Wednesday, January 28, 2009
The HANDMADE/CRAFTING WORLD - The New Law - CPSIA - Affecting My Corner Of It
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
Not being an attorney or someone professionally involved in law-making or writing, I am generally careful of what to say about some things.
But this new law on Children's Products, the CPSIA (Consumer Product Safety Improvement Act) is going to have an affect on my little corner of the Handmade Crafting World - as well as all kinds of Children's Products all over the United States. YES - my little corner!!
I am seriously worried - not so much for me personally, as I am not professionally involved in a career requiring the selling or buying of Children's Products - nor do I have any children 12 years of age or younger.
BUT IN GENERAL, I SUPPORT LIMITS OF LEAD IN CHILDREN'S PRODUCTS - ESPECIALLY ITEMS A BABY OR CHILD MIGHT UNKNOWINGLY SWALLOW OR CHEW ON. ACTUALLY I SUPPORT A NON-TOXIC OR LOW-TOXIC ENVIRONMENT FOR ALL OF US HUMANS, WHICH IS GOING TO REQUIRE EDUCATION AND KNOWLEDGE AND, YES, SOME TESTING, SO WE KNOW WHAT CONTAINS LEAD AND DOESN'T.
It will affect the few crocheted and knitted items that I have made for children in that age range - my Baby Hats in my ETSY shop, RSS Designs Wearables, have been selling over the months and under the new rules of testing for lead in All Children's Products, their price would at the very least double (or maybe even more).
Possibly un-realistic in the market I am selling them in - after all, I am trying to make and sell Affordable Baby Hats as Baby Hats are good for the health of the babies and recommended!!
I am afraid that with the CPSIA as it is currently written, the word "Affordable" "goes out the window", so to say!!
So, unless there are some regulations regarding using yarn to make things - and some exemptions for testing, that small part of my ETSY shop will be empty on the effective date of Feb. 10, 2009 - or maybe a couple of days earlier. I am not taking any legal risks - and the regulations I am hoping for at some time will not be ready and effective by then.
When I am affected or interested in something from the Federal government, I have found it advisable to get the actual data and documents from the government. In the area of environmental laws and regualtions including Public Land Management (i.e. the Giant Sequoia National Monument where I went to a lot of US Forest Service Meetings on it), I read the actual documents from the US Forest Service, and though I check some professional's opinions, I rely on most facts from the US Forest Service documents themselves.
So, that is what I am doing on the CPSIA. I have this page (http://www.cpsc.gov/about/cpsia/cpsia.html) bookmarked and check it for new documents, General Counsel opinions, new items published in the Federal Register, etc. If you haven't looked at it, you might want to check it out and get informed.
As I crochet and knit some wearable children's items - or maybe a pillow or toy or bag for them - with either yarn or thread, what I am keeping an eye on and developing opinions on is:
-- component testing and using supplier certifications of lead content (not approved yet)
-- the apparel industry
-- the yarn/textile industry
-- how to get exemptions from testing for materials that I would use that I have already gotten data on and apparently have little or no lead in them and are within the limits of the CPSIA. (not approved yet).
Not being an attorney and not fully understanding how to inerpret some portions of this law, I am not sure if the CPSC can just write rules/regulations on the implementation of the CPSIA for me to get what I want - or if the CPSIA needs to be amended - or if we need some new laws from Congress.
Here are some of my opinions, but they are just that - opinions and personal ones at that!
1. The basic intent of the law (the CPSIA) is good -- I don't want dangerous level of leads in Children's Products that could dangerously affect kids.
2. The way the CPSIA is written for All Children's Products is a little general and will either require a huge amount of un-affordable testing or a large amount of legal clarifications and legal rule-making -- or it could end up in the courts with precedents from judges that could affect the implementation and enforcement of the law.
3. If rules are not made allowing exemptions from testing final products/units made with materials that have no known lead content (or just natural trace levels of it), those who cannot afford the testing will just stop making things, so there will be a lot of things, that are available for children now, that won't be after the effective date or enforcement of the CPSIA.
