CPSC Workshop Day 1

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.

CPSC Workshop on CPSIA

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.

RDIA Detergent Determinator – Up and Running!

Detergent DeterminatorWe 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.

Bamboo gets hot

Bamboo has been, for awhile now, a very hot fabric. Seemingly new, altogether different, and full of remarkable qualities. Turns out bamboo textiles are also hot in terms of being sought after by the FTC for being falsely labeled and a fabric commonly misrepresented to the consumer.

The Federal Trade Commission (FTC) recently charged four companies with deceptive labeling and advertising because the bamboo used in their textiles was actually rayon but not disclosed as such. (And getting on the FTC’s radar also landed 3 of the 4 companies with additional charges for violating other labeling/advertising regulations, including failure to note country of origin.)

The rulings are an effort at enforcement but also one of education. The Federal Trade Commission, in working to protect the consumer, wants the general public to know that

“the soft ‘bamboo’ fabrics on the market today are rayon. They are made using toxic chemicals in a process that releases pollutants into the air. Extracting bamboo fibers is expensive and time-consuming, and textiles made just from bamboo fiber don’t feel silky smooth. There is also no evidence that rayon made from bamboo retains the antimicrobial properties of the bamboo plant …”

(See the FTC’s recent consumer alert: Have You Been Bamboozled by Bamboo Fabrics?)

The Real Diaper Industry Association has been following these developments for over a year and working hard to educate its members on compliance with federal regulations. Member meetings in Las Vegas last year included a talk on greenwashing, labeling and the use of the term “organic.” This year there will be another session on regulations including CPSIA and more on labeling. (Non-members welcome at this year’s cloth diaper business meetings Sept 14-15 in Las Vegas. Register here.)

So what do you need to know to avoid being Bamboozled by labeling claims on what many thought to be a trendy and totally environmentally friendly fabric?

The Federal Trade Commission has been remarkably clear this time and have published a series of documents which are easy to read, informative and straight to the point.

“If you sell clothing, linens, or other textile products, you’re responsible for making truthful disclosures about the fiber content. If your product isn’t made directly of bamboo fiber – but is a manufactured fiber for which bamboo was the plant source – it should be labeled and advertised using a generic name for the fiber, such as rayon, or ‘rayon made from bamboo.'”

Consumers are urged to educate themselves and know what to look for, what to ask and how to shop for their green goodies with a clean conscience.

Manufactures need to keep themselves educated and seek to help their own customers understand the fabrics used in their products.

Retailers need to understand what they are selling and be clear with customers about products.

The RDIA website is one place to find information and news on cloth diaper industry related topics like fabric, labeling, and laundering. Members can also post questions or news bits to the forum and seek assistance from peers, committee members, and board members. We all have a great deal of information to share and together we can help make sure we are neither Bamboozled nor Bamboozling.