Every few years, it is standard for associations to review the make-up of their members and modify board representation to accurately reflect their membership. For example, diaper service membership had grown considerably, but diaper services were still represented by only two board members. With this discrepancy and others in mind, the RDIA board proposed By-Law changes in September of 2011, and these By-Law changes were overwhelmingly passed by 49-3 on February 7, 2012.  These changes improve our association in many ways.

More Diaper Service Board Members, Fewer Manufacturer and Retailer Board Members

RDIA membership is currently comprised of 17 Manufacturers, 50 Retailers, 71 Diaper Services, 7 Artisan Manufacturers, and 21 Associate Members. Since the resurgence of diaper services has brought more diaper service members to RDIA, the board wanted these members to be properly represented. Under the new By-Laws, manufacturers, retailers, and diaper services each have three board members.

New “At-large” Seats Provide Flexibility

Sometimes there are experienced and enthusiastic members that would like to join the board, but there are no vacancies on the board within their category. To encourage these interested members to join the board, we created three “at-large” board seats.

Small Manufacturers Become “Artisan Manufacturers”

The original intent of a “Small Manufacturer” category was to ensure all manufacturers were represented within the association, regardless of size. Since there have been, and always will be, professional makers sewing cloth diapers by hand and selling directly to end users, the original board wanted to ensure the voice of these cloth diaper makers, and their unique needs, were heard separate from those of larger manufacturers whose business is primarily wholesale.

Over time, however, the label “Small Manufacturer” brought confusion. Many manufacturers identified with the category name of “Small,” even though they weren’t sewing their diapers themselves by hand. So, the board decided to clarify this by adding “handmade” and renaming the category “Artisan Manufacturers.”

Manufacturer Member Requirement less Limited

Manufacturers used to be required to meet two of the following three criteria: 1. Gross sales over $100,000/year, 2. Has wholesale accounts (their product sold by resellers), and 3. Be in business for over 1 year. This excluded some smaller or start-up businesses manufacturing for wholesale, and was one of the reasons newer businesses often joined as “Small Manufacturer,” so this section was removed.

Cloth Diaper Information Services Category Eliminated

This was probably the only change that isn’t as intuitive as all the others. Historically, Cloth Diaper Information Services have not stepped up to serve on the board after Jennifer Liptrot (Diaper Pin) served. This board seat had been vacant since August 2009. For a full year, there was only one member in that category. With that in mind, the board reevaluated diaper service information services.

When the board was first created, the founding members sought a place on the board for businesses like Diaper Pin, where cloth diaper information was presented to consumers and businesses, who were then redirected to other cloth diaper businesses. Since that time, the era of blogging has taken over. In this new climate, cloth diapers are highlighted on hundreds of blogs. These blogs help spread the word of cloth diapers in our industry, and consumers as well as RDIA businesses are grateful for their contributions. Last year, a handful of bloggers joined RDIA in the diaper information service category.

Over time, blogs have become a form of publishing and public relations. Blogs are popular, social, informative, and can have political impact. The natural category for bloggers seems to lie within the Associate Membership category, along with all other businesses  and organizations that support the cause of RDIA, want to be an integral part of its future, interact with its members, and show that together our industry is stronger than as individuals. In my research on trade associations, this is where bloggers typically fall. The decision was further encouraged because no information service members showed interest in representing their category on the board in 2011 when there was an open seat.

An association is a living, breathing entity that constantly changes to best serve its industry.  We can only assume that we will revisit this decision and reevaluate cloth diaper bloggers and other cloth diaper information services in the future. In the meantime, we will work with bloggers as associate members, offering an open dialog to better our industry, as well as opportunities for interacting with all RDIA members. We have offered all previous cloth diaper information service members a full one-year extension to their now associate memberships. We look forward to a continued relationship between cloth diaper bloggers and other cloth diaper businesses.

How Will These Changes Be Phased In?

The board analyzed several scenarios for phasing in the new board member distribution. The goals were to ensure all current board members would serve out their terms, minimize short terms (less than three years), and keep the board as balanced as possible. Ideally, we wanted to see new board members elected each year for each of the large categories: manufacturers, retailers, diaper services, and at-large.

The graph below shows our idea for implementing the new board seats. Please click on it to see a larger view.

