Ever since I posted my new shop announcement about how I'm going to handle the new regulations regarding the CPSIA and lead testing, I've been asked by many just what changes I'll be making, and how I'm going to comply with the law. So, I thought I'd let you all in on my design process!
Up until now I have let the creative mind of my brain take me in any direction it cared to go. That meant a lot of one-of-a-kind items, fabrics that might or might not coordinate with other things in my line, and basically create items on a whim! I like working this way because when I see a fabric I love, I would just go ahead and order, without giving any thought to whether it "went" with other things that I was doing. While this method is fun for me, it didn't always allow my items to mix and match. So...
What the CPSIA has forced me to do is take a really hard look at my clothing. Can the items work on their own? Yes. Without a doubt. Can they mix and match? Not so much. How many fabrics am I using? Hundreds. Even though component testing isn't allowed right now, I expect this to change in the future. So, for my Spring/Summer '09 collection, I am working very hard to make my line work differently. I am drastically paring down fabric and button selections in order to keep the cost of testing down, and of course, pass that savings on to my customers. I know this sounds very fundamental to many of you, but it just isn't how I have operated.
In the past I was reluctant to buy bolts of fabric, because I never needed that much of any one thing. Having limited fabrics for a whole line will allow me to purchase in bulk, again, keeping costs low. I will also be concentrating on more reversible styles which will allow for greater versatility for my customers.
I am really, really excited about my upcoming designs. They are practical, stylish, and of course, CUTE! There will be tons to mix and match, and I will be concentrating on two colorways, namely pink and blue. These are bestsellers for obvious reasons, and they also look great together.
I am also committed to following the law, and to that end will have all of my styles tested for lead. I am pretty sure there isn't any there to begin with, but if the big guys can prove it, then I guess so can I.
Of course, in August, we face another big hurdle. XRF testing will not be allowed, and everything must be done by a third party lab. If that doesn't change, I am not sure how I can stay in business as the cost of wet chemical destructive testing is just too great for it to make any sense for a small business like mine. So keep working to change the law, and stay tuned for my Spring/Summer collection in February!
Thursday, January 8, 2009
sneak peek spring/summer '09 collection
Tuesday, January 6, 2009
My New Shop Announcement
Just thought I'd post this here as well, in case you missed it.
Dear Customers,
There is a new law that was enacted by Congress in November that will go into effect on February 10th, 2009. This law, called the Consumer Product Safety Improvement Act of 2008, states that all children’s products, even handmade and one of a kind items, must be certified by a qualified lab for a maximum level of lead, regardless of whether the components used pose any kind of risk.
For now there is an interim provision in the law that allows for XRF technology, or x-ray detection of lead, to be used for compliance. However, this testing, while not as costly as destructive testing mandated in August, will still be a challenge to implement. In order to keep my business, I will be complying with this law to the best of my ability, but there will be some changes in my product offerings.
Many of the businesses on Etsy that offer products for children have been lobbying for changes in the law that will allow for a more rational approach to the lead requirements. For more information, you can read my blog, support the petition from the National Association of Manufacturers, and contact your congressmen to express your opinion on the untenable nature of this law in the current state of the U.S. economy.
Feel free to contact me with any questions you have. Thank you for your continued support and patronage.
Dear Customers,
There is a new law that was enacted by Congress in November that will go into effect on February 10th, 2009. This law, called the Consumer Product Safety Improvement Act of 2008, states that all children’s products, even handmade and one of a kind items, must be certified by a qualified lab for a maximum level of lead, regardless of whether the components used pose any kind of risk.
For now there is an interim provision in the law that allows for XRF technology, or x-ray detection of lead, to be used for compliance. However, this testing, while not as costly as destructive testing mandated in August, will still be a challenge to implement. In order to keep my business, I will be complying with this law to the best of my ability, but there will be some changes in my product offerings.
Many of the businesses on Etsy that offer products for children have been lobbying for changes in the law that will allow for a more rational approach to the lead requirements. For more information, you can read my blog, support the petition from the National Association of Manufacturers, and contact your congressmen to express your opinion on the untenable nature of this law in the current state of the U.S. economy.
Feel free to contact me with any questions you have. Thank you for your continued support and patronage.
Monday, January 5, 2009
CPSIA Business ICU-The Clever Kitty
I thought that it might be a good idea to feature some sellers of children’s products that are going to be directly affected by the new regulations that go into affect on February 10th, 2009. Shannon of The Clever Kitty has been making and selling fabulous children’s products on Etsy for several years. She started her crafty endeavors as a young child, and decided her creative mind couldn’t be ignored. She got her degree in Fiber Arts at Kansas City Art Institute. Not only does she make and sell her wonderful baby products, but she’s a part time florist as well, and I’m not surprised. Her use of color is one of her strengths, and her gorgeous baby booties and accessories reflect that love.
