Rick Woldenberg is rapidly becoming a near mythic figure in his tireless devotion to cleaning up the CPSIA (Consumer Product Safety Improvement Act) mess.
He wrote a letter (2.1 MB pdf) that was included into the record of the February 26 hearings held by Rep. Rush's subcommittee on the revision or amendment of TSCA the Toxic Substances Control Act). The subcommittee is apparently considering changing the focus of TSCA into a precautionary law much like the EU's REACH.
Interestingly, to change TSCA into a precautionary law would require overlooking the terrible example of the CPSIA, a blatantly precautionary law that avoids all concept of risk assessment.
As Gib Mullan, Director of the Office of Compliance and Field Operations of the CPSC stated on February 26 at the ICPHSO (International Consumer Product Health & Safety Organization) Conference in Orlando, Florida (www.icphso.org), "Congress made it clear that [the CPSC is] to get away from 'that kind of analysis'". Thus, the CPSC is a precautionary law in which the regulatory agency is prohibited from considering if there is ANY risk associated with banned or restricted products.
Rick is pleading that Congress amend the CPSIA urgently before it singlehandedly devastates the children's product industry, many tens of thousands of businesses.