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	<title>Comments for WeMakeItSafer Blog</title>
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	<link>http://wemakeitsafer.com/BlogPage</link>
	<description>Safety Matters</description>
	<lastBuildDate>Fri, 08 Jan 2010 16:31:57 +0000</lastBuildDate>
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		<title>Comment on Lead, Phthalates and Sellers of Children’s Products – What’s All the Fuss?   An Explanatory Overview for Consumers by CPSC Postpones Testing and Certification Requirements for Some &#171; WeMakeItSafer Blog</title>
		<link>http://wemakeitsafer.com/BlogPage/2009/01/lead-phthalates-retailers_explanation-for-consumers/comment-page-1/#comment-1496</link>
		<dc:creator>CPSC Postpones Testing and Certification Requirements for Some &#171; WeMakeItSafer Blog</dc:creator>
		<pubDate>Fri, 08 Jan 2010 16:31:57 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=38#comment-1496</guid>
		<description>[...] to certification and testing requirements.  As stated in our earlier article explaining the Lead and Phthalate Bans, as of August 14, 2009 products intended for children twelve and under cannot contain lead (in [...]</description>
		<content:encoded><![CDATA[<p>[...] to certification and testing requirements.  As stated in our earlier article explaining the Lead and Phthalate Bans, as of August 14, 2009 products intended for children twelve and under cannot contain lead (in [...]</p>
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		<title>Comment on CPSC Stay on Testing and Certification Requirements: What Does it Mean to Manufacturers and Retailers? by CPSC Postpones Testing and Certification Requirements for Some &#171; WeMakeItSafer Blog</title>
		<link>http://wemakeitsafer.com/BlogPage/2009/01/cpsc-stay-on-testing-and-certification-requirements-what-does-it-mean-to-manufacturers-and-retailers/comment-page-1/#comment-1495</link>
		<dc:creator>CPSC Postpones Testing and Certification Requirements for Some &#171; WeMakeItSafer Blog</dc:creator>
		<pubDate>Fri, 08 Jan 2010 16:31:41 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=37#comment-1495</guid>
		<description>[...] Because of the recent meeting and vote, there will not be another vote to lift the stay on or prior to February 10, 2010.  To understand why the stay was originally put in place read our earlier blog post about the January 2009 stay and what it means to manufacturers and retailers. [...]</description>
		<content:encoded><![CDATA[<p>[...] Because of the recent meeting and vote, there will not be another vote to lift the stay on or prior to February 10, 2010.  To understand why the stay was originally put in place read our earlier blog post about the January 2009 stay and what it means to manufacturers and retailers. [...]</p>
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		<title>Comment on Safety To-Do #5:  Install at Least One Carbon Monoxide Detector in Your Home by Bill</title>
		<link>http://wemakeitsafer.com/BlogPage/2009/02/safety-todo-carbon-monoxide-detector/comment-page-1/#comment-283</link>
		<dc:creator>Bill</dc:creator>
		<pubDate>Sun, 06 Dec 2009 19:12:10 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=36#comment-283</guid>
		<description>I lost my life and family to carbon monoxide. You don&#039;t have to.  

CO detector are sooo sooo sooo important. They should be mandatory in building codes everywhere. Get one. Do not put it off.

50,000+ people in the US are poisoned each year and KNOW they have been poisoned. 

Many many more are poisoned but don&#039;t know its carbon monoxide that&#039;s causing their symptoms. Good info for anyone that wants to know more http://www.carbon-monoxide-survivor.com/carbon-monoxide-poisoning-symptoms-multiple-exposures.html</description>
		<content:encoded><![CDATA[<p>I lost my life and family to carbon monoxide. You don&#8217;t have to.  </p>
<p>CO detector are sooo sooo sooo important. They should be mandatory in building codes everywhere. Get one. Do not put it off.</p>
<p>50,000+ people in the US are poisoned each year and KNOW they have been poisoned. </p>
<p>Many many more are poisoned but don&#8217;t know its carbon monoxide that&#8217;s causing their symptoms. Good info for anyone that wants to know more <a href="http://www.carbon-monoxide-survivor.com/carbon-monoxide-poisoning-symptoms-multiple-exposures.html" rel="nofollow">http://www.carbon-monoxide-survivor.com/carbon-monoxide-poisoning-symptoms-multiple-exposures.html</a></p>
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		<title>Comment on WeMakeItSafer is Prepared for New Tracking Label Laws by Sarah Natividad</title>
		<link>http://wemakeitsafer.com/BlogPage/2009/07/wemakeitsafer-is-prepared-for-new-tracking-label-laws/comment-page-1/#comment-2</link>
		<dc:creator>Sarah Natividad</dc:creator>
		<pubDate>Mon, 27 Jul 2009 22:30:12 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=8#comment-2</guid>
		<description>Tracking labels should save you a lot of money in data entry costs!  Thanks to the vagueness of CPSC&#039;s &quot;guidance,&quot; there will be lots fewer products available!
