CPSIA – Response to Questions by Nancy Nord (100 ppm Hearing February 16th)

This is my Response for the Record to a supplemental question posed by Commissioner Nancy Nord to the CPSC’s February 16th Hearing on the pending 100 ppm Lead Standards:

Response to Commissioner Nancy Nord’s Request
for Comment in the Federal Register

1. You stated reduction from 300 ppm in substrate to 100 ppm in substrate removes the margin of error for low tech manufacturers. Would you elaborate on this with some of your own testing experience?

When we consider the impact of the lower standard, we first ask how we would manage a failure. As (presumably) rational business people, we want to allocate our capital to maximize our returns, and thus, risks to those returns must be weighed and addressed as appropriate. We have tried to understand our risks under the new lower lead standard – and the results are not encouraging. Once a failure (failed test) is discovered, it is often incurable. A failed test on a completed item including an integrated failed component (e.g., a zipper) likely means a total loss under the CPSIA. Failures of components already subject to valid passing component tests cannot be ruled out and in fact, are likely to occur. Our inability to solve this problem for even trivial violations introduces a new and significant risk of random (unpredictable and uncontrollable) losses to our business.

The agency’s stance on re-testing is not encouraging either. The draft rules on re-testing in the “15 Month Rule” are best described as unworkable. The doubt raised over the consequences of a failed test under pending rules only elevates our concern over how we might deal with a failed test. At present, there seems to be few options. For this reason alone, the proposed reduction of lead standards to 100 ppm is extremely threatening.

Given the dire consequences of a failed test, we must assess whether we can control our supply chains and raw materials/components to always comply with the new lower standard. In my testimony before the Commission, I noted that 98.3% of our passing test reports in a two-year period (2701 CPSIA test reports) were compliant with the new standard. Unfortunately the 1.7% in the range of 100-300 ppm scatters randomly across our many products and components. Thus, we don’t know how to predict which components are prone to risk of non-compliance and the consequences of finding them at the wrong time can be devastating. [It goes without saying that 2701 tests in a two-year period is a strong demonstration of both the devotion of resources and the huge expenditures required by the CPSIA to obtain passing tests reports – continual clean bills of health, over and over and over again.]

Our testing results reveal two troubling trends. First, we have found a material number of our items with one or more components that fall into the 100-300 ppm zone, sometimes just barely above 100 ppm. For a “miss” of as little as 5 ppm of lead entombed permanently in a substrate, an entire lot can be relegated to the garbage heap. Failed components might be as insignificant as a label or a lens cap. We also know from experience that retesting the same unit or units from the same lot may result in a passing test report but do not anticipate that we will be afforded this option to “comply”. In any event, retesting to obtain a clean passing test report does not change the product. If this law is truly about safety, I fail to see what is being accomplished by piling up the test reports to the profit of the test labs. The occurrence of failures under the new standard for a few ppm of lead will raise our costs significantly.

Second, we have encountered significant variability in our testing results. I have attached three test reports as examples of the variability problem. The first report (submitted with my comments on the 100 ppm standard) shows the test results on a single piece of string from a mesh bag holding dominoes. We cut the string into ten pieces and then tested each segment. The lead content results ranged from 239 – 275 ppm. A representative of the bicycle industry gave similar evidence (wide variability in multiple tests on different parts of a single component) at the 100 ppm hearing on February 16th. In the attached test report on tape measures, we found lead levels in coatings in the same tape measure lot ranging from 79-97 ppm, which is more than a 20% variability range. Finally, I have attached three test reports showing yellow plastic substrate from the same lot of educational products at 23, 88 and 139 ppm lead levels. Our success in obtaining passing test reports will apparently depend on LUCK when lead levels are near the 100 ppm concentration. We don’t have a solution to this problem. In our experience, this problem strikes randomly and often absurdly. We have found, for instance, lead levels between 100-300 ppm on zipper housings on the inside of a sewn bag. Lizard tongues might be able to reach it but fortunately, none of our customers are lizards.

None of this randomness or massive expense can be tied to safety – just to the enrichment of testing companies and lawyers. I am hopeful that the Commission will see that action is needed to stop the reduction of the lead standard to 100 ppm to help preserve the value our company brings to schools and families throughout the United States.

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CPSIA – Response to Questions by Nancy Nord (100 ppm Hearing February 16th)

CPSIA – What Does the CPSC Know that the EPA Doesn’t?

