Responsibility when printing for the trade. Need answer immediately!

[Frog]

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?

I have heard this from a certain element in this industry since day one, and I suspect that this is not the only law that they ignore, or corner they cut. Hell, I know people who still text while driving.
Nonetheless, while not defending the actual law, I understand its intent when unscrupulous business people blatantly started putting profits before consumer's health and safety.
Remember that this came on the heels of some Chinese manufacturers essentially poisoning some pet foods with a chemical additive that had the effect of raising protein levels when tested.

Next, Barbie went to China, and came back with lead poisoning. That is what prompted this knee-jerk reaction and hurried legislation.

As for who will get nailed. Sean, just as with most artists back on TSPMB thinking I was crazy talking about licenses needed to legally reproduce most car art, it's the big boys that have the most to worry about because of their exposure and notoriety. However, the added danger with this is the consumers themselves.
There are few more dangerous animals out there than a mother protecting her cubs, or pups, or whatever.

[Denis Kolar]

This is a mess. What are they going to do when something goes wrong and they need to recall the shirts. I know who I sold the batch of shirts to but they can't know who they sold all 1000 shirts to individually. So how can they call them and tell them that the shirt is bad and not to use it? If you hide the tag in a design, what if the people cant find it if they do for some act of God hear about the recall.

I am not selling shirts intended for Kids under 12. I don't think I would lose much work. I only print a hand full of kids stuff any ways.

Pierre I like your idea about the website and putting the website on the shirts with a tracking number. Now what number do you use. If I print a 6 color design and the inks are from all different patches then I would need 6 tracking numbers? You can't put that much info on every shirt.

the website is 103recall.com. The latest version of the software is not up yet though.
You will be able to enter the garment description (with the manufacturer name and the lot number) and all the info for the ink (different batch numbers and other info). This will generate a tracking number (and in the near future also the certificate of conformity).
You will stamp that in the shirt and be compliant. As Frog pointed out, you will need the means for ppl to contact you and check the status. Phone number works, the web address might.
THe web site we are working on will also provide you with a list of customers that purchased the recalled shirts. So if the manufacturer calls you and says that this particular batch has been recalled, you will be able to type the number in and get a list of every order that used that ink. My guess is it is not your responsibility to actually notify all the ppl that are wearing the actual shirts, but rather just the actual customer who bought them.

pierre

There is maybe an answer on this, but I was not able to find it.
What is going on with the items that will be sold retail. I have a few shirts that I sell on eBay and few other sites, how can I label those. There will not be a single buyer for 30-40 shirts. I hope I do not have to type in everybody's name in that web site.

[Ron Pierson]

Here's my take on all of this. We are a contract printer. I'm sure that the broker we print for does NOT want MY name anywhere NEAR his "blind ship" product. (Rightfully so). I think the ultimate solution in the contract aspect of all this is to have the BROKER place a disclaimer on HIS web site that states that he uses all compliant printers to produce his goods. When the ambulance chasers finally arrive at the door (they will - just a question of when), there should be a way to "back track" an order to its produced date and any information required for its process. The answer to the "back track" is the PO number issued by the broker. We could and probably should keep records of what we used in the production of "lil Jonnies baseball jersey" at the time of printing so it can be back traced.  Sure enough, some kind of a stamp with a number to reference and a record of the ink used referencing that stamp can be internally used.  Purchasing the correct inks and keeping the ink companies certificate for that ink would be a good idea. Having a lab test – say, once a quarter - for a completed product using that compliant ink would probably satisfy the issue as well. Some guy (Pierre – you listening) will probably create tracking software and a stamp (for sale) for this purpose. Printers with a mix of good and bad ink will have to throw away a lot of “bad” ink and do some sanitizing to get a good test but in the end, it may garnish more business for all the obvious reasons. Yep –it will be a pain in the a$$ but I think it will be sufficient and I’m sure printers can and will be able to charge for this new found service provided by our Government. Looks to me like the Government has given me a new profit center to offer to my “compliant brokers”.  Is this veiled “win-win” for a few extra dollars and a chance for more business – might be.

