CPSIA – At First, I Thought The Onion Was Trying to be Funny. . . .

I think this is a parody, not a real news report. At least I think so. . . .

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CPSIA – At First, I Thought The Onion Was Trying to be Funny. . . .

CPSIA – So What’s the Problem? New CPSIA Product Ideas.

This bike is made of pure titanium – no lead!

Something cute for the nursery? Be sure to ask for the GCC!

“Safe Sleep” initiative candidate. Just watch out for the sharp points.

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CPSIA – So What’s the Problem? New CPSIA Product Ideas.

CPSIA – But Who Will Test the Test Lab Testing Testers???

Demonstrating that creative, innovative flair we look for in our regulatory agencies, the CPSC has just announced its discovery of a much-needed new testing protocol, the test lab testing tester. Okay, so you say someone’s been playing with their clacker balls a bit too much, but heck, they gotta know what they’re doing, right?

Embedded deep in the impressively long 160-pager entitled “Proposed Rule: Testing and Labeling Pertaining to Product Certification, April 1, 2010“, the CPSC reveals that there’s trouble in La-La-Land over variances between lab tests performed at different certified labs: “Another comment noted that variations in sample preparation by conformity assessment bodies can and do lead to differing test results. One comment, noting lab-to-lab variations in test results for the same product, suggested that CPSC should require CPSC-recognized third party conformity assessment bodies to conduct blind correlation studies and lab audits.”

Oy vey, what do people EXPECT? The CPSC can’t help out on every niggling problem: “The Commission’s limited resources preclude CPSC from directly conducting verification of the numerous CPSC recognized conformity assessment bodies. Additionally, the activities and requirements for accrediting conformity assessment bodies are outside the scope of this rulemaking.”

Case closed?

Au contraire, Pierre! This CPSC will face down every challenge! They ain’t no teething tiger any more, they are a Lion of Safety now, so they came up with the perfect rule to resolve this dilemma. After all, lest we forget, you CAN’T be too safe! Here’s what they came up with:

“Proposed § 1107.24(a) would state that a manufacturer is responsible for verifying that its children’s products, as tested by a third party conformity assessment body, comply with applicable children’s product safety rules. For purposes of proposed § 1107.24, “verification” would mean testing that demonstrates that the test results from one third party conformity assessment body are consistent with the test results from another third party conformity assessment body for a particular children’s product. Proposed § 1107.24(a) would require a manufacturer to send samples of a previously certified children’s product or a children’s product that previously has been tested periodically pursuant to proposed § 1107.21 to a third party conformity assessment body for verification.

. . . . Proposed § 1107.24(b) would require verification to occur on a reoccurring basis and be conducted at a frequent enough interval to provide a high degree of assurance that the children’s product that had been certified previously continues to comply with the applicable children’s product safety rules or that the periodic test for the children’s product was performed correctly.”

]Emphasis most enthusiastically added.]

This is GENIUS! Thank heavens we have the CPSC to protect us. Who else would have spotted this terrible and threatening gap in our consumer safety network? But having added this new layer of “protection”, aren’t other safety holes now visible? I call on the CPSC to bring out rules clarifying:

• Certification of testing testers;
• Certification of testing tester testing testers (you need those, too);
• Certification of testing tester testing certifiers;
• Rules for tolerable variances among testing labs for each certified test, record keeping on all test results and variances for at least 100 years, and plans of remediation for every conceivable variance for each possible test under all conceivable circumstances;
• Rules for a new agency to check all the work of the CPSC and to reconsider and rewrite every rule they have ever written, plus record keeping and hearings and comment periods for this new agency;

I think the new agency to check the work of the CPSC should be called the Consumer Product Safety Commission Checking Commission for Safety Enhancement and Verification Processes (CPSCCCSEVP), you know, for simplicity. Gotta keep it simple and efficient. That’s my motto!

[For more pleasure reading on this important topic, don't miss the 110-page Staff briefing or the equally riveting 29-page Slide Presentation for the April 15 Commission meeting on the same topic. Happy reading!]

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CPSIA – But Who Will Test the Test Lab Testing Testers???

CPSIA – The Long-g-g-g-g Wait is Over!

The long-awaited test standard for clacker balls is FINALLY here! At only 16 pages, it’s a mere trifle of a test standard but – believe me – it’s packed with goodness.

And if you’re one of those people who stays up late at night, fretting over how to find a testing company properly qualified to test your clacker balls, you can rest easy now – this godsend of a standard addresses that exact dilemma! Third party assessment of clacker balls has been identified by Congress as ESSENTIAL to restore America’s confidence in the clacker ball industry. Clacker ball safety – that’s change you can believe in!

These steps are long overdue, particularly in light of panic over imported clacker balls which may be prone to off-tempo clacking.

