Wednesday, August 11, 2010

New costs, no common sense

Even though the safety considerations for mattresses, clothing textiles, carpets, and plastic vinyl are exactly the same for children as for adults, the current successful testing requirements for these products will no longer be enough. Now the Commission’s decision to treat “general product safety rules” as “children’s product safety rules” will require new third-party testing of the children’s versions of these products in CPSC accredited specialty labs. These additional testing costs are being layered on top of testing that has been carefully designed based on science-based protocols that are already known as the “gold standard” in safety.

I do not believe that the Consumer Product Safety Improvement Act requires this new, additional third-party testing that the Commission’s recent string of decisions mandated. These tests will not reduce risk and will ultimately harm productivity, increase cost and limit consumer choice. For instance, government regulation is cited as a major obstacle to new business start-ups or to expansion.

Most Americans will never learn about highly technical regulations that our agency recently passed. But they will be paying the price in higher costs, fewer choices and lost jobs. So, the next time you hear a commentator ask a guest, “What would you do to increase jobs or reduce government spending?”…think about the cost of government regulation…

•Commissioner Northup’s Official Statement on 3rd Party Testing for Flammability of Carpets & Rugs, and Vinyl Plastic Film: Requirements for Accreditation

•Commissioner Northup’s Official Statement on Testing the Flammability of Clothing Textiles, Mattresses and Mattress Pads, and/or Mattress Sets: Requirements for Accreditation of Third-Party Conformity Assessment

1 comment:

Rick Woldenberg, Chairman - Learning Resources Inc. said...

In my comment letter on the "15 Month Rule" last week, I noted that the agency's new rules if adopted will require our company to spend $15 million per year on safety testing. I have addressed this in my blog several times in recent days - the data is based on the CPSC's own testing data.

This rulemaking takes place eight months after the CPSC's two-day workshop in which it sought "feedback" from people like me (in fact, specifically from me, since I was asked to appear as a panelist at that event). The rule appears to be the same as last December, just filled in with worse details.

Of course, this rule if adopted will promptly end our company's life, not to mention terminate the 150 jobs we provide. Although I didn't say it directly in my comment letter, both of the rules up for comment on August 3rd were contemptibly stupid and dangerous. I guess you would call that an additional comment, filed after the due date. . . .

The assertion that the new rules would contribute to safety is an untested assertion. I cannot imagine how the agency could prove or even support that contention. However, at this point, I have lost any remaining shred of confidence that the agency will ever listen to common sense. So I assume that the August 3rd rules will be adopted. The CPSC certainly knows more than us . . . about everything, apparently.

If the Commission allows the 15 Month Rule to go forward as currently contemplated, I call on you to RESIGN your post. Personally, I could not remain on this Commission or associate with its irresponsibility if I were a Commissioner. This has gone way past comedy, into the realm of tragedy.

It's time to take a stand. Those of us still trying to earn a living are counting on you.