August is here, Congress is leaving town and it is time to settle in by the pool for a good read. Let me recommend a few things. For those looking for something light and frivolous, I recommend the CPSC’s proposed direct final rule instructing that only those toys made from the trunks of trees (Just the trunks? Really?) will be exempt from pre-sale testing for heavy metals.
However, for a more thoughtful perspective not only on this rule but also on the overly-constrained approach a majority of Commissioners have adopted to trying to provide relief from its overly burdensome testing rules, I recommend Commissioner Mohorovic’s statement accompanying this rule. He has rightly pointed out that the Commission has framed its work on burden reduction in such a way that real, meaningful results—that reduce costs without compromising safety—will be almost unachievable. As the Commissioner states, where testing costs add a safety value then those costs are worthwhile, but where testing is required for the point of testing, as is the case under the CPSC’s current approach, then valuable safety resources are being squandered.
To further round out your CPSC reading list, be sure to check out the CPSC Commissioners’ blogs. You can find them on the agency web site. I was so pleased to see that the Commissioners now are able to post blogs on the web site. This was not true back in 2009 when I started “Conversations with Consumers.” To write and post a blog I had to go outside the agency and set it up privately. Check out the Commissioners’ blogs from time to time to get a sense of what issues are of special interest to the leaders of the agency.