Industry regulations > CPSIA Section 103 - Tracking Labels
Responsibility when printing for the trade. Need answer immediately!
blue moon:
--- Quote from: CastleKing on January 16, 2012, 03:53:00 PM ---The way I am interpreting CPSIA is that if you run multiple lots of ink, then each lot needs to have certification documents.
So, lets say you have a 10,000 piece run, you can have it certified one of two ways. The first is tested as a "whole" shirt. You send your finished garment to be tested for lead content. The problem here is that we all know that we may not run the entire production order with the same ink lot numbers; consequently, there should be multiple samples tested throughout the print run
The other way to certify is to have "batch" certification on the inks, which means you send wet samples of all of your colors and bases to be tested. Not only is this extremely expensive to do, but still poses the same problem once you open a new drum of ink.
Sounds like the regulators haven't done their homework to fully understand the printing process.
We are going to print tagless labels along with our internal PO# to track and identify the print date but I'm not sure how we will manage testing "whole" or "Batch"
--- End quote ---
as far as I can tell, the best way to resolve this issue would be to have the distributors test some batches and charge extra for the ink with the certificates. this way we could just order the ink we need for the upcoming jobs and even if we open another batch, all we'd have to do is add it to the list of the batches used in production. We would not need to create another certificate or a recall number.
Unfortunately, so far no distributors have stepped forward and offered that solution. I have heard from a couple of manufacturers that they are still trying to wrap their head around this and that they have no idea right now of how to proceed.
We'll just have to wait and see . . .
pierre
pierre
mk162:
it's a pain. write your congressmen about this. I have been staying on top of ours.
Not to move this in a direction that is political, but this is the type of regulation that stifles small business. I can't afford to hire an employee to tag shirts and arrange the tracking system. Large companies can, these types of laws only hurt the smaller companies, and remove competition for larger ones.
It's sad that I have to list ANOTHER government agency I fear an audit from.
As for tracking this BS, I am hoping the law is rewritten or appealed. Most of the components they have problems with are not available in the US anymore. So, if they aren't available, how am I going to use them?
House painters should have to test every batch of paint before they paint kids rooms then.
Denis Kolar:
--- Quote from: mk162 on January 19, 2012, 09:33:54 AM ---it's a pain. write your congressmen about this. I have been staying on top of ours.
--- End quote ---
I like this.
Shawn (EIP):
I nor my fellow local printers that I've spoken to pay any attention to this CPSIA crap and no one has been knocking on doors nor has any customers requested the info. Must be a CA thing?
If the CPSIA doesnt know their own rules how can they inforce them?
blue moon:
--- Quote from: endless ink printing on January 19, 2012, 09:52:57 AM ---I nor my fellow local printers that I've spoken to pay any attention to this CPSIA crap and no one has been knocking on doors nor has any customers requested the info. Must be a CA thing?
If the CPSIA doesnt know their own rules how can they inforce them?
--- End quote ---
it is NOT a CA thing! My guess is that they are taking it easy and giving ppl time to get onboard. From what I have seen, once they start, the first fine will be enough to set you back YEARS and repeat offenses might be enough to shut you down permanently (up to $10 mil in fines).
pierre
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