Comment from Kevin Grish

We are a manufacturer and importer of fine Dinnerware, Cookware and Home Furnishings. We sell to an exclusive clientele through direct, retail and wholesale sales. We routinely have production runs from 1 to 6 piece on a job order (batch or lot). One item in particular is quite expensive (~$19,000) and has a production quantity of one piece (yearly forcast is ~25 pieces). For us to comply with the CPSIA (Finished Piece requirement for testing) would be catastrophic financially to make two pieces so that one could be sent for third party testing. It would be more economocal and productive for us to do component testing and issuing a Certificate of Conformity based on the component testing and process controls. We would like to urge the CPSC to offer two options for compliance and certification issuance; one of the options allowing for component testing with production process controls measures as verification to issue a compliant and acceptable GCC as per the CPSIA. If the CPSC does not account for smaller manufacturers with small production run quantities and mandates finished piece testing, you will be sounding the death bell for small businesses in the United States. We are confident that utilizing component testing we will provide a safe and compliant product to the US Consumer. Respectfully submitted, Kevin A. Grish Technical Services Manager Mackenzie-Childs, LLC.