Comment from Terry Bush

Neither 16 CFR Part 1107 or 16 CFR Part 1109 nor the comments or responses address why ordinary books are included in CPSIA. According to the CPSC website, there has never been a recall or report of illness or injury due to the presence of lead or heavy metals in ordinary books. Therefore, either one of the proposed rules, or CPSIA itself, should be amended exclude ordinary books because they are not a hazard. Although providing the means to test less frequently for a problem that doesn’t exist still does not address this issue, the Commission has stated in the proposed rules “that products with a higher potential for injury or death should undergo greater scrutiny.” Using the same reasoning, products with a much lower potential should undergo much less scrutiny. Therefore, while exempting ordinary books should still be done, the proposed rules should be amended to provide an exemption process for component parts and/or finished products that demonstrate they are in compliance with applicable rules and regulations with test results for a particular chemical that indicate a very low or nonexistent level. The exemption process could begin with a reduced testing regimen followed by removal from the testing requirement altogether.