At the recent 100 ppm hearing before the CPSC Commission, Nancy Nord asked presenters to submit regulations put out by other agencies restricting lead in our environment. She presumably wanted perspective on whether a reduction to 100 ppm lead-in-substrate content in children’s products would actually improve health or instead, simply further punish the fools who stubbornly remain in the children’s products market.

I submit here EPA regulations on permissible lead levels in play yards and residential dirt. Pleae note that lead in dirt is soluble, so it actually presents a health risk to children. In 2001, the EPA implemented a revised legal/regulatory architecture to protect children from lead-in-paint and lead in the environment. The regulations (40 CFR Part 745) are entitled “Lead; Identification of Dangerous Levels of Lead; Final Rule”.

I think this is an interesting rule because we sell sand and soil as part of children’s science kits. Hmmm. The CPSIA restricts lead content in everything we sell, even fossils and rocks, hence our well-known lead labels. Does the EPA permit something that the CPSC forbids?

Guess!

Consider what the EPA said about its new regulations:

“EPA is also promulgating amendments to the regulations for leadbased paint activities under the authority of TSCA section 402 (15 U.S.C. 2682) and to the State and Tribal program authorization requirements under authority of TSCA section 404 (15 U.S.C. 2684). These changes are needed to ensure consistency among the various regulations covering lead risks under TSCA.”

Consistency seems to be a concern of the EPA. How quaintly passé.

Nonetheless, the EPA seems to understand what is at stake for American children when it comes to lead:

“Reducing exposure to lead has been an important issue for EPA for more than 2 decades. Young children are especially vulnerable to the toxic effects of lead because their nervous systems are still developing and they absorb more of the lead to which they are exposed. Many of the health effects associated with lead are thought to be irreversible. Moreover, the effects at lower levels of exposure are often asymptomatic. In light of the impacts on children and the nature of the health effects, EPA’s goal is to eliminate exposure to harmful levels of lead.” They get it, right?

Uh-oh. The EPA veers away from the current script . . . .

“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.” [Emphasis added]

Sounding like administrators from another planet, the EPA continues:

“In performing its analyses for this rule, the Agency could not quantitatively compare interim control strategies with abatement strategies because there are only limited data available on the effectiveness of interim controls over extended periods of time, and those data which are available are not suitable for quantitative comparisons with abatements. In comparing interim control strategies with abatement strategies, one must make a number of assumptions
concerning the costs of administrative management, and frequency of monitoring and renewal over the planning horizon. For the 50–year planning horizon which the Agency used in its dust and soil analyses, one would have to compare the time stream of interim control expenses, for as long as such expenses are necessary, and weigh the possible differences in potential blood-lead reductions, to make a fair comparison of abatement and interim control strategies.” [Emphasis added]

Later, the EPA warns: “Also, identification of lead-based paint hazards under this regulation is sure to have impacts that could be expensive even though the range of expenses is, itself, difficult to resolve because of the uncertainty of individual behavior and the willingness of individuals to accept risks that EPA may identify. 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.” [Emphasis added]

Clearly the EPA just does not get around very much. Damn the expense, man, there is NO safe level of lead!!!

Importantly, the EPA seems to grasp the difference between CORRELATION and CAUSATION. I wish Congress understood that idea a bit better. . . .

“For dust and soil, EPA had substantial raw data on environmental levels and blood lead levels, even though it faced substantial uncertainty in correlating the levels. . . . If EPA were to set unreasonable standards (e.g., standards that would recommend removal of all lead from paint, dust, and soil), States and Tribes may choose to opt out of the Title X lead program and property owners may choose to ignore EPA’s advice, believing it lacks credibility and practical value. Consequently, EPA needed to develop standards that would protect children without wasting resources by chasing risks of negligible importance and that would be accepted as reasonable by States, Tribes, local governments, and property owners.”

Hope you weren’t eating while you read that last bit. Sorry!

I could quote from this document all day. In light of the nightmare that is the CPSIA, the EPA rules read like some sort of comedy routine. Unfortunately, the joke is on us.

So what did the EPA actually do?

