First, I am concerned that the proposed standard will not address the biggest safety problem we have seen with slings, namely the deaths attributed to positional asphyxia. This is not for lack of trying. The CPSC staff has confronted this issue directly, but was unable to find a satisfactory solution. Removing the recommendation for cradle carry would be one step to address the positional asphyxia risk as well as education, but others have written that they are not interested in hearing about education... Despite this shortcoming, the proposed standard may impose very substantial costs on manufacturers, most of whom are small or very small. Most of these costs would not result from any changes to the product, but only because the new mandatory standard would trigger the requirement of third-party testing under the Consumer Product Safety Improvement Act (CPSIA). The testing costs anticipated by CPSC staff are significant enough to consume all the profits from small batch operations. Many small manufacturers may be forced out of the market. Can we focus on this a bit more with comments especially among the small scale handwoven manufacturers? All of her points I believe are valid and can be found here: cpsc.gov/en/About-CPSC/Commissioners/Ann-Marie-Buerkle/Ann-Marie-Buerkle-Statements/Commissioner-Buerkle-Statement-on-the-Proposed-Standard-for-Slings/
Posted on: Fri, 26 Sep 2014 03:11:58 +0000
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