On September 14, Walter Olson wrote an article on the Opinion Page of the Wall Street Journal.  (See http://online.wsj.com/article/SB10001424052970203706604574370712943409146.html#articleTabs%3Darticle). Interestingly, his comment that “not one of the thousands of craftspeople, retailers and small manufacturers the law has sent reeling was permitted to testify”.  Indeed, the letter Peter mailed on August 4th, supports that observation:

August 4, 2009

Dear Chairmen and Ranking Members:

I am writing in regard to the Committee hearing set for September 10, 2009 in which the Hon. Inez Tenenbaum, Chairman of the U.S. Consumer Product Safety Commission (CPSC), is scheduled to testify on the implementation of the Consumer Product Safety Improvement Act (CPSIA).

I am extremely disappointed and surprised that no small businesses impacted by the new law have been invited to share their experiences in testimony before the Committee. The small business owner who has worked diligently for many years to produce safe toys and has conformed to all the testing requirements, both voluntary and mandatory, through third party labs has been thrown in to a turmoil. The law has had so many interpretations over the last months that no one is able to determine how and what needs to be done.

In our small companies products are made in small quantities and therefore many common components are used in order to keep product costs down. Under the new law we now have to treat these common components as entirely different entities for each toy they are a part of. We have to test some of our components 25 and 30 times, at cost of several hundred dollars each time, even though they have already been documented as safe by an independent testing lab. This is just one of several issues in this law that could be made simpler and less expensive without being any less safe. Most of these problems have to do with a lack of knowledge and understanding of actual manufacturing processes and need to be addressed to prevent small businesses from failing.

Small business in the children‘s industry has been actively calling for hearings since the passage of the CPSIA because of the issues that threaten our very existence and the availability of important playthings for our children. Issues that, if addressed, could allow us to survive this unbelievably difficult time and continue to make toys that would be as safe as the Congress intended. Companies in the small business segment have an excellent record of safety and are asking to be heard so we can continue to make excellent products. These issues need to be explored by the Committee based on the testimony of real companies suffering real pain.

The deck is stacked against small business under the new law. Ironically, while we are left to puzzle over how to “ascertain” co-hort information on products, the new law awards a freebie to large businesses who seek to test their own products.

I strongly believe that the perspective of businesses like our company is essential to a complete picture of the problems caused by the CPSIA and its implementation. Thank you for your consideration of this important matter.

Sincerely,

Peter F. Reynolds

President

The Little Little Toy Co., LLC

peter@littletc.com

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