“As stated in Unit II.F.3., today’s rule establishes two hazard standards for bare residential soil; 400 ppm for play areas and an average of 1,200 ppm for the rest of the yard. [See 40 CFR §745.65(c)] EPA recommends that organizations and individuals consider some action in certain areas even where levels in bare soils are below the hazard standard, particularly, if there is a concern that children 6 years and under might spend substantial time in such areas, or if there is concern that the bare soil in such areas may contribute to lead levels in the dwelling, or in the play areas. However, this rule does not mandate that any action be implemented when levels are found to be below the lead hazard standard. Moreover, the kind of response that organizations and individuals might consider could include modest actions such as planting grass (or other ground cover) to more extensive actions such as covering the bare soil with several inches of clean fill.”

Yes, you read that correctly. The standard for play yards (sand) is 400 ppm lead and for bare soil is 1200 ppm lead. If we put a bag of dirt in a child’s science toy, the current CPSC limit is 300 ppm and at this very moment, the Commission is mulling a reduction of the lead limit in that soil to 100 ppm. This change will make more science products either illegal or unsalable for children under 13 years of age. We don’t believe lead labels solve the problem.

The CPSC’s rule on our products will have no effect on play yards, bare soil or anything except items defined as “Children’s Products” under the incomprehensible rule adopted by the Commission.

The longer this goes on, the more I am convinced that only a new government solves the problem. Sad . . . but true.

Read more here:
CPSIA – What Does the CPSC Know that the EPA Doesn’t?

CPSIA – The Great Set-Up

For those who had better things to do than wade through my comment letters last week, I want to highlight a few points.

The two CPSC rulemakings up for comment on August 3rd were on component testing and on the so-called “15 Month Rule”. Both are very important rules and both have been long discussed. The “15 Month Rule” relates to testing frequency and defines a “reasonable testing program”. The long controversy over these rules relates to their acknowledged potential to be TERMINAL to small businesses. This was the principal reason that Inez Tenenbaum delayed issuing these rules on time in November 2009 as required by law (they can vary from law when it suits their purposes, please note). She called a two-day workshop for December 2009 for the purpose of gathering the feedback of stakeholders. I was asked to appear as a panelist, as were two of my colleagues. These sessions were taped (they were able to hear all the feedback and digest it).

So here’s a few things you should know:

a. Component testing will not be useful except for the largest companies and for those rare situations when everything falls neatly into place. The rules as written are too complex, too demanding (full traceability of all components is REQUIRED, which is delusional and completely unnecessary for such simple, innocuous products) and far too risky. The liability risk associated with these very challenging rules will scare off all but the most foolhardy or ignorant companies.

b. Component testing relies on a fantastic assumption, namely that component tests (if desired) will even be available. Why don’t we assume they will be available for every paint and for every plastic pellet on the planet? Does that solve the problem? I dare say not. There are many convenient examples of likely missing test reports – think of aluminum foil in a science kit, for instance. If you are missing only a few component certificates, any benefit from the rule is lost.

c. The “15 Month Rule” was apparently NOT CHANGED from the draft discussed in December 2009. In other words, despite the agency’s “misgivings” about the rule way back then, and even after two days of comments by more than 200 stakeholders, the agency ended up in the same problematic place – and put the rule out for comment now. Of course, they filled in some holes (see below). In my opinion, this means either that the “feedback” process was a complete sham (the agency gave the appearance of “listening” but did as it pleased anyhow) or else that the agency lacks the temerity to tell Congress that the CPSIA is simply screwed up. Having ducked that punch, the CPSC instead opted to put you and me out of business.

If they were unable or unwilling to listen in the last nine months, I have absolutely no confidence they will listen this time. That bodes badly for me and for you. Consider the following . . . .

d. Using the numbers from the CPSC’s rulemaking, I derived that the agency wants me to spend $10,000 per item per year in testing costs (all-in). We have 1,500 items. Do the math – that’s $15 million per year in testing. This is for a company with ONE RECALL OF 130 PIECES TO ITS NAME IN 26 YEARS. This is also the rule regulating a “risk” that killed ONE CHILD and MAY HAVE INJURED THREE CHILDREN . . . in 11 years. [You can review the math in my comment letter. It's their numbers, not mine.] Do you think this might be a touch excessive? No matter, that’s our problem to resolve.

I can’t get this $15 million number out of my head. Do you realize that this rule could become the law shortly? Hey, HTA members, do you get it yet? All that nuzzling up to the CPSC, all their tears over your plight – this rule shuts your doors. If they push forward on this rule (as I anticipate), we will all face a very daunting choice – do we close our doors, sell our companies, go into another business or, breath deep, knowingly break the law by ignoring this rule? Is this a surprise to anyone? This has to be the world’s stupidest rule – and we are left with the ultimate Hobson’s Choice. Thanks CPSC.