One of my favorite items she makes are her florajanes. These come in a large array of colors, and can be custom made for your baby. They are felted booties that have a tiny little felted flower attached at the buckle, and snap for easy on and off. Inspired by Chuck Taylor’s, Shannon’s felted high-top booties are too cute for words, and are perfect for that sporty baby in your life.
If the CPSIA stands as written, Shannon will be forced to stop selling these gorgeous, SAFE, baby products. Please help by contacting your congressmen and tell them you don’t support this law un-amended.
Sunday, January 4, 2009
CPSIA Comment 8, FINAL ONE!
“Whether consideration of third-party testing of component parts should be given for any particular industry groups or particular component parts and materials. Explain what it is about these industries, component parts, and/or materials that make them uniquely suited to this approach.”
The Apparel Industry: The aim of the CPSIA is to keep dangerous products out of the hands of children. If manufacturers are able to use component and supplier provided testing of fabrics and other inputs, and spread the cost of testing over a larger product range (ie. the same zipper on 5 different garments, the same snaps on an entire product line) then the business can afford to be compliant. Also consumers would benefit from lower prices. If the apparel manufacturer must test each unit, costs will skyrocket, and many companies will fail.
There should also be a subset of exemptions for materials used in any industry that are inherently lead free, and do not pose a health risk to children. For the textiles, apparel and footwear sectors, fabrics, thread and other materials should be excluded because they are known to contain no or very low amounts of lead. Paper, printing inks, laminates, adhesives, bindings and cardboard used in books and other paper-based printed materials and toys should also be excluded.
There are already international standards in place for fabrics. Oeko-tex and GOTS certified fabric already exceed the standards set forth in the CPSIA. Apparel manufacturers should be able to choose these inputs without having to incur any additional testing at all, as they are already inherently safe. Many suppliers already test their products, and companies should be allowed to use these certificates as part of their “reasonable testing programs.”
Also, an exemption should be given for components that are inaccessible. The CPSIA establishes one clear example of an inaccessible component part: a part which is not physically exposed by reason of a sealed covering or casing that can withstand appropriate use and abuse testing. There is sufficient evidence for the Commission to immediately conclude that certain components of children’s products do not present hazards based on their inaccessibility to children when contained in the product, to include circuit boards that are in a sealed covering, innersprings in upholstered furniture, and other products that are inaccessible when considering normal use and abuse.
Toys that are component tested v. unit tested would also be inherently safer. If only one small component on an entire toy tests for higher levels of lead, then that component may not be enough to put that toy in the non-compliant category. But if it were component tested, and that component were to test at or higher than the threshold level, then that component would have to be replaced with a suitable substitute, thus making the unit inherently safer.
Feel free to comment! I am going to work on some rewrites this week, and will be sending mine to the CPSC as soon as those are complete. Feel free to copy any portion of my comments, and change to suit your own needs. The more people that comment on component v. unit testing, the better. Also, please review the NAM Petition. I am going to submit a copy of this petition along with my comments, as I wholeheartedly support it. All comments are due by January 30, 2009.
The Apparel Industry: The aim of the CPSIA is to keep dangerous products out of the hands of children. If manufacturers are able to use component and supplier provided testing of fabrics and other inputs, and spread the cost of testing over a larger product range (ie. the same zipper on 5 different garments, the same snaps on an entire product line) then the business can afford to be compliant. Also consumers would benefit from lower prices. If the apparel manufacturer must test each unit, costs will skyrocket, and many companies will fail.
There should also be a subset of exemptions for materials used in any industry that are inherently lead free, and do not pose a health risk to children. For the textiles, apparel and footwear sectors, fabrics, thread and other materials should be excluded because they are known to contain no or very low amounts of lead. Paper, printing inks, laminates, adhesives, bindings and cardboard used in books and other paper-based printed materials and toys should also be excluded.
There are already international standards in place for fabrics. Oeko-tex and GOTS certified fabric already exceed the standards set forth in the CPSIA. Apparel manufacturers should be able to choose these inputs without having to incur any additional testing at all, as they are already inherently safe. Many suppliers already test their products, and companies should be allowed to use these certificates as part of their “reasonable testing programs.”
