CPSIA Update: Less Than a Month is NOT Reasonable Guidance

By July 22, 2009Regulations

Rick Woldenberg of Learning Resources, Inc., a key activist, commentator and clear thinker on the depredations of the Consumer Product Safety Improvement Act, reacts to the CPSC’s issuance of guidance on permanent product tracking labels.

From “CPSIA – Thoughts on Tracking Labels (Part I)”

The Time to React to Tracking Labels Guidance is absurdly Short. As noted, it took the CPSC more than 11 months to answer even ONE question on tracking labels. Notwithstanding the Commission’s obvious efforts to be appear to be flexible and cooperative in the new guidance, it remains a fact that there are now only 22 days until August 14. The diversity of companies and industries affected by tracking labels is simply mindboggling. Commercial lead-times on production runs are (shall we say) OBVIOUSLY more than 22 days. How is that runaway train supposed to stop on a dime in supply chains all over the world? Notwithstanding the CPSC’s flexibility pledge in their guidance, what does the Commission think companies will be able to do in the short period of time before August 14? I previously alluded to the fact that some people actually take summer breaks, so they might not even be scheduled to be at work to get this critical task started. For quite some time into the future, particularly in long lead-time industries, many companies will be stuck with whatever they decided to do many months ago. The new guidance will be ineffective to prevent breaches of law as of August 14. In that sense, the guidance is a total failure.

And …

So . . . if the tracking labels are no emergency, why isn’t the CPSC taking the high road in this new Tenenbaum era to give industry time to digest the rules, dialogue with the agency on its further open questions or reasonable objections, and implement tracking labels in a planned and orderly fashion? Good question, perhaps? Ms. Tenenbaum has the opportunity to make this a reality by voting in favor of the NAM stay petition before the August 14 deadline. Every day that goes by without the stay, the problems for the victimized industries will grow and grow.

Ms. Tenenbaum, please don’t leave us hanging. Do the right thing – vote for the NAM stay petition. Thank you.

See this Shopfloor.org post on the NAM petition, “CPSIA Update: A New Request for Stay on Labeling Requirement.”

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