Let’s not forget that Bob Adler spoke in stern tones last February when he said he would not vote to extend the stay on the testing and certification rules again. In the absence of further Commission action, the testing stay lapses on February 11, 2011. This rulemaking is intended to put the agency in position to let the stay expire. The next step would be enforcement of this new rule. Ms. Tenenbaum has publicly announced that 2011 will be all about enforcement – you have been warned, the pogroms are coming.

Do you get it . . . yet? IF the agency cannot wrap up this rulemaking in time, it will need to extend the stay. Arguably, that problem is on its doorstep right now. Even they understand that businesses need time to plan, and without final rules, no planning or preparation can take place. IF they cannot get this done in time (soon), they will have to extend the stay AGAIN. This would be incredibly damning of the agency, as it would be an apparent concession that the awful CPSIA cannot be implemented, perhaps ever. Of course, that only confirms what you and I have known for a long time – the law can’t be fixed by this agency and is fatally flawed. In the absence of dynamic Congressional action, we’re all toast (this is old news).

I urge you to take this battle to the political arena. The CPSC and the Dem-controlled Congress have shown that they just won’t listen. They don’t care about our problems. I say that if they are intent in putting us out of business, all of our productive businesses making contributions to our community and our markets every day, then it’s time to return the favor. We need to put THEM out of business first.

Time’s a-wastin’.

Read more here:
CPSIA – The Great Set-Up

CPSIA – Has Congress Ever Done This Before? Ha!

The CPSIA was crafted as a response to a then-shocking but rather inconsequential series of toy recalls in 2007/8 (very few injuries or deaths). After years of intentionally starving the CPSC of budgetary resources, Congress blamed the agency for the large scale toy recalls, leaped to the conclusion that children’s products (not just toys) weren’t “safe” anymore and proceeded to gut the law governing safety and the CPSC (the CPSA). The resulting law (the CPSIA) upended regulation of children’s product safety across an unprecedented array of industries. “Unintended consequences” popped up everywhere almost immediately. Many people claimed to be “surprised”. Given the low injury statistics across the category, the law seems like a vast overreaction.

It’s easy to overlook historical precedent during a crisis. Has Congress ever missed the boat like this before?

Okay, dumb question. But well put!

Consider the response to the Titanic tragedy in 1912. In that famous collision with an iceberg, 829 passengers and 694 crew died when the Titanic sank in the Atlantic. Perhaps you recall the movie . . . . Anyhow, it turns out that the Titanic did not carry enough lifeboats to save everyone. There were 2,228 people on board but the lifeboats only held 1,178. Don’t doubt my math but 705 survived.

Congress couldn’t stand still after the Titanic. Pinning the blame for the loss of life on the lifeboats, rather than the iceberg, Congress passed the La Follette Seamen’s Act of 1915 mandating boats and life rafts for all persons on board seafaring ships. The thinking goes that if every ship had a life boat seat for every passenger, no one would ever die in such a tragedy in the future. The public furor over the loss of the Titanic prevented consideration of the fact that most ships have no risk of colliding with icebergs because of their routes. Likewise, lifeboats are an ineffective remedy in many marine disasters because they would not be able to be launched. No matter, Congress “solved” the problem.

Notably, some members of the maritime industry resisted. In Congressional testimony, A. A. Schantz of the Detroit & Cleveland Navigation Co. noted that the rules intended for the high seas would backfire on the Great Lakes. Schantz pointed out that the light draft and ship design would make Great Lakes ships top-heavy and unseaworthy under the new law. He went so far as to predict that some Great Lakes ships would “turn turtle” if forced to operate with the heavy and useless lifeboats. His argument wasn’t just that the expense was pointless – he also noted that it was counter-productive and even dangerous.

Let’s pause for a second here. Congress rushes onto the field to “solve” a problem it doesn’t really understand. Why doesn’t Congress understand the problem despite hearings and so on? Well, among other things, Congress lacked industry-specific know-how and expertise. It is better at identifying “effect” than “cause”, and therein lies the problem. Consequently, Congress was looking for a particular answer, and tended to reject discordant data (like Mr. Schantz). When industry tried to advise Congress of the inadequacy of its solution, Congress knew better and brushed them off. After all, who has more integrity, Congress or the industry that “caused” the problem in the first place?