[blue moon]

Here's my take on all of this. We are a contract printer. I'm sure that the broker we print for does NOT want MY name anywhere NEAR his "blind ship" product. (Rightfully so). I think the ultimate solution in the contract aspect of all this is to have the BROKER place a disclaimer on HIS web site that states that he uses all compliant printers to produce his goods. When the ambulance chasers finally arrive at the door (they will - just a question of when), there should be a way to "back track" an order to its produced date and any information required for its process. The answer to the "back track" is the PO number issued by the broker. We could and probably should keep records of what we used in the production of "lil Jonnies baseball jersey" at the time of printing so it can be back traced.  Sure enough, some kind of a stamp with a number to reference and a record of the ink used referencing that stamp can be internally used.  Purchasing the correct inks and keeping the ink companies certificate for that ink would be a good idea. Having a lab test – say, once a quarter - for a completed product using that compliant ink would probably satisfy the issue as well. Some guy (Pierre – you listening) will probably create tracking software and a stamp (for sale) for this purpose. Printers with a mix of good and bad ink will have to throw away a lot of “bad” ink and do some sanitizing to get a good test but in the end, it may garnish more business for all the obvious reasons. Yep –it will be a pain in the a$$ but I think it will be sufficient and I’m sure printers can and will be able to charge for this new found service provided by our Government. Looks to me like the Government has given me a new profit center to offer to my “compliant brokers”.  Is this veiled “win-win” for a few extra dollars and a chance for more business – might be.

essentially, that is the idea behind the 103recall.com. the contract printers will enter their customer's info on the  site and when looked up on the web, the contract printer's name will not be visible. The beta version should be up in about a week or two. The small batch certificate part is probably about a month away.

As far as "bad" ink, all the ink currently in use is lead compliant. Which means that only if you are going to print for kids 3 and younger there might be a phthalate issue, but otherwise all the ink on the market should be good.

pierre

[blue moon]

This is a mess. What are they going to do when something goes wrong and they need to recall the shirts. I know who I sold the batch of shirts to but they can't know who they sold all 1000 shirts to individually. So how can they call them and tell them that the shirt is bad and not to use it? If you hide the tag in a design, what if the people cant find it if they do for some act of God hear about the recall.

I am not selling shirts intended for Kids under 12. I don't think I would lose much work. I only print a hand full of kids stuff any ways.

Pierre I like your idea about the website and putting the website on the shirts with a tracking number. Now what number do you use. If I print a 6 color design and the inks are from all different patches then I would need 6 tracking numbers? You can't put that much info on every shirt.

the website is 103recall.com. The latest version of the software is not up yet though.
You will be able to enter the garment description (with the manufacturer name and the lot number) and all the info for the ink (different batch numbers and other info). This will generate a tracking number (and in the near future also the certificate of conformity).
You will stamp that in the shirt and be compliant. As Frog pointed out, you will need the means for ppl to contact you and check the status. Phone number works, the web address might.
THe web site we are working on will also provide you with a list of customers that purchased the recalled shirts. So if the manufacturer calls you and says that this particular batch has been recalled, you will be able to type the number in and get a list of every order that used that ink. My guess is it is not your responsibility to actually notify all the ppl that are wearing the actual shirts, but rather just the actual customer who bought them.

pierre

There is maybe an answer on this, but I was not able to find it.
What is going on with the items that will be sold retail. I have a few shirts that I sell on eBay and few other sites, how can I label those. There will not be a single buyer for 30-40 shirts. I hope I do not have to type in everybody's name in that web site.

in this case you need to put your contact info inside the shirt. When they call you should be able to provide the lot/batch numbers for the ink and garments.

instead of stamping 103recall.com, just stamp your web address so they can reach you (a phone number would not hurt either) with the batch number.

pierre