The CPSC public comment period for the Sling Safety Standard has created quite the flurry of concern in our industry. Many are looking for constructive ways to comment, show their support for the industry and generally get a handle on the issues at hand.
Many of the comments that have already been submitted are very harmful to our industry as a whole, and the sling product category in particular (slings, wraps, pouches, carrier shirts). This cannot be stressed strongly enough- there is a very real possibility that the comments already posted may well have jeopardized the entire standard creation process to date, and by extension our industry as a whole. These comments also illustrate a fundamental misunderstanding of the process at hand and the organizations involved. Four years ago the products in our industry were in very real danger of being banned for sale completely in the US. This is not an idle concern. We urge people to be thoughtful, well informed and strategic in their comments. Strong comments offer solutions and new information to the discussion. Please keep in mind that public comments become permanent public record and cannot be undone.
What do I need to do before commenting?
Before putting together a public comment one should:
1) Read and understand the relevant ASTM standard (in this case ASTM F2907-14a is referenced in the CPSC briefing, 14b is available for purchase)
(also available as a read-only document here: http://www.astm.org/cpsc.htm)
2) Watch the video briefing to the Commission
3) Read the docket
4) Familiarize yourself with the current CPSIA regulations in place and what they mean (material change testing, tracking labels etc)
But I don’t really have anything new to say
That’s ok. The BCIA will be submitting a public comment on behalf of members. BCIA board member and ASTM sub-committee chair Rochelle Price will also be submitting a short comment on behalf of the ASTM committee in reference to F2907-14b. This is a rundown of the key points in the BCIA comment which we think are factually supported and adding relevant information to the process:
1) Our official stance is that we absolutely support adopting the voluntary F2907 standard as mandatory.
2) The size of the industry as indicated through BCIA membership and best estimate. The CPSC briefing has grossly underestimated this because there is simply not a reliable source for this information. Our comments stress the large number of industry businesses that are micro-businesses in size. Part of the CPSC mandate is to take into account the economic impact of any regulations.
2) Proposed changes to current regulations- perhaps products could be tested bi-annually instead of annually. Or only when there is a material change, which would allow businesses to spread out when products were tested and phase in new products.
3) Allowing for changes to the material change testing process- ie. tensile/fabric strength testing as opposed to full product testing (this is where one would make an argument for less expensive testing options for different weaves/fiber blends).
4) Modifications to the ASTM standard itself- the test dummy used in the F2907 testing process is slippery and while most woven wraps do fine in the testing process, it is harder to correctly position ring slings and water wrap type carriers on it- we are proposing some possible changes to the test dummy going forward.
5) Accepting the updated testing processes for ring slings as proposed in 2907-14b which is critical if quality ring slings are to pass the mechanical testing process.
6) Adopting a government-backed joint education campaign as is being carried out successfully in other countries, namely Canada and Australia.
I still don’t understand who does what in this industry!
Then you need to watch this video now.
What if I already submitted a statement that is damaging to the industry?
If you have already submitted a comment that is potentially damaging, you have the option of submitting a second comment referencing the first. Points to stress would be that the initial comment was premature or not carefully considered, or perhaps being a new business in a small industry meant that you did not fully understand the scope of the mandatory standard proposal. We strongly suggest that you familiarize yourself with the F2907-14a standard and support it in your public comment if you are trying to undo the damage of an initial comment made in haste.
I just want to help, what can I do?
You can help by spreading factual information (like this post) to parties who have a vested interest in this process. If you are passionate about the industry, please lend your support in other ways- by quelling misinformation when you see it and stressing to those in your network the importance of standing together in industry solidarity.
Undoing the damage that has been done is using considerable resources for our small organization. If you work in this industry and are not a current BCIA business member, we strongly encourage you to join. The only thing we have is a voice of reason and strength in numbers.
Not a business? Please consider joining at the friend (25$/year) or champion level (100$/year).
Alternatively donations can be sent directly to email@example.com/dev. Every little bit helps. We are facing immediate legal costs and funding a trip to DC to speak with regulators. These costs will be ongoing. Please understand that every dollar we divert to crisis management is a dollar we have taken from industry advancement. Spread the word, we need your help.