Can anyone guess where this is going?

On July 15, 1915, while at dock in the Chicago River, the S.S. Eastland capsized, killing 844 passengers and crew waiting to cruise on holiday to Michigan City, Indiana. The reason? The Eastland was already top-heavy and became unstable under the federally-mandated safety equipment. The ship, when it listed and sank, was described as rolling over “as though it were a whale going to take a nap”. Quite an image. Quite a tragedy. Thanks for all the help, Congress!

Not only is this story creepily similar to the CPSIA saga, it is also a reminder of the risks in the broad financial reforms currently being contemplated by this Congress. Senator Judd Gregg warned: “We shouldn’t put in place a regulatory regime that overly reacts and, as a result, significantly dampens our capacity to have the most vibrant capital and credit markets in the world.” He might as well be speaking of our friend, the CPSIA. As Jim Grant notes: “The intended consequences of government regulations are frequently less potent than the unintended ones.“

As obvious as Mr. Grant’s point has become in the case of the CPSIA, the Democrats if anything have hardened their position and remain resolute that they are doing “everything they can” for us. Put another way, everything else that we want (and which has been denied us) in a CPSIA amendment is NOT forthcoming. No reason supplied except the intellectual pap that everyone wants kids to be safe – America demands it. Apparently, the Dems think they have a much better idea on how to keep kids safe than the industry.

So the Democrats are willing to risk another S.S. Eastland in the children’s product industry rather than admit they went (way) too far. The Republicans, to their undying credit, admit that the CPSIA needs severe restructuring and are working hard to bring about real change. Sadly, Waxman and his Dem co-horts are able to block the Republican effort at reform, and that’s why we are in a stalemate. Who will be the S.S. Eastland of the children’s product industry? It could be my company, could be your company, could be your school or even your child. The unintended consequences keep coming to light, and as the evidence mounts, the Democrats in Congress and their counterparts at the CPSC will held to account for the damage they have wrought. History will not forget.

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CPSIA – Has Congress Ever Done This Before? Ha!

CPSIA – Regulation by Newspaper Headline

There was once a time when newspaper headlines did not immediately become law. Those golden days are seemingly a hazy memory, to judge from the swift and judgmental reaction to a recent AP story on cadmium in children’s jewelry.

PLEASE NOTE – This essay is not a defense of cadmium. That’s becoming a tiresome objection, frankly. Cadmium is bad, okay? Back to the story . . . .

The AP story, backed up by test reports that AP will apparently not release, prompted Senator Chuck Schumer to introduce legislation on Wednesday, two days later, to “stop it cold”. After an equally lengthy deliberation and careful consideration of the flimsy facts of this case, Chairman Inez Tenenbaum of the CPSC made this astounding announcement today:

“Because of these recent developments, I have a message for parents, grandparents and caregivers: Do not allow young children to be given or to play with cheap metal jewelry, especially when they are unsupervised.”

Whoa! Tenenbaum is saying that consumers should boycott ALL “cheap” metal jewelry now? Is she trying to put Claire’s Boutique and countless thousands of other small companies out of business entirely, all because of the unconfirmed accusations of an AP reporter about a handful of pieces of jewelry from a tiny number of sources? Within 48 hours, too? I think that’s irresponsible.

Yes, it’s irresponsible, but that’s the way this populist government of reactive politicians wants to govern. The Obamites are apparently shocked to discover that anything ever goes wrong, and if they ever find a single fly in the ointment, they then assume they are facing a broad scale assault. Hence, the immediate action to implement bans and cessations of trade.

Stop it cold, indeed – but what exactly is being stopped? Trade. Jobs. Futures.

Even worse, frankly, is the notion that this problem must be “solved” by legislation. While Senator Schumer was simply doing the usual, pandering for votes, where is it written that this problem is best resolved by Congressional action? [Let's put aside the niggling detail that some further assessment of the nature of this "dire" threat is appropriate before we take ANY action whatsoever.] Apparently, Mr. Schumer believes it’s his job to fix this problem and that in the absence of his decisive action, the rest of the government would fall on its face.