Some rules in progress at these links in the Federal Register:
http://www.cpsc.gov/businfo/frnotices/fr09/leadlimits.pdf (aka natural materials exemptions)
http://www.cpsc.gov/businfo/frnotices/fr09/leadprocedures.pdf (aka Notice of Proposed Procedures and Requirements for a Commission Determination or Exclusion)
http://www.cpsc.gov/businfo/frnotices/fr09/leadinaccessibility.pdf (aka Inaccessible Component Parts)
http://www.cpsc.gov/businfo/frnotices/fr09/leadelectronic.pdf (aka Exemptions for Certain Electronic Devices)
If you look at each of these documents, where to send comments by mail, fax or email is in the documents including the Date by which comments must be made. This is public commenting, in the Federal Register, so any public may send in comments!! I believe the deadline on all of these is Feb. 17, 2009 (notice this is the comment period and it ends after the effective date for the CPSIA of Feb. 10, 2009.).
There is also a PDF document regarding a request from the CPSC on comments regarding
"Mandatory Third-Party Testing for Certain Children’s Products Section 102 of the Consumer Product Safety Improvement Act (“CPSIA”)" - http://www.cpsc.gov/about/cpsia/ComponentPartsComments.pdf -- and this has a deadline of Jan. 30, 2009.
4. I am not sure what exactly is going on in the retail markets of Children's Products, but with the General Counsel's opinions on existing inventory, retailers large and small may have a huge problem if they can't get certification of CPSIA compliance by Feb. 10, 2009 - or if a large part of their inventory fails testing (has too much lead in it) and cannot be legally sold. There are some dire predictions (businesses shutting down, bankrupcies, etc.) on the affect on the economy - we shall see what happens.
5. I think some things got left out when they wrote the original bill - I am of the opinion that the biggest matter left out was that suppliers to manufacturers at all levels, but particularly at the bottom level, must test and state the lead content of their supplies. I think that they must be required to put the actual lead content per some measure (ounce, yard, meter, etc.) on the labels/information for the products they are selling to assemblers/manufacturers. AFTER ALL, FOLKS, THE WHOLE POINT IS TO HAVE LEAD-FREE OR LOW-LEAD PRODUCTS FOR THE CHILDREN-IF YOU WANT TO BUY THINGS TO MAKE THINGS WITH NO OR LITTLE LEAD, YOU NEED TO KNOW THE LEAD CONTENT OF WHAT YOU ARE BUYING.
For me, this is a major issue, because all I am really doing with my crocheting and knitting of Children's Products is re-arranging the yarn or thread into something. I want it on the label if there is no lead content or how much lead per yard or per package, etc.
6. Also, though they are addressing this issue to some degree with the proposed rules I list in section #3 of this article above, there may be unnecessary testing required (duplicate testing of the same materials). If the materials that are being used to make something, even if dyed and treated, have no lead or just very low traces of lead (within the limits of the CPSIA) - and it is known and stated from the manufacturer of the materials - then the finished product should not have to be tested. As the law currently stands, the finished product has to be tested even if the components have been tested.
See this presentation to the CPSC on Jan. 22, 2009 from the The Craft Yarn Council Association and The National Needlearts Association regarding lead and phthalates in yarn: http://www.cpsc.gov/about/cpsia/crafts.pdf. This, in particular is siginificant to me with my crocheting and knitting.
In that document is information from testing of yarn and dyes in it. Apparently I don't have to worry that the yarns I have purchased - and probably the crochet threads, too - have too much lead in them to be used to make the Children's Products per the CPSIA limits for lead content, but I can't afford the testing of the finished product/unit and am waiting for Final Rules on these matters from the CPSC.
Hopefully there will be a way for even the dyed yarns and threads to be exempted from testing as long as I can get the information on lead content from the sellers of the yarn. (The natural materials exemption will cover the undyed cotton yarns I have.) But this will depend on supplier certifications being allowed and third-party testing being waived.
