CPSIA – It’s Raining Paper . . . Again

At the April 29th CPSIA hearing, I testified that the CPSIA and associated rulemaking had exploded into more than 2500 pages in new CPSIA laws, rules and documents that pertain to my business. I also noted that 608 pages had been issued in the 30 days preceding the hearing and that the rulemaking process continues unabated. Well, the CPSC just spewed out another ream of paper (396 pages) for you to absorb this week:

1. Publicly Available Consumer Product Safety Information Database, Notice of Proposed Rulemaking, DRAFT Federal Register Notice, May 7, 2010. [150 pages]
2. Testing and Labeling Pertaining to Product Certification, Notice of Proposed Rulemaking, DRAFT Federal Register Notice, May 7, 2010. [164 pages]
3. Conditions and Requirements for Testing Component Parts of Consumer Products, Notice of Proposed Rulemaking, DRAFT Federal Register Notice, May 7, 2010. [82 pages]

At a mere 396 pages, this week’s new rules increases the total paper released in the last 45 days to at least 1,004 pages. In its usual helpful fashion, the agency issued these rules to replace other documents recently released and that you may have already read. Gotta read these pupies from the top, since they aren’t redlined against prior drafts. This doubles the fun of the new rules – you need to master them to run your business PLUS you get to go on an exciting treasure hunt as you try to figure out what has changed! And we get all that fun for free!

Good thing time grows on trees or else I might get frustrated.

Happy reading! Just remember, if you don’t comment on these rules and the CPSC imposes final rules that are unreasonable or crush your business, you will have no one to blame but yourself.

As I said, happy reading!

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CPSIA – It’s Raining Paper . . . Again

CPSIA – New Definition of "Children’s Product" Published – Did You Catch It?

The CPSC apparently published a new definition of “Children’s Products” last Tuesday in the Federal Register to no fanfare whatsoever. This little morsel clocks in at only nine pages but it goes in the heap with the other 579 unread pages of miscellania spewed out by the CPSC in the last month. Everyone – quit your jobs so you can keep reading this stuff!

Ah, but the fun doesn’t end there. Try to find this document on the vaunted CPSC website. It’s not under “What’s Hot?” and it wasn’t mentioned in a press release. Until last week, even finding the definition of “Children’s Product” on the site involved quite a bit of hunting and pecking. They remedied that by creating a new category under “CPSIA by Topic” but who would know it’s there? You have to sense its presence and then go find it. This is “Where’s Waldo?”, CPSC-style.

And the final “kicker” – the definition changed from the last publication of this rule on March 19. Since that time, there has been a Commission hearing and much industry chit-chat over the original definition approved by the CPSC Legal Department. Supposedly, this (unread) new definition reflects changes that I am told I will like. The CPSC Legal Department approved this new and revised definition, too. And the conformed or redlined copy for me to read? Nowhere to be found.

What a lovely way to spend my time. Reading rules, digesting rules, commenting on rules, rereading rules, trying to figure out what’s changed, reviewing my last analysis, connecting all the dots, reworking our internal processes again and again and again . . . .

This is the CPSC’s full employment plan. They may be able to solve the unemployment problem all by themselves! Thanks for everything, guys.

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CPSIA – New Definition of "Children’s Product" Published – Did You Catch It?