Congressman Henry Waxman’s proposed fix to the CPSIA has been released to the public. Now is the time to weigh in on how this would work for you. Specifically, these are my questions:
- Could your company (or anyone you know) afford to petition the agency in order to prove that the lead in their product serves a “functional purpose,” that it’s “not practicable” to remove, and the other new requirements?
- Note the further limitations under sections entitled: “burden of proof;” “admissible evidence;” “limitation on exception,” and; “narrowest possible scope of exception.” Do these requirements set a bar that you can reach? Would the cost to apply for such an exemption exceed the benefits?
- Does this proposal do more to discourage companies from the hope of an exemption, rather than provide a hope of flexibility?
- How many small businesses could qualify for the “relief for small manufacturers” on testing costs with such a narrow definition of “low-volume”?
- And a rhetorical question: Why would we ask companies (and our own agency staff) to do all of this new work for perfectly safe products to begin with?
If the expansion of the tax code is any reminder….a fix that’s not necessarily a complete fix, yet adds loads of paperwork and time-consuming, complex, costly, new requirements—is probably not a fix.
Please email me at Commissioner_Northup@cpsc.gov
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