7. Also, I am of the opinion that XRF testing with GCC's - not necessarily third-party mandatory testing in accredited labs, which goes into effect in August 2009 - is enough for some Children's Products. But I don't feel qualified to legally state this. I am thinking of mostly smaller items and clothing/textile items. Larger items - especially items made with metals, etc. - should be professionally tested in a third-party accredited lab. Also, I am of the opinion that All Imported Items should require third-party testing in an accredited lab. I am not sure if allowing XRF gun testing without third-party accredited labs for some products would require an amendment of the CPSIA in Congress or if the CPSC can issue some ruling on this.
8. I think there is the possibility that a whole new separate law for the Children's Apparel Products would be a good idea. I think this law should include provisions for natural materials, materials that have no known lead content -- and should specifically ban items and attachments that have known lead content and can be swallowed or chewed on, like rhinestones, swarovski crystals, faux pearl buttons, some metals. Will all metals required for clothing, such as snaps and zippers, need to be made of surgical steel, which apparently does not contain lead -- or can they make some metals for these items that have no or very low lead? I have seen XRF gun testing results stating that some snap components are failing - having too much lead in one snap piece. It would need to be written so as to keep available in the market affordable clothing for children -- including in the Handmade market.
As someone in the Handmade market, which I support (www.buyhandmade.org), I want to continue to make Handmade Children's Products - and I want others to, too.
As an environmentalist and a supporter of a non-toxic environment for all, I want controls and limits on toxic, dangerous substances in products available for sale.
I recommend the following sites for information and data:
The Smart Mama (Jennifer Taggart) http://www.thesmartmama.com/bg/ - or Follow Her on Twitter (http://twitter.com/thesmartmama) - for a lot of information about the CPSIA and what fails and passes in XRF testing for lead.
As a member of ETSY, I have been following this on ETSY and in ETSY chats. Here is their latest action kit, which has a lot of good info, including contact info: http://www.etsy.com/storque/media/bunker/2009/01/CPSIA-Etsy-Resources.pdf
I recommend that individuals should do what they feel is right.
You can write and call your own Congressional representatives - but I believe that in addition to calling, it is effective to fax or mail substansive comments/opinions to their offices.
The Energy and Commerce Committee in the House of Representatives is the Congressional Committee responsible for deciding on re-visiting/amending the CPSIA. Currently, the Chairman is Congressman Henry Waxman, who I have found very good on environmental issues. Their phone number is (202) 225-2927 (I have called them) and their fax number (for faxing written comments/letters) is (202) 225-2525. I recommend calling and faxing written letters.
I would like to bring up one more point, which is something we all must face on this issue. Getting lead out of Children's Products is a good idea. I support this in general for the safety and health of children -- as an environmentalist and humanist. But this is going to require changes in manufacturing and selling of Children's Products - and it may result in some higher prices to consumers. In economics, there is discussion of "external costs to consumers", which the costs of dealing with health problems from lead exposure/poisoning would fall under. Getting the lead out of the products and so making the health risk of exposure to lead in dangerous levels much lower is called in economics "correcting for external costs". But this "correcting " will initally result in higher prices to the consumers for Children's Products -- but in the long run, with fewer external health costs because of lead exposure/poisoning because the risk is lowered significantly, the overall cost in the community may even out - when you consider the high cost of medical care.
But for this to work out in the economy, I think some changes are in order - waste of time and effort with duplicate testing of materials for lead content is going to cost us dearly.
I am hoping that in the long run, with some common-sense rulings, this will all work out --maybe even be cheaper - and healthier - in long run!!
But my biggest "beef" on this is that supplies to manufacturers in all sizes of business must have stated in their labeling what their lead content is per measure so everyone knows what they are dealing with in terms of what things have lead in them - like vinyl and faux pearl buttons, to name a few items than unexpectedly have huge amounts of lead in them way over CPSIA limits (read http://twitter.com/thesmartmama)!!
TO A HEALTHIER WORLD!!
Ruth
Friday, January 23, 2009
"LOVEBIRD IN A HEART" DOILY MADE IT TO THE VOTER POLL FOR ETSY'S GIFT GUIDE "How Do YOU Say Love?"
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
ETSY is putting together a Gift Guide for Valentine's Day - the "Season of Love": How Do YOU Say Love?