Of course, not every lab is qualified to test your clacker balls. A Third Party Clacker Ball Conformity Assessment Body (we call them “test labs”, but you should probably call them TPCBCAB’s) needs to be accredited in the Clacker Sciences before any General Conformity Certificate would be acceptable. As if this weren’t obvious . . . . For high-volume clacker ball manufacturers, the CPSC has thoughtfully provided special rules for money-saving Firewalled Clacker Ball Conformity Assessment Bodies (FCBCABs, not to be confused with a TPCBCABs). So you have options!

Fortunately, the CPSC saw the crisis in clacker ball safety coming and POURED money from its annual $118 million budget into its clacker ball department, hiring squads of Ph.D.’s skilled in clackerology – just file a Section 15 report and see how quickly they clack your balls like never before! And to protect our borders, the CPSC beefed up its atrophied team of Field Clacker Ball Inspectors (FCBIs). To combat clacking marauders, the CPSC staged FCBIs at each domestic port, alert and poised to protect America against contraband balls.

Does anyone think it’s ironic that there are no clacker ball recalls listed on the CPSC website? Okay, the agency has only been protecting us since 1972 – that’s only 38 years – but still, no clacker ball recalls? Clearly the absence of recalls proves the need for more vigilant clacker ball testing is URGENT. The public’s relief at a re-energized CPSC, ready to oversee our every clack, is palpable. No longer a toothless tiger, this CPSC has become a snarling, clacking . . . something.

So, worry not America, your clacker balls will be safe again for many hours of happy clacking!

Just don’t forget – when you play with your balls, always ask for lead-free. You CAN’T be too safe . . . .

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CPSIA – The Long-g-g-g-g Wait is Over!

CPSIA – 50 Rhinestones, with Apologies to Paul Simon

This was submitted as a comment to one of my blogs on rhinestones. It’s too good to waste as a mere comment. Enjoy!

Just don’t eat those 50 rhinestones…

(With apologies to Paul Simon)

“The problem is all because of lead”, she said to me
The answer is clear just not commonsensically
I’d like to help you as you move to be lead free
Just don’t eat those 50 rhinestones…

We asked for guidance ‘cause we don’t want to be sued
CPSIA’s no help; its meaning can be misconstrued.
She just repeated, at the risk of being crude,
just don’t eat those 50 rhinestones…
Please don’t eat those 50 rhinestones.

Don’t have them for a snack, Jack
Don’t put them in a pan, Stan
Don’t soak them in soy, Roy
You should be lead free
Pretend they are pus, Gus
You don’t need to taste much
Don’t put ‘em in your tea, Lee
You should be lead free

Don’t have them for a snack, Jack
Don’t put them in a pan, Stan
Don’t soak them in soy, Roy
You should be lead free
Pretend they are pus, Gus
You don’t need to taste much
Don’t put ‘em in your tea, Lee
You should be lead free

We told her that the kids all like their bling.

That its safe even when connected by a string.

She just smiled and talked of toys made in Beijing
and warned about the fifty crystals…

She was sure something somewhere would prove her right
Put these stones on stuff and someone will indict
And then I realized it had become a new sound bite
To Say ‘Don’t eat those 50 rhinestones’…
Please don’t eat those 50 rhinestones.

Don’t have them for a snack, Jack
Don’t put them in a pan, Stan
Don’t soak them in soy, Roy
You should be lead free
Pretend they are pus, Gus
You don’t need to taste much
Don’t put ‘em in your tea, Lee
You should be lead free

Don’t have them for a snack, Jack
Don’t put them in a pan, Stan
Don’t soak them in soy, Roy
You should be lead free
Pretend they are pus, Gus
You don’t need to taste much
Don’t put ‘em in your tea, Lee
You should be lead free

- anonymous

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CPSIA – 50 Rhinestones, with Apologies to Paul Simon

CPSIA – How to Know if the CPSC is Going to Pull a "Daiso" on You

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CPSIA – How to Know if the CPSC is Going to Pull a "Daiso" on You

CPSIA – How to Know if the CPSC is Going to Pull a "Daiso" on You

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CPSIA – How to Know if the CPSC is Going to Pull a "Daiso" on You

CPSIA – Redesign the Dog!

I hope you didn’t miss the hubbub today from the American Academy of Pediatrics over dangerous hot dogs. Apparently, you can choke on hot dogs. This shocking revelation stimulated an outpouring of news articles, including this one: “Pediatricians call for hot dogs to be redesigned“. I guess the bun would have be altered, too. Readers, submit your suggestions as comments! I am looking for something very “Space Age” but also exquisitely safe.

Pundits across the blogosphere couldn’t let this pass, like our friends Walter Olson (“Cut grapes into pea-sized portions?“) and Lenora Skenazy (“Surely You Must Be Choking!“). Many newspapers repeated the AAP’s call for warning labels on items like nuts, certain hard fruits and hot dogs. “Back away from the peanut slowly, Tommy, I don’t want you to choke!”

