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Industry regulations => CPSIA => CPSIA