There is an ETSY Storque article on it: http://www.etsy.com/storque/etc/vote-how-do-you-say-love-3292/
Here is the actual Voter Poll on ETSY: http://www.etsy.com/voter_list.php?ref=voter&room_id=28
I was quite honored today to find out that my hand-crocheted doily, "LOVEBIRD IN A HEART" made it into the Voter Poll for this Gift Guide.
There is a total of 59 items that made it to this Poll. When I last checked (a minute ago), it showed 988 votes and there is about 6 more days to go on it!!
If you are a member of ETSY, you should vote - you can help to determine what gets into the Gift Guides on ETSY!
I love doing my crochet - especially the finer items that really reflect artistic composition.
Elizabeth Hiddleson, the crochet designer, created this design - as I explained earlier in a post, I have a book with a picture of it in the back of the book - and I created a chart to crochet it from from that picture. I just love the flying bird inside the heart!!
This doily is listed with tags for the following ETSY Teams:
Eco Etsy Street Team-teamecoetsy (http://ecoetsy.blogspot.com/)
ETSY Thread Artists Team-threadartists (http://etsythreadartists.blogspot.com/)
Design Style Guide-interiordesignteam (http://designstyleguide.blogspot.com/)
All of these Teams have some good artists in them, who make and have available for sale in their shops some beautiful - and sometimes even useful - handmade creations!!
Ruth
Monday, January 19, 2009
A new creation in Thread
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
I actually get a lot of pleasure out of creating the designs I do in crochet thread.
My latest completed work is from a pattern by the prolific crochet designer, Elizabeth Hiddleson, though I took some liberties with the pattern and did it a little bit differently and added some 3-dimensional roses.
You can find it here on ETSY: http://www.etsy.com/view_listing.php?listing_id=19963912
But I will share a couple of photos with you. This first one is of the whole doily:
This second one is a closeup of the top half of the doily, so you can see the detail of the hearts, roses and border more clearly.
The pattern is from a book copyrighted 1960, which makes it and the patterns in it Vintage (over 20 years old and this is over 40 years old), so it definitely has a Vintage feel to it, but those of us who just like the detailed lace designs, it is beautiful!!
Ruth
Another Treasury from Etsy Thread Artists - the Colors of Valentines/Hearts/Romance
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
I managed to get another Treasury on ETSY tonight.
It was for my Etsy Thread Artists Team - in the spirit of Valentine's Day!!
Here is the link: http://www.etsy.com/treasury_list.php?room_id=34447
And this is the screen shot of it, but for a good look at it and the items in it, go to the link and click on the pictures you would like to see up close!!
Ruth
Thursday, January 15, 2009
Seasonal Creative Crochet - The Making of "LOVEBIRD IN A HEART"
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
I do various types of crochet because I enjoy doing the craft.
But some of the most fun crochet to do is for the different seasons, including different holidays.
Something I made for Valentine's Day, which is "just around the corner" was a lot of fun and an exercise in creativity.
I call it "LOVEBIRD IN A HEART".
It is so very lovely with the bird in flight and the butterfly and the curlycues.
The inside and major part of this piece is done in Filet Crochet, which is creating designs or images with solid blocks of crochet and open spaces.
But this design is also shaped - in the shape of a heart - and the bird in flight and the butterfly are arranged with curlycues around them that mirror each other exactly on both sides.
So, all the rows with blocks and open spaces have to be done perfectly for the whole design to come out.
Here is a closeup of the inside design:
On the Way to protecting More Wilderness - the healthiest land on the planet!!
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
At 8:14 PM this evening, the Press-Enterprise Riverside County published an article - the Senate has approved a new bill for protecting as Wilderness about 2 million acres nationwide and about 190,000 acres in Riverside County.
Article: http://www.pe.com/localnews/rivcounty/stories/PE_News_Local_S_wilderness16.1.3fb1ea6.html
Quoting the article:
"Although the legislation still needs House of Representatives approval and the president's signature, backers were optimistic because the House approved a version of the bill last year and Obama ran on a pro-environment platform."
