But boy, the last URL you suggested, which refers to an article about more stringent regulations on labeling and certification, certainly raises my eyebrows. And I could imagine big companies like Mattel having the manpower and money to fund these additional certifications and assurance, but gosh, that would be quite challenging for small and startup businesses.
Any SUN small biz and manufacturers out there who`s watching how the regulations may be changed? Any worries out there?
I haven`t seen any discussion of it on SUN. It also affects retailers too because they must require that their vendors supply them with upstream certifications meaning, they may not be able to stock the shelves.
I can`t speak for SUN but we are certainly worried
, particularly as it affects small producers. We have a thread going
with over 60 posts at last count. Luckily, since our membership is comprised ONLY of manufacturers, some with extensive regulatory experience, we`re analyzing and working through it. We are planning to spearhead an effort during the comments phase once guidelines on proposed implementation are presented. Please note that while the guidelines are not yet finalized,the rules go into effect tomorrow
One of the things we`ve done is get detailed quotes from certification labs. Quotes, depending on the services rendered are ranging from $500 to $982 PER ITEM. Obviously, your process comes into play, will you assay known inputs or finished goods? Here I`ll quote what one of our member manufacturing engineers says
* When we were setting up our hazardous waste
satellite accumulation point, our safety officer explained to me that
there were two ways to establish the contents of a waste stream: by
input analysis or by assay (sampling and testing). You rely on the
former when you are using known inputs and known processes, the latter
when using multiple inputs and a variety of processes. Seems to me that
you could take the same approach here. If you are making something
relatively simple, you get your fabrics, facings, thread, and hardware
tested and you`re done. If you`re doing something complex (specialty
dyes, processes, re-purposing, etc.), you may have to resort to
Anyway, it is causing quite a stir, this has been flying under the radar but after this afternoon, I imagine the big press wires will begin to pick up the story and get the word out. We are doing our part!
~Nurture people, not products~