Umm, well, we used to have a federal agency for this very task, the CPSC. Okay kids, gather ’round, let me tell you about a long ago time when the CPSC has actual authority to assess risk and depending on its independent judgment, was entitled to draft and implement rules governing safety in the marketplace. Wasn’t that a wonderful time, kids?! Well, not anymore. Nowadays, apparently only Congress can exercise judgment. And that judgment is best exercised without the use of any scientific advice or reliance on the agency charged with the responsibility for safety administration.

Courtesy of the CPSIA, the CPSC is now a bureaucracy designed to serve the will of the politicians – determining what is safe (and what is not) is not their primary job anymore. Congress has no use for Ph.D.s or other people that actually understand science. With folks running the show like Chuck Schumer who apparently believe that an AP story is a perfect substitute for expert advice, there is no need for the CPSC to do anything other than fuel panic for Congress to assuage. Hence Ms. Tenenbaum’s shocking announcement today.

This is completely wrongheaded and will damage markets almost immediately. It’s all the more amazing because we have been here before, and paid the price with two years of chaos, misery and pain. The lessons of the CPSIA apparently weren’t learned, and to judge from the knee-jerk reaction to the AP story, it appears unlikely that this group of politicians (Democrats) and administrators are capable of ever mastering them.

Remember, I think cadmium is bad. But bad is no justification for legislation or rulemaking on the fly. This is not a sudden and life-threatening crisis. This metal, while undesirable, was probably in the market for years, all without poisoning large swaths of American children. The story of the little boy in Minnesota who swallowed a jewerly bangle and died (monotonously repeated by Senator Amy Klobuchar and now by Inez Tenenbaum), sad as it is, should be retired. I have no interest in seeing the children’s product industry put out to pasture just because of one accident.

Someday I hope we can restore some sense of proportion and restraint in safety administration. It can be done. . . .

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CPSIA – Regulation by Newspaper Headline

CPSIA – What on EARTH is She Talking About?

In a statement approving of a penalty imposed on a company for a drawstring choking hazard violation, Commissioner Nancy Nord made some mysterious remarks. Dense as I am, I just don’t get it. If you understand these remarks, I hope you can explain them to me sometime. a. “On a broader level, I commend companies already following the drawstring voluntary standard. However, I am deeply concerned by the industry’s need to increase its efforts to educate its member companies about the problem with drawstrings on children’s upper outwear, as well as the Agency’s need to increase its efforts to publicize the hazards of these circumstances. Industry and the Agency must make a more aggressive effort, together, to get this warning information out to manufacturers, especially smaller ones who may be less likely to be aware of the seriousness of this problem. In addition, efforts need to be increased to have parents be better informed and be more vigilant in making sure their young children do not wear clothing with drawstrings in their upperwear.” Huh? A need for EDUCATION OF MANUFACTURERS, ESPECIALLY SMALL ONES? What?! The CPSC and industry working COOPERATIVELY to REACH OUT to both makers AND TO PARENTS? Heresy! Besides, doesn’t Commissioner Nord know that all problems are best solved by governments, and that individual responsibility, not to mention the obligation to supervise children, is an outmoded concept? Please! b. [This quote is even CRAZIER.] “In situations like this, I am sadly reminded how agency and industry efforts and limited resources have had to be focused on issues that do not present real safety concerns , like bike valves, library books and rhinestones, instead of on real dangers like drawstrings on children’s apparel. The Agency, the industry, and the public at large need to remain focused on the seriousness of drawstrings in children’s outerwear until every avoidable injury is just that – avoided.” [Emphasis added.] I don’t get it. What’s she talking about? You would think she’s never been the Chairman of the CPSC or something. First of all, why does she regret the expenditure of millions of dollars and thousands of man-hours dickering about dangerous items like rhinestones? Kids lick their bike chains and chow down on rhinestones every day, after all – oooh, that’s so unsafe! And what’s this about “limited resources”? Can’t Obama just print up some more dough? It’s raining dollars, let’s hire lots of investigators . . . . I am also mystified by the notion that it is possible to figure out that some dangers are “real” and some are not. Didn’t Congress do all the thinking for us already? Ms. Nord, get with the times! I certainly hope this kind of thinking doesn’t catch on. What would I do for amusement?

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CPSIA – What on EARTH is She Talking About?

CPSIA – Car Seat Lead Poisoning Hoo-hah

Perhaps you heard that there have been six cases of lead poisoning by car seats in Maine. Sounds ridiculous, right

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CPSIA – Car Seat Lead Poisoning Hoo-hah