Any of this ring a bell? The AAP remains among the most ardent of the CPSIA advocates. They are in regular contact with the Waxmanis and advise on which scraps of relief we might be allowed. In fact, my spies point to the AAP as the big rabble rouser on rhinestones (sooooooo dangerous!) Having succeeded in gutting the children’s products industry, the AAP have turned their attention to that symbol of America, the hot dog. Parents cannot possibly deal with hot dogs without government intervention – individual responsibility is so passe. The AAP will make us all so safe . . . .

This seems to be a theme of this space – the world seems to have lost its moorings. Redesign the dog, indeed. Spare me.

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CPSIA – Redesign the Dog!

CPSIA – Some ICPHSO Humor

After a day at ICPHSO when

• The General Counsel quizzed the audience perhaps ten times about who was tweeting (my spies indicate that three people tweeted from that session, including me), ribbing us (me?) for letting you know what she was saying. [I blogged live from last year's event, which was noted with shock by some participants.]
• The Chairman instructed us not to believe “Internet rumors” and to only believe websites ending in “dot gov”. You know, you can always believe your government!
• The Chairman told us to stop fighting old battles – in other words, give up, guys!
• The Chairman heralded the work of the Center for Environmental Health, one of the most noxious of the consumer group terrorists active in today’s market. Their tactic of extracting coercive settlements under CA Proposition 65 to set precedent and to fund their activities has been well-documented in this space.
• The looming reality of the public database was shoved in our faces (Tenenbaum: It’s time to get prepared). We confronted the realization that we will be forced to treat every consumer report as an emergency simply because of the database, and
• The Chairman pointed to the Toyota feeding frenzy as the model for future regulatory action on “slow” recalls in this era of populist corporation bashing,

where do you think the ICPHSO planners sent everyone on last night’s social event?

To see “Sheer Madness”, of course!

You have to admit, it was a perfect choice.

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CPSIA – Some ICPHSO Humor

CPSIA – Playing Footsie with Lead Standards

I have complained in this space from time to time about the recent success of Center for Environmental Health in inducing public officials to recall shoes for lead in their soles and insoles. In that case, CA AG Jerry Brown fell right in line and recalled seven items, including a pair of shoes and a pair of sandals for these frightening infractions. The CPSC, as far as I know, was not consulted – this was State AG enforcement of the CPSIA at its best! Did I mention that Jerry Brown is running for governor again . . . .

Of course, a mania over lead in shoe soles and sandal insoles is kooky. You would hope that the CPSC wouldn’t fall prey to such nonsense. Of course, the insightfully-written CPSIA makes no such distinction in the wording on its lead content restrictions. This is one reason why the footwear folks are so concerned about the law. Still, the CPSC is not so reactive to recall shoes for this reason . . . are they?

Regular readers of this space know the answer already. Here it is, the CPSC saving the world from “dangerous” leather work boots for kids! This public menace was recalled because the “Classic Scuffproof Boots” have a logo stamped on its insole that exceeds the new lead-in-paint standard. Whoa! The notice warns that “Consumers should stop using recalled products immediately unless otherwise instructed” and later advises that “Consumers should immediately take the recalled boots away from children”. The number of scuffproof work boots affected is 21,000 pairs sold for between $50-$70, or between $1-1.5 million in retail value. That’s real money, guys. No doubt there’ll also be a penalty in, say, three years.

Soooo, what are we looking at here? These are children’s leather ankle high work boots with a logo ON THE INSOLE that might violate the lead-in-paint standard. [Personally, I STRONGLY doubt that Timberland uses paint for its insole logos - we believe it's made with an ink, thus not affected by the lead-in-paint standard.] Let me ask you an important question – have you EVER licked the insole of an ankle high boot? If you have, can you please send me a diagram of how you did it? While we’re at it, do you believe a child ANYWHERE has EVER licked the insole of their ankle high leather work boot? Chewed off the yummy logo? Just curious . . . .

Man, are we safe now! Is it a huge stretch to contend that most people would not let their kids consume their scuffproof leather work boots, no matter how tasty? It is my distinct impression that many icky chemicals are used to make leather. That’s a “watch out”, if you ask me.

Furthermore, Timberland is a corporate “good guy”. Their website practically oozes with enviro-friendly policies and social responsibility. In fact, they are famous for their personnel practices and activism. Here, for instance, is a portion of their mission statement:

• Value. Humanity. Humility. Integrity. Excellence. These are the core values that we inject into everything we do, everyday.
• Purpose. Creating positive change in our company, community and environment. Any way you can.

Clearly, the government needs to keep a close eye on these people.

Unfortunately, now that a lunatic law governs the country and CPSC leadership seeks to please a cartoon character Congress that “wants” products like this off the market, embarrassing and demoralizing recalls like this become commonplace. For business people, these irrational recalls only heighten the fear and amplify the lack of trust that now infect the regulatory environment. After all, if the CPSC would stick it to Timberland for this, what would stop them from wreaking similar havoc on you?

Somehow we have to stop this runaway train. If you don’t want your country run like this, you better do something about it.

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CPSIA – Playing Footsie with Lead Standards

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