CPSIA: coming attractions

Preoccupied with unrelated deadlines, I’ve skipped over a number of interesting stories and developments on CPSIA that deserve in-depth discussion. Each of the following really deserves its own full-length post, and if my schedule permits in the coming days and weeks, I’ll try to do each one justice.

Slowly getting there

  • In response to Michigan Democratic Rep. John Dingell’s request for information about problems in implementing the law, CPSC Acting Chairwoman Nancy Nord had a smart response: she let the commission’s top career staff draft the letter answering the Congressman. The result is a 21-page memo (PDF; w/three-page cover letter) that provides a devastating and thoroughly documented account of why the law was destined from its day of passage to have catastrophic consequences for producers and retailers. In Washington, the career staff of an agency is often listened to in a way that an appointee of an outgoing administration is not. With much detail not formerly available and careful documentation of the way the law’s drafters tied the agency’s hands to prevent the very same reasonable exemption-making that many proponents of the law now claim to favor, the document deserves much more extended analysis than I can give it here and now; it should be read by anyone interested in the case for CPSIA reform.
  • CPSIA’s threat to vintage books is the subject of a story in yesterday’s Washington Post, and was covered by Publisher’s Weekly last week (as well as at many blogs). Both pieces can usefully be read in conjunction with the detailed discussion of the vintage book issue toward the end of the CPSC staff/Nord/Dingell letter, above, which sheds light on questions raised in both articles.
  • Deputy Headmistress has been looking into the question of how it was that European countries had earlier adopted regulations on the same subject and yet experienced far less trauma to small producers, sellers and consumers. She takes up the topic in posts here, here, and here. Not to spoil the suspense, but it has a lot to do with Europe’s willingness to 1) phase in regulations over a period of years; 2) prescribe testing and certification protocols as if they actually cared about sparing producers pointless cost and hassle; 3) target regulations at the particular market segments (e.g., items used by the youngest kids) most likely to present an actual risk of ingestion. In each instance, the U.S. Congress chose differently.

My to-be-blogged file also contains whole stacks of stuff on who on Capitol Hill appears to have a clue on this issue and who doesn’t, on the often wrongly guesstimated costs of testing, and yet more on vintage books, among many other topics. And don’t forget the rally coming up next Wednesday in D.C.


  • That memo from the CPSC staff is 24 pages of awesome.

    Basically it’s telling Congress, “Hey, we are only doing what you told us. And what you told us is stupid.”

  • There is a reference in the memo to a real hazard, so Xmas is wrong. What is stupid about CPSIA is that there is no evidence that any child was or would be harmed by the lead in everyday materials.

    Where is the estimate of decrease in lead levels in blood should the law be 100% effective? Would that matter? If lead had a real effect on cognition, then why are we now so concerned about our schools?

  • […] collections, have a life cycle and would be replaced eventually. I’m not familar with this blog, but they put up a link to a pdf study of how this particular facet of the law was almost destined […]