CPSIA – Rumorville on 15 Month Rule

Hope you haven’t assumed that the “15 Month Rule” has gone away.

CPSIA – If The CPSC Goes Out, Do You Think They’ll Come Back???

With the Federal government about to shut down, one wonders – could we possibly live without the CPSC for a few days? I, for one, would very much like to find out. But what about the CHILDREN, you say. It’s a horrifying thought. After all, with annual expenditures of north of $100 million per hyear and in recent times an obsession with children, the CPSC has managed to uncover one death allegedly tied to lead (swallowing a jewelry bangle) and three injuries tied to lead-in-paint over an 11-year period from 1999 – 2010. That’s what you get for regulatory expense of more than $1 billion – four alleged injuries. Value for the dollar . . . . In the last couple years, though, the federal government in its infinite wisdom has chosen to pass all regulatory cost increases on to YOU. Yes, in a new innovation making rising taxes obsolete, Congress raised YOUR costs by billions each year when it inflicted the CPSIA on America. I have previously presented an analysis based on Congressional testimony that estimates those costs at more than $5.6 billion each year. And I think that’s low. I know you’re probably not a statistician, but what are the odds that lowering the ten-year results from four alleged injuries to zero alleged injuries would be considered statistically significant? I believe the answer is zero or very very low. $5.6 billion a year doesn’t buy much, does it? The scale of the threat was explored in a revealing moment yesterday when the infamous Rachel Weintraub of the Consumer Federation of America was asked by four different members of Congress for names or lists of victims of lead-in-substrate. She couldn’t name any. Dana Best had no chance to answer such questions, because she bolted before questioning. I rather doubt the members were much in the mood to accept an answer of “jillions” anyway. I haven’t had a chance to review the tape yet, but I understand Ms. Weintraub assured Congress in response to these queries that lead is a “silent” harm-doer. Rachel says there;s no way to tell . . . so I guess the implication is that we should assume millions of kids have been harmed. Possibly bazillions. Who knows?! Has anyone considered the possibility that the injured children that only Ms. Weintraub and Dr. Best can see are IMAGINARY? Consider this argument: Rachel and Dana and their ilk have had three years to find a victim, any victim, at any time since Hector had pups. They have failed in this endeavor. Maybe Rachel and Dana didn’t try, maybe they don’t care. After all, they probably thinks they’re right and who are we to challenge either of them. No response required. . . .. But IF Rachel’s right, why don’t the numbers yield up MANY victims? It really shouldn;t be hard to find injured kids – which makes the failure to do so all the more galling. There are lots of children in the regulated age group – more than 50 million. That population is constantly changing because kids “age out”. So if you look over a decade, say, you might be talking about 75+ million. What do these kids do? What all kids do. They play, they breathe, they eat, they ride ATVs, they lick bicycles, they suck on the ink end of pens, they consume fistfuls of rhinestones, the usual. Some of them oddly do extreme things. You are looking at a BIG population. Over a decade, that’s HUNDREDS OF TRILLIONS of product interactions, some of them excessive. And yet there are no known victims. Hmmm. Perhaps this is a pretty low probability event. And not worth $5.6 billion a year in excess costs. So when the CPSC goes out, will anyone notice? That;s a good question. It may be an experiment worth running. And if the world doesn’t come to an end without them, perhaps Congress might find something new to cut when life gets back to normal. There’s no safe level of fear mongering, guys. Your Friend, The “Lead Doser”

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CPSIA – If The CPSC Goes Out, Do You Think They’ll Come Back???

CPSIA – Witness List for April 7th CPSIA Amendment Hearing

Memo to Members of the House Subcommittee on Commerce, Manufacturing and Trade: When you listen to Dr. Dana Best fling around numbers tomorrow, please remember that “bazillions” is not a real number. When she asserts that there are possibly “millions” of injured children from lead-in-substrate, please demand real, auditable data! The Witnesses: Panel 1 Mr. Robert Jay Howell Assistant Executive Director Hazard Identification and Reduction U.S. Consumer Product Safety Commission  Dr. Barbara D. Beck, Ph.D., DABT, FATS Principal Gradient Dr. Dana Best, MD, MPH, FAAP American Academy of Pediatrics  Panel 2 Ms. Erika Z. Jones Partner Mayer Brown On Behalf of the Bicycle Product Suppliers Association   Mr. Paul C. Vitrano General Counsel Motorcycle Industry Council Principal Ms. Sheila A. Millar Partner Keller and Heckman LLP Caroline Cox Research Director Center for Environmental Health Panel 3 Mr. Frederick Locker Locker Greenberg & Brainin PC Mr. Charles A. Samuels Member Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C. Mr. Dan Marshall Vice President, Handmade Toy Alliance Co-Owner, Peapods Natural Toys & Baby Care   Ms. Rachel Weintraub Director of Product Safety and Senior Counsel Consumer Federation of America

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CPSIA – Witness List for April 7th CPSIA Amendment Hearing