</description>
		<content:encoded><![CDATA[<p>Tracking labels should save you a lot of money in data entry costs!  Thanks to the vagueness of CPSC&#8217;s &#8220;guidance,&#8221; there will be lots fewer products available!</p>
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		<title>Comment on Safety To-Do #11:  Check Bicycle Helmets by Ajlouny</title>
		<link>http://wemakeitsafer.com/BlogPage/2009/04/safety-todo-check-bicycle-helmets/comment-page-1/#comment-3</link>
		<dc:creator>Ajlouny</dc:creator>
		<pubDate>Sat, 18 Jul 2009 05:19:02 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=21#comment-3</guid>
		<description>I would also recommend making sure that anytime you family is on a bicycle to always wear your helmet, even if it&#039;s for a very short ride or just around the corner from home.
</description>
		<content:encoded><![CDATA[<p>I would also recommend making sure that anytime you family is on a bicycle to always wear your helmet, even if it&#8217;s for a very short ride or just around the corner from home.</p>
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		<title>Comment on 2009 Bicycle Helmet Safety Guidelines by Ajlouny</title>
		<link>http://wemakeitsafer.com/BlogPage/2008/12/2009-bicycle-helmet-safety-guidelines/comment-page-1/#comment-5</link>
		<dc:creator>Ajlouny</dc:creator>
		<pubDate>Sun, 26 Apr 2009 22:25:05 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=54#comment-5</guid>
		<description>Thank you for making this information public and advocating for more helmet safety.  It&#039;s one thing that most parents don&#039;t give a second thought to when their child gets on their scooters, skate boards, and bikes.  The possibly of getting a head injury is huge when not protected.
</description>
		<content:encoded><![CDATA[<p>Thank you for making this information public and advocating for more helmet safety.  It&#8217;s one thing that most parents don&#8217;t give a second thought to when their child gets on their scooters, skate boards, and bikes.  The possibly of getting a head injury is huge when not protected.</p>
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		<title>Comment on Inaccessibility Rules for Exemption to CPSIA Lead Limits by x-ray fluorescence</title>
		<link>http://wemakeitsafer.com/BlogPage/2009/01/101b2-lead-accessibility/comment-page-1/#comment-4</link>
		<dc:creator>x-ray fluorescence</dc:creator>
		<pubDate>Fri, 13 Feb 2009 07:18:21 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=45#comment-4</guid>
		<description>Thank you for posting this CPSIA issue.The CPSIA mandates that ANY PRODUCT intended for a child of 12 or younger be tested, not just earth-friendly handmade toys....
</description>
		<content:encoded><![CDATA[<p>Thank you for posting this CPSIA issue.The CPSIA mandates that ANY PRODUCT intended for a child of 12 or younger be tested, not just earth-friendly handmade toys&#8230;.</p>
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		<title>Comment on CPSC to Streamline Certification Requirements Under CPSIA Sec. 102 by Jennifer P. Toney</title>
		<link>http://wemakeitsafer.com/BlogPage/2008/11/cpsc-to-streamline-certification-requirements-under-cpsia-sec-102/comment-page-1/#comment-7</link>
		<dc:creator>Jennifer P. Toney</dc:creator>
		<pubDate>Wed, 11 Feb 2009 04:01:52 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=58#comment-7</guid>
		<description>Hi Lisa,
The CPSC published a document late last night (that it has since converted to a webpage) titled: “Guidance on the Consumer Product Safety Improvement Act (CPSIA) for Small Businesses, Resellers, Crafters and Charities” http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.html
While the information contained within the guidance document is not new, it is a good overview for those who are confused or who are just learning about the new laws.  However, I do caution you that the document is far from comprehensive and should only be used as a guide to point you in the right direction.