Looks good.
We need what Wilderness we have left protected.
Just a few days ago I quoted Aldo Leopold on Wilderness from his book, A Sand County Almanac and I am going to reiterate one of the quotes from "Wilderness For Science":
"One cannot study the physiology of Montana in the Amazon; each biotic province needs its own wilderness for comparative studies of used and unused land."
So, for planet-wide health, we need the healthy Wilderness lands protected, but they also serve to help us in their own biotic provinces in restoring other lands to a healthy condition as these Wilderness lands are examples/samples of healthy land in their biotic provinces.
Another quote from the same writing by Aldo Leopold:
"In many cases we literally do not know how good a performance to expect of healthy land unless we have a wild area for comparison with sick ones. .... In short all available wild areas, large or small, are likely to have value as norms for land science. Recreation is not their only, or even their principal, utility."
Though I think recreation in wild lands such as hiking, climbing, snow-shoeing and river-rafting is important for people to do, I am really concerned about the land health on our planet and protecting more Wilderness gives me hope for improving land health as well as protecting it!
From the above-referenced article, I understand that this bill incorporates many bills - about 160 - with support from California Congressional legislators Senator Barbara Boxer, Senator Dianne Feinstein and Representative Mary Bono Mack.
Also, from the article, I understand that some of the Wilderness protected will be in the Sierra Nevada - a globally significant Biodiversity Hotspot.
Thank You to them -- and all the supporters who will make it happen!!
Ruth
Monday, January 12, 2009
Logged/Slashed Rainforests Are Regrowing, but Still Have Issues
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
I read 2 articles today concerning the conference/symposium at the Smithsonian National Museum of Natural History in Washington D.C. about the rainforests.
I don't really have all the data that was discussed or presented, but the 2 articles have slightly different perspectives.
Article from "Times Online": Apocalypse delayed: tropical forests fight back as farmers flee
Article from "globeandmail.com/science": Regrowing rain forests still have issues
Also interesting that both are from non-U.S. sources on the Internet, but the Smithsonian is in the United States. The "Times Online" is from London; the "globeandmail.com" is from Canada.
In the first article about "Apocalypse delayed", a Professor Laurance is quoted: “We are still having a devastating loss of forests. It’s just that there’s some suggestion now that it is partly offset by the regeneration of secondary forest.”
In the second article, other statements by the same Professor are given:
"But these young forests cannot support what the old-growth forests did, said William Laurence, also of the Smithsonian Tropical Research Center." - and
“There's just no way that secondary forests are going to capture a lot of the biodiversity and critical ecosystem,” he said. “They're also much more vulnerable to fire.”
I find this discussion all very interesting. It made me think almost immediately of a chapter in Aldo Leopold's book, A Sand County Almanac, Part IV The Upshot, "Wilderness for Science" - where he discusses the value of wilderness for science. Here are 3 of my favorite quotes from this section on this subject in the order they are in this section of his book.
1. "Many forest plantations are producing one-log or two-log trees on soil which originally grew three-log or four-log trees. Why? Thinking foresters know that the cause probably lies not in the tree, but in the micro-flora of the soil, and that it may take more years to restore the flora than it took to destroy it."
....
2. "Palentology offers abundant evidence that wilderness maintained itself for immensely long periods; that its component species were rarely lost, neither did they get out of hand; that weather and water built soil as fast or faster than it was carried away. Wilderness, then, assumes unexpected importance as a laboratory for the study of land-health."
....
3. "One cannot study the physiology of Montana in the Amazon; each biotic province needs its own wilderness for comparative studies of used and unused land."
Also, it should be pointed out that they are discussing the first logging/slashing of the rainforest and the regrowth is secondary forest and seems to be natural regeneration, which is relatively good.
Referring to what Aldo Leopold stated about forest plantations with smaller trees (one-log is smaller than three-log or four-log) - quote #1 above - and what this Professor Laurance is quoted as saying, it is fairly obvious that the deforestation affected the micro-flora of the rainforest soil and that even though there is regrowth, the regrowth is not as strong as the original old growth that was in the rainforest.