Also, an exemption should be given for components that are inaccessible. The CPSIA establishes one clear example of an inaccessible component part: a part which is not physically exposed by reason of a sealed covering or casing that can withstand appropriate use and abuse testing. There is sufficient evidence for the Commission to immediately conclude that certain components of children’s products do not present hazards based on their inaccessibility to children when contained in the product, to include circuit boards that are in a sealed covering, innersprings in upholstered furniture, and other products that are inaccessible when considering normal use and abuse.
Toys that are component tested v. unit tested would also be inherently safer. If only one small component on an entire toy tests for higher levels of lead, then that component may not be enough to put that toy in the non-compliant category. But if it were component tested, and that component were to test at or higher than the threshold level, then that component would have to be replaced with a suitable substitute, thus making the unit inherently safer.
Feel free to comment! I am going to work on some rewrites this week, and will be sending mine to the CPSC as soon as those are complete. Feel free to copy any portion of my comments, and change to suit your own needs. The more people that comment on component v. unit testing, the better. Also, please review the NAM Petition. I am going to submit a copy of this petition along with my comments, as I wholeheartedly support it. All comments are due by January 30, 2009.
Friday, January 2, 2009
Please Take This Survey (Economic Impact of CPSIA)
Only one more question to go, but Kathleen Fasanella of www.fashion-incubator.com is trying to get a handle on how this is going to affect all of our businesses. She has put together a survey that will become part of a larger "economic impact statement" because clearly the government is a bit clueless. It doesn't take very long to complete, but if we can show in a systematic way how this will affect everyone, it may help the cause.
CPSIA Comments, Question 7
"How a manufacturer would manage lot-to-lot variation of component parts, in a third-party testing of component parts regime, to ensure finished consumer products are compliant."
In this instance, supplier provided testing is an advantage over unit testing. For example, if a manufacturer only tests one unit, yet that production run consists of 3 lots of components, then presumably only one of those lots will be tested per sku. But if the supplier of that component has an on-going testing regime, then those results would be superior to unit testing. If a supplier consistently chooses the same materials to produce their products, then that lot-to-lot variation will be insignificant. The same would apply to the manufacturer.
In this instance, supplier provided testing is an advantage over unit testing. For example, if a manufacturer only tests one unit, yet that production run consists of 3 lots of components, then presumably only one of those lots will be tested per sku. But if the supplier of that component has an on-going testing regime, then those results would be superior to unit testing. If a supplier consistently chooses the same materials to produce their products, then that lot-to-lot variation will be insignificant. The same would apply to the manufacturer.
CPSIA Comments, Question 6
Back to the task at hand: Question 6 is HARD! Again, please feel free to comment, and help me with these complex questions. Here goes:
"What changes in inventory control methods, if any, should be required if third-party testing of component parts were permitted. Address receipt, storage and quality control of incoming materials, management and control of work-in-process, non-conforming material control, control of rework, inventory rotation, and overall identification and control of materials."
A manufacturer would need to make sure that there is a system for labeling and tracking incoming components, and have that tracking linked to the test results and the final units.
The manufacturer must have an inventory system where untested components be kept separate from tested components. If a component is proven to be non-compliant, there must be a “quarantine” area to which workers on the floor do not have access. Then the manufacturer would need to make the determination whether to return that component to the initial manufacturer, scrap the component, or use it in a different manufacturing application.
There must be coordination between the inventory control and tracking system and the physical location in the facility. Once a component has been tested, logged, and stored that component must still be traceable to the final product by assigning batch ID#’s. For a micro-producer or artisan, this can be accomplished by supplier provided certifications, and not allowing non-compliant components into the workspace.
"What changes in inventory control methods, if any, should be required if third-party testing of component parts were permitted. Address receipt, storage and quality control of incoming materials, management and control of work-in-process, non-conforming material control, control of rework, inventory rotation, and overall identification and control of materials."
A manufacturer would need to make sure that there is a system for labeling and tracking incoming components, and have that tracking linked to the test results and the final units.
The manufacturer must have an inventory system where untested components be kept separate from tested components. If a component is proven to be non-compliant, there must be a “quarantine” area to which workers on the floor do not have access. Then the manufacturer would need to make the determination whether to return that component to the initial manufacturer, scrap the component, or use it in a different manufacturing application.
There must be coordination between the inventory control and tracking system and the physical location in the facility. Once a component has been tested, logged, and stored that component must still be traceable to the final product by assigning batch ID#’s. For a micro-producer or artisan, this can be accomplished by supplier provided certifications, and not allowing non-compliant components into the workspace.
Subscribe to:
Posts (Atom)
Posts