Specific to your question, the answer depends on whether or not you make/paint the shoes yourself, or if you just sell them.  If you or your staff make/paint the shoes, you are considered the manufacturer.  In that case, question number five addresses your concern:
“Question 5: For testing and certification of children’s products that are required now (for example, lead paint and small parts), what do I need to do?
Where testing is required, manufacturers and importers of children’s products must test their products using a third-party accredited testing lab.
…
Manufacturers and importers must comply with certificate requirements, which is the documentation that shows that the product has been tested and meets appropriate standards.&quot;
Here is a link to accredited third-party, testers approved by the CPSC: http://cpsc.gov/cgi-bin/labapplist.aspx
Scroll to bottom of page to narrow search by regulation (eg., lead paint)
Keep in mind that, depending on other materials used in or on the shoes, additional safety regulations may apply.
If you do not make the shoes but only sell them, you do not need to test and certify for safety compliance, but you do still need to be certain that the products do, in fact, comply.  The CPSC gives the following advice for retailers:
“As a practical matter, you must either: Test the product; Refuse to accept or sell the product, which will mean disposing of it if you already have it in your inventory; Use your best judgment based on your knowledge of the product; or, Contact the manufacturer about questionable products.”  (Question 15)
Since it sounds like you are prepared to test, if you are only the retailer and not the manufacturer, you do not need to conduct third-party testing and, in the case of lead, can instead hire a professional to do X-Ray Fluorescence (XRF) testing, which can be done with a hand-held machine on site.   An online search for “XRF technician” or “X-Ray Fluorescence (XRF) testing” plus the name of your city or county should help you find someone to do the testing.  BUT be very careful.  I have no doubts that testing has fast become a hot business, and not everyone you encounter will be qualified.  Be sure to do your due diligence.
Hope that helps.  Feel free to email me directly if you are still confused.  Jennifer [@] WeMakeItSafer.com
Disclaimer: As always, content on this site, including that which is provided in comments, is based on the opinions and understanding of each individual author; it is provided for information and discussion purposes only and should not be considered as legal advice.
</description>
		<content:encoded><![CDATA[<p>Hi Lisa,<br />
The CPSC published a document late last night (that it has since converted to a webpage) titled: “Guidance on the Consumer Product Safety Improvement Act (CPSIA) for Small Businesses, Resellers, Crafters and Charities” <a href="http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.html" rel="nofollow">http://www.cpsc.gov/about/cpsia/smbus/cpsiasbguide.html</a><br />
While the information contained within the guidance document is not new, it is a good overview for those who are confused or who are just learning about the new laws.  However, I do caution you that the document is far from comprehensive and should only be used as a guide to point you in the right direction.<br />
Specific to your question, the answer depends on whether or not you make/paint the shoes yourself, or if you just sell them.  If you or your staff make/paint the shoes, you are considered the manufacturer.  In that case, question number five addresses your concern:<br />
“Question 5: For testing and certification of children’s products that are required now (for example, lead paint and small parts), what do I need to do?<br />
Where testing is required, manufacturers and importers of children’s products must test their products using a third-party accredited testing lab.<br />
…<br />
Manufacturers and importers must comply with certificate requirements, which is the documentation that shows that the product has been tested and meets appropriate standards.&#8221;<br />
Here is a link to accredited third-party, testers approved by the CPSC: <a href="http://cpsc.gov/cgi-bin/labapplist.aspx" rel="nofollow">http://cpsc.gov/cgi-bin/labapplist.aspx</a><br />
Scroll to bottom of page to narrow search by regulation (eg., lead paint)<br />
Keep in mind that, depending on other materials used in or on the shoes, additional safety regulations may apply.<br />
If you do not make the shoes but only sell them, you do not need to test and certify for safety compliance, but you do still need to be certain that the products do, in fact, comply.  The CPSC gives the following advice for retailers:<br />
“As a practical matter, you must either: Test the product; Refuse to accept or sell the product, which will mean disposing of it if you already have it in your inventory; Use your best judgment based on your knowledge of the product; or, Contact the manufacturer about questionable products.”  (Question 15)<br />