But hopefully there is some native original rainforest in the same biotic province that can be studied for restoring more fully the regrowth, if some scientists will follow through with it!
I find it very interesting to apply what I have read in books to what is going on today in the world!!
Restoration can be done - and it is significant in the high biodiversity rainforests, even if the restored areas are not quite as good as the original forests.
If you are interested in the land health of this planet, I strongly encourage you to read Aldo Leopold's books, which you can find listed here: http://www.aldoleopold.org.
And if you are interested, you might want to take a look at my other posts under the Label "forest" here on my blog!
By the way, Aldo Leopold restored forest!!
Ruth
Saturday, January 3, 2009
A FEW FAVORITES FROM DESIGN STYLE GUIDE (AKA INTERIORDESIGNTEAM)
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
As one of the several hundred members of Design Style Guide - a Team on ETSY, I periodically am looking at Treasuries and seeing work of the members, they become part of my Favorites on ETSY.
I like to share a few of them with readers, so here are a few who make some really artistic home decor.
1. Fabric Wall Art - painting and stitching on fabric then quilted - closeup of a Tulip by lizplummer -- http://www.etsy.com/view_listing.php?listing_id=9404840
2. A pillow with Blue Florals by FloraDoraInc -- http://www.etsy.com/view_listing.php?listing_id=14603880
3. A stained glass star "Rainforest" by Pamela Angus -- http://www.etsy.com/view_listing.php?listing_id=19232774
4. Hand-blown glass vase -- "All of the colors and decorations are encased within the gathers of crystal clear glass." by Art Glass Sinks -- http://www.etsy.com/view_listing.php?listing_id=18401648
5. A wooden display bowl showing the wood grain by Aussie Woodcraft -- http://www.etsy.com/view_listing.php?listing_id=7869870
Enjoy looking at some of the artistic decor you can find on ETSY!!
Ruth
Thursday, January 1, 2009
IT'S A NEW YEAR!!
RSS Designs In Fiber - Internet Shop of Handmade Items
RSS Designs Wearable - Internet Shop of Wearable Items
It is a New Year - I was still up last night at midnight when it became 2009 and I thought - so now it is the new year and I am looking forward to some new things!!
One of the subjects frequently mentioned this time of year is New Year Resolutions.
Well, I am all too often making resolutions about different things and I live by some resolutions all the time and it doesn't have to be a New Year to make them!!
Actually, for some reason or reasons, this New Year I am hopeful of some good changes in some areas of life that I care a great deal about.
And one of the things I am grateful for is, of all things, that I found and got on Twitter!!
I am http://twitter.com/rssdesigns on Twitter.
I have found that Twitter is a great place to find out information and to communicate and make fast originations about things I want to make known publicly.
I have found some good connections through Twitter - and have found some people who are doing some really good things!!
The world and the Internet are vast -- I have found that checking the Profiles of people/groups on Twitter, I can find people with common interests and goals and connect up!!
You can do fast, quick posts, Direct Message, Reply, Follow -- and do it whenever you want or can! If you haven't tried it, you might want to!!
I am expecting some changes in our world in this New Year -- some facing up to realities and one of those is that this planet can physically only handle so much and we need to re-organize and restructure life on this planet so we can live here.
I put this on Twitter and I am going to say it again:
We all need to live within our means and do our very best to have an ecological footprint for one person.
Well, I am not sure - but the last time I took a "test" for my ecological footprint, it was pretty close to 1 person.
But I don't drive and primarily use public transportation, I do my best to buy "local" foods (within a 200 mile radius -- like I told someone at a local grocery store where they had cherries from Chile -- I don't buy food from overseas), I grow my own herbs and at times some veggies and, during the months when it is available, I get my fruit from a local orchard where I can pick it if I have time.
Now I am going to be concentrating on make children's clothes and other "wearables" in natural cotton yarns (Peaches and Creme worsted cotton in white and ecru). Watch for these in my shop, http://www.rssdesignswearables.etsy.com/ .
If you want to make some New Year Resolutions, go right ahead!!
But I believe in making them all year round -- as needed!!
Ruth