Become a Board Member

There will be a total of six vacancies on the RDIA board this year (2 Diaper Service, 1 Manufacturer, 1 Retailer, and 2 At-Large). The second diaper service seat and the second at-large seat will be short terms as we work toward the ideal of each category having one seat up for election each year.

RDIA Board Members Matt Guckin, Mandi Meidlinger, and Catherine Bolden.

As elections approach, be sure to ask board members questions about what it takes to serve on the board, why board members devote so much time to our industry, and how you could contribute. Reach out to fellow members and encourage them to run for a board seat. Then, be sure to attend the “State of the RDIA” webinar that we’ll be holding for members in a couple of weeks.

The four major roles of RDIA and associations in general are:

1. member education and benefits,
2. research and statistics,
3. standardization, and
4. lobbying.

On a more basic, or perhaps human, level, an association is a group of people who find strength in numbers while sharing a common interest. According to ASAE (the American Society of Association Executives), associations are founded on democracy, volunteerism, and common interest that are the heart of the American experience.

When we work together, big and small, we strengthen our own industry while advancing society. Our industry needs leaders, and this year is a great time to lead the future of the association.

Mandi Meidlinger
Jillian’s Drawers
Chair, Real Diaper Industry Association

On January 6, 2010, Intertek, a major testing provider, held a webinar on CPSIA changes: “Revised Rules of the Road: How Changes to CPSIA Testing and Certification Requirements Impact You.” RDIA member Alison Maynes of LolliDoo Diapers attended the webinar and provided the report below.

The Challenge

Since the enactment of the Consumer Product Safety Improvement Act (CPSIA) last year, many have struggled to understand and comply with the law’s new product testing and certification requirements. In a series of votes last week, the U.S. Consumer Product Safety Commission (CPSC) announced new enforcement policies and the agency’s intention to take up an Intertek petition aimed at easing the burden imposed by the CPSIA—making testing and certification for mandatory safety standards more efficient and effective. However, several of these measures are provisional in nature, and have conditions on when they can be utilized and how they can be relied upon by manufacturers and importers who are required to ensure their products meet U.S. standards.

The Solution

Intertek is committed, not only to providing you with the most accurate and timely information about these developments, but also finding effective and affordable solutions for your testing and other product safety needs. Toward that end, on January 6, 2010, Intertek experts will be hosting a free webinar to explain in detail last week’s actions by the CPSC, and what each does or does not mean to you in practical terms. The webinar will include a Q&A session to enable participants to have their specific questions and concerns addressed.

The CPSC last week voted to:

1. Extend the existing “stay” (delay) of enforcement for the CPSIA requirement that products covered by the federal safety standards be certified with a General Conformity Certificate, or “GCC.” This applies to a number of (but not all) product safety standards, notably the ban on lead in the content (substrate) of children’s products, the ban on certain phthalates (plastic softeners) in toys and child care articles, and the general toy safety standard (ASTM F-963). However, compliance requirements for lead in content, phthalates and ASTM F-963 are still in effect.

2. Adopt a new “Interim Enforcement Policy” that, under certain circumstances, will allow the certification of products for the lead-in-paint standard (and ultimately the lead-in-substrate standard) based on testing components (including paint) rather than testing only the final products.

3. Publish for public comment and formally consider a petition submitted by Intertek and the American Apparel and Footwear Association (AAFA) to specifically allow certain test methods for the lead-in-paint standard (specifically “spray sampling,” “multiple stamping” and “finished component testing”) that will save manufacturers both time and money in testing products.

Each of these votes, along with issues surrounding them, is admittedly complex. All of these actions taken by the CPSC could be superseded by a broader testing regulation the agency is expected to issue sometime next year which can impact your holiday 2010 products. However, with careful understanding and application, manufacturers and importers of consumer products can ensure that their products meet all applicable safety standards and that they do not incur unnecessary expense or delay in testing and certifying their products to those standards.

Stay of Enforcement

CPSC voted to lift the stay for certain standards beginning February 10, 2010. This continues the stay for lead and substrate one year longer.

The stay of enforcement is continued for general wearing apparel, which applies to cloth diapers.

Component Testing

CPSC now allows component testing for certain products for lead and paint standards.

