OK everyone, all our letters and emails and overall hard work is starting to get the CPSC's attention. They have now opened up comments on component testing. This is important to many of us because if they allow manufacturer's to test each component, and possibly use our supplier's testing results, the costs of conforming will decrease significantly.
I want to ensure my products are safe. To that end I have contacted Westminster Fibers, the fabric company I use for the bulk of my line. Guess what? No detectable lead. Big surprise, right? I also contacted Mettler thread, and because they test using Oeko-tex standards, a very rigorous European program, they are lead free as well.
If I am allowed to use their tests as part of my "reasonable testing program", my costs are significantly decreased. It could be that only my trims and buttons need to be tested, in which case my costs to test could be spread out over a larger product line. And, I wouldn't have to sew up every product before the test could be performed. Batching this out to a lab becomes much simpler and cheaper. This is very, very important, and could mean the survival of my little business.
So here is the link: http://www.cpsc.gov/about/cpsia/cpsia.html and you can scroll down to see just under "What's New" to see the pdf form. These are the questions they are specifically targeting to the industry. It is complicated, but I will post my letter here when I get everything written. The deadline to post your comments is January 30th. The more people we get to respond to this, the better.