Having read the proposal and conducted some research, I am teetering on not supporting CPSC Docket No. CPSC-2010-0090. I have read many blogs and responses to the additional cost, particularly to small business owners, of having to pay for these so called third party inspections. Although in principle I agree that child safety is very important, in fact I rely on it for my own children; however if the cost of the inspections are likely to drive many small business out of the market, effectively you have helped indirectly to create a major competitive advantage for larger firms. From a business perspective, you have reduced the competition and created a much bigger barrier to entry based on the cost of inspecting for the production of safe products. This law needs to be narrowly focused on specific industry firms that is directly affected by not conducting these inspections. There are too many businesses that are adversely affected by this broad requirement which are unlikely to be of any kind of risk to children to begin with. As a result, many small businesses have to close their doors offering fewer choices for consumers. My recommendation is that this law is amended to focus on directly linked manufacturers who fail to produce safe products for children and penalize them as opposed to the small business community.
Comment from Dan Gaskins
This is comment on Rule
Third Party Testing for Certain Childrens Products; Youth All-Terrain Vehicles: Requirements for Accreditation of Third Party Conformity Assessment Bodies
View Comment
Attachments:
Comment from Dan Gaskins
Title:
Comment from Dan Gaskins
Related Comments
Public Submission Posted: 09/21/2010 ID: CPSC-2010-0090-0002
Sep 27,2010 11:59 PM ET
Public Submission Posted: 10/01/2010 ID: CPSC-2010-0090-0004
Sep 27,2010 11:59 PM ET
Public Submission Posted: 10/01/2010 ID: CPSC-2010-0090-0006
Sep 27,2010 11:59 PM ET
Public Submission Posted: 10/01/2010 ID: CPSC-2010-0090-0005
Sep 27,2010 11:59 PM ET
Public Submission Posted: 09/22/2010 ID: CPSC-2010-0090-0003
Sep 27,2010 11:59 PM ET