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Happy 1 Year, CPSIA- AAFA - paper is the right choice for clothes & shoes
17
Aug '09
AAFA celebrates one-year anniversary of the Consumer Product Safety Improvement Act, landmark legislation that provided needed resources to the Consumer Product Safety Commission to improve consumer product safety. We are also commemorating the second of three phase-in dates for reductions in lead standards for children's products.

As tradition holds, the first anniversary gift is paper. For our anniversary gift, Congress should consider giving the producers of children's clothing and shoes a thoughtful piece of paper: legislation allowing the U.S. apparel and footwear industry the opportunity to continue making safe clothing and shoes.

The CPSIA was an effort to adapt consumer product safety to the changing manufacturing landscape. While well-intentioned, the CPSIA has unduly burdened businesses by shifting focus away from risk toward legal compliance. As a result, companies that manufacture and sell safe products have been forced to shut down.

The legislation went far beyond its intended purpose of keeping unsafe and dangerous toys off store shelves by creating a “guilty until proven innocent” compliance environment — even for products that have always been safe. As a result, manufacturers of children's products are spending tremendous resources in duplicative testing of their products simply to comply with the legislation. These extra costs are doing little to improve public health or provide safety, and they are adding enormous pressures to companies already scrambling for ways to cope with the economic downturn.

The U.S. apparel and footwear industry has been a victim in this unfortunate debate that pits compliance against safety. We believe we have a strong safety record. While any recall is one too many, the amount of recalls in our industry in 2008 equaled less than 0.0082 percent of total merchandise sold. To give you an idea of that figure: If a football player were to stand at one end of a football field and run 0.0082 percent of the way to the other goal line, he would travel only a small fraction of an inch.

For us, product safety is engineered into clothing and shoes from the start. That is why we need strong and clear product safety rules that can be communicated and understood up and down the supply chain. However, the CPSIA's rigid parameters have eliminated key “flexibility” and “risk assessment” tools that are needed for the product safety system to work efficiently. And with some rules implemented retroactively or being announced only a few days before they take effect, the system falls apart.

We will always work with the CPSC and consumer interest groups to determine what, if any, product safety problems exist in the industry and how to best rectify them. Congress should encourage this cooperative environment because it alleviates many of the current burdens the CPSIA imposes on industry — burdens that do not improve consumer safety. This transparent process creates a risk-based, common-sense product safety regulatory network that is agreeable to all stakeholders.


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