time to move on, guys.

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CPSIA – CPSIA Amendment (ECADA) Mark-up Expected This Week

CPSIA – Treatment of Resale Shops and Garage Sales under CPSIA Amendment

A comment was posted recemtly here questioning whether ECADA (CPSIA amendment) truly liberates the resale industry from the CPSIA. In my opinion, it does. I have also conferred with the authors of ECADA for their intentions, and they confirm that resale shops are intended to be exempted under the new language. The authors point to this language: “obtained by the seller, either directly or indirectly, from a person who obtained such children’s product for use and not for the purpose of resale”. This language should give true resale activities, whether in a shop, in your garage, even on eBay, an exemption from all the requirements of CPSIA. What they didn’t exempt is sales by liquidators. In other words, they did not intend to open a loophole in the protections (purported protections) offered to consumers under the CPSIA allowing mass liquidation of potentially violative products Otherwise, real resale activities are exempt. There are some limited exceptions in ECADA to the resale exemption notably. Thanks for posting this question. I hope this helps clear up any infusion.

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CPSIA – Treatment of Resale Shops and Garage Sales under CPSIA Amendment

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