Since it sounds like you are prepared to test, if you are only the retailer and not the manufacturer, you do not need to conduct third-party testing and, in the case of lead, can instead hire a professional to do X-Ray Fluorescence (XRF) testing, which can be done with a hand-held machine on site.   An online search for “XRF technician” or “X-Ray Fluorescence (XRF) testing” plus the name of your city or county should help you find someone to do the testing.  BUT be very careful.  I have no doubts that testing has fast become a hot business, and not everyone you encounter will be qualified.  Be sure to do your due diligence.<br />
Hope that helps.  Feel free to email me directly if you are still confused.  Jennifer [@] WeMakeItSafer.com<br />
Disclaimer: As always, content on this site, including that which is provided in comments, is based on the opinions and understanding of each individual author; it is provided for information and discussion purposes only and should not be considered as legal advice.</p>
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		<title>Comment on CPSC to Streamline Certification Requirements Under CPSIA Sec. 102 by Lisa Tam</title>
		<link>http://wemakeitsafer.com/BlogPage/2008/11/cpsc-to-streamline-certification-requirements-under-cpsia-sec-102/comment-page-1/#comment-6</link>
		<dc:creator>Lisa Tam</dc:creator>
		<pubDate>Tue, 10 Feb 2009 17:38:53 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=58#comment-6</guid>
		<description>HELP! I am opening a store for hand painted baby shoes and am totally confused. How do I get the certification that I need??? There&#039;s so much gobbledy-goop on the net that I can&#039;t sift through it all. Just tell me where to send the product for testing in order to be certified, and I&#039;ll do it! My site should be operational by the end of this week, so I&#039;d hate to put it on hold any longer than needed...
Thanks!
</description>
		<content:encoded><![CDATA[<p>HELP! I am opening a store for hand painted baby shoes and am totally confused. How do I get the certification that I need??? There&#8217;s so much gobbledy-goop on the net that I can&#8217;t sift through it all. Just tell me where to send the product for testing in order to be certified, and I&#8217;ll do it! My site should be operational by the end of this week, so I&#8217;d hate to put it on hold any longer than needed&#8230;<br />
Thanks!</p>
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		<title>Comment on US Product Recall System is Ineffective…Still? by Jennifer P. Toney</title>
		<link>http://wemakeitsafer.com/BlogPage/2008/09/us-product-recall-system-is-ineffectivestill/comment-page-1/#comment-9</link>
		<dc:creator>Jennifer P. Toney</dc:creator>
		<pubDate>Sat, 06 Sep 2008 19:07:00 +0000</pubDate>
		<guid isPermaLink="false">http://wemakeitsafer.com/BlogPage/?p=70#comment-9</guid>
		<description>The numbers sited in the post are relevant only to products that fall under the Consumer Product Safety Commission’s (CPSC) jurisdiction.  Vehicles recalls, regulated by the National Highway Traffic Safety Administration (NHTSA), tend to have much higher effectiveness rates at 68 - 72%.  This is largely due to the fact that owner registration data is updated regularly, making it easier for car makers and dealers to contact owners directly.  Recalls of automotive accessories and tires, however, have lower effectiveness rates at about 51% and 28%, respectively.
As you point out, the impact of defects in automotive products can be devastating.  While automotive recalls are much more effective than consumer product recalls, the consequences of 30% of recalled vehicles not being repaired can still be detrimental, both to the consumers whose families are at risk of injury, and to the company, which may be perceived as not having done enough to make sure consumers were aware of the recall.
</description>
		<content:encoded><![CDATA[<p>The numbers sited in the post are relevant only to products that fall under the Consumer Product Safety Commission’s (CPSC) jurisdiction.  Vehicles recalls, regulated by the National Highway Traffic Safety Administration (NHTSA), tend to have much higher effectiveness rates at 68 &#8211; 72%.  This is largely due to the fact that owner registration data is updated regularly, making it easier for car makers and dealers to contact owners directly.  Recalls of automotive accessories and tires, however, have lower effectiveness rates at about 51% and 28%, respectively.<br />
As you point out, the impact of defects in automotive products can be devastating.  While automotive recalls are much more effective than consumer product recalls, the consequences of 30% of recalled vehicles not being repaired can still be detrimental, both to the consumers whose families are at risk of injury, and to the company, which may be perceived as not having done enough to make sure consumers were aware of the recall.</p>
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