The component testing documents allows for component testing to children’s products subject to the lead paint and lead substrate standard – 300 parts per million. As long as your product meets the standard, you don’t need third-party testing or the GCC.

Though the paint standards don’t apply to diapers, this gives an indication of the direction CPSC can be expected to go in their interpretations of the law.

General Conformity Certificates

You can certify as a manufacturer (not retailer) based on a test by an approved third-party lab. Based on a passing test report, you can issue a GCC based on another issuance of a certificate.

Compliance Testing

A sample sent for testing must be representative of what is used on the product, though it doesn’t need to be the same quantity.

There is a very detailed testing guidance document on the CPSC website. This document has not been voted on as regulation at this time. It is, however, a good indicator of what will be in place in the near future.

Children’s Product Definitions

Note the CPSC is working on a new regulation of the terms “children’s product,” “toy,” and “child care articles.”

Bottom line: make sure your product complies with the standards set out in the CPSIA.

I should receive a PDF document of the presentation soon, so please email me if you’d like a copy: alison@lollidoo.com.

Alison Maynes
LolliDoo Diapers

Dan Marshall of Peapods Natural Toys and Baby Care traveled to Washington DC this week to represent Handmade Toy Alliance and Real Diaper Industry Association at a Consumer Product Safety Commission workshop on CPSIA. Seeing him hold up a pink diaper cover for the CPSC commissioners to see was a moment we can all be proud of. This is when we know we have been noticed and heard. You can watch the videos of the workshop on the CPSC website.

HTA board members present petition of 25,000 signatures to Commissioners Tenenbaum and Adler. HTA members Mary Newell, Cecilia Leibovitz, Dan Marshall, and Kate Glynn.

I have just returned from two intense days at the CPSC headquarters, where I represented small batch manufacturers who are struggling to comply with the requirements of the CPSIA on behalf of both the Handmade Toy Alliance and the Real Diaper Industry Association.

I feel very strongly that we accomplished a lot at these workshops, much of it behind the scenes. This was primarily a CPSC event, so we didn’t get a lot done on the Hill, although several HTA members had good meetings with their representatives while they were in town.

The workshops themselves were interesting. It was a very good thing we were there to counter YKK, who was there in force to oppose component testing, mostly because they don’t want to pay for it. HTA Treasurer Mary Newell of Mary’s Soft Dough and I argued in the Friday morning session that small batch manufacturers need to be treated differently and need component testing in order to survive. I used a diaper cover to illustrate how RDIA members would benefit from component testing because we could share the costs of certifying snaps, velcro, polyurethane laminate, etc. It was made clear to us in a number of ways that component testing will be approved but that CPSC staff are working on the details.

We also got some agreement from some surprising sources, including Dr. David Pittle, a longtime consumer advocate and one of the first CPSC commissioners, who said during the Friday morning session:

“There is something I’ve heard over the last few days, which I’ll never be the same on because it was new to hear it all. , , and that is the important distinction between large batch manufacturers and small batch manufacturers. . . . The small batch manufacturer almost needs like a section of the regulation. . . they need a very careful and judicious way of making sure they can do it and survive.”

These comments were extremely encouraging.

We had the opportunity to speak at length with Pittle and several other consumer group representatives, including Rachel Weintraub of Consumer Federation of America. They were cautiously sympathetic to our position. We shared the HTA Seeds of Change document with many of them, and I think we truly conveyed that we are very different from mass market producers. I think we also finally laid to rest with them the idea that we might be astroturf. We made the point that we’d like to fix this law sooner rather than later.

We presented our petition of 25,000 signatures to Commissioners Tenenbaum and Adler yesterday morning in a formal reception. Tenenbaum was courteous and said she reads all of our emails. We also got a chance to discuss many issues with Commissioner Adler, including that we need more time for component testing and ASTM requirements to be worked through.

Above all, I got the sense that the CPSC Commissioners are concerned for our businesses and are truly interested in our input. We are being heard and we are clearly influencing how this law will be enforced. Hopefully we will soon be able to influence the way it is written as well.

As many of you know, I was to represent RDIA this week in Washington, DC, at the CPSIA workshop on compliance, sampling, testing, challenges, and impact.

Unfortunately, a series of family medical emergencies kept me from traveling at the last minute. The good news is Dan Marshall was already planning to be in attendance representing the Handmade Toy Alliance, and he agreed to represent RDIA in my absence. Dan is an RDIA retailer member with Peapods Natural Toys & Baby Care.

The workshops are broadcast via webcast live throughout the day. Today’s series begins at 9:30am Eastern and runs through 4:30pm. You can view the webcast at cpsc.gov

Thursday, December 10, 2009 Workshop Summary

Attendees were welcomed by Consumer Product Safety Commission Chair Inez Moore Tenenbaum and reminded that comments are open until January 11, 2010.

CPSIA Review.
The specifications of CPSIA were reviewed and everyone was reminded that this IS currently the law and compliance is required. A slide show illustrated several types of products which fall within the law and why.

Hazard Reduction.
Differentiations between Reasonable Testing Program and Third-party Testing were clarified and questions posed. General Certificates of Conformity ARE required, and the methods one uses to obtain them vary based of product type, source considerations and more. There will be continued discussion on Third-party Testing and all that in encompasses. (Discussion points: manufacturer’s judgment, historic risk.)

Component Testing.
Component Testing is that testing done when the rest of the product is not needed in the overall determining of compliance. This was a fresh perspective on an old term. It isn’t a new definition, but looking at it this way illuminates different aspects of the law. From all that is being said, Component Testing will “quite likely happen” although to what extent is certainly yet to be determined. (Discussion points: What kind of systems should be in place for suppliers? Who fits the definition of supplier? Where does the ultimate responsibility fall?)

Random Sampling.
Participants discussed random sampling for several hours. There are statistical methods in place which afford a “true random” sample. Such sampling is a business best practice regardless, but making sure those samples are statistically random increases effectiveness of the entire testing process and reduces the impact of “estimates.” (Discussion points: is sampling to be done per lot, production run, day, or month? To what extent can a manufacturer introduce their own responsibility when devising a sampling plan? Is a practical approach enough?)

Cost of Testing.
This section was disturbing in regards to the range considered to be acceptable. Single product testing for lead was quoted as varying from $20 to $100+ with the lower end being testing done in China. Clearly, sending single items to China for testing is neither feasible nor at all desirable for so many small cloth diaper manufacturers. I think we need to be clear about our own testing costs then make sure we tell the CPSC what these costs are.

Design Element vs Manufacturing Error.
An interesting statistic that 2/3 of all products considered unsafe (unsure of reference) were found to be unsafe at the design NOT at manufacture. Toys are legally subject to design safety testing. Implications here could be far reaching and provide some food for thought.

Be sure to tune in for the Day 2 summary to hear about Dan Marshall holding up a pink diaper cover and ask for a full product exemption.

We are so excited to announce the launch of a great new online cloth diaper detergent search tool from the Real Diaper Industry Association that will help make it even easier to figure out your diaper washing routine – the Detergent Determinator!

It’s a nifty tool that lets you find out which detergents contain what, and it was created especially to make things easier for cloth diapering folks!

Browse Detergents by Name

Here’s how it works. First, go to the Detergent Determinator page. Then:

1. Type in the name of the detergent you want information about
2. Click Submit
3. And voila! You can see if that detergent contains enzymes, brighteners, dyes, fragrance, or fabric softeners. Then, you can compare that result to whatever your diaper manufacturer suggests avoiding.

Browse detergents by characteristic
Or you can also browse by detergent characteristics using the Detergent Determinator:

1. Check the additives you want to find or avoid
2. Choose any other filters you’d like (HE certified, liquid, Canadian availability etc)
3. Click Submit
4. And bam! Couldn’t be easier. Now you have a list of detergents fitting your criteria.

The important part is to always check what your diaper manufacturer recommends, and avoid any additives or ingredients that they prohibit.

So, enjoy! It’s easy, and chock full of information.

A few notes on the RDIA and detergents in general

Please keep in mind that this is only a reference tool and detergent manufacturers often change ingredients without informing the public (or us!). Additionally, detergents react differently based on many factors including quantity of detergent, quantity of water, and water hardness. If your baby ever develops a rash which can not be explained, please consider that it may be the detergent or your wash routine.

Contact the manufacturer of your diapers for advice if you are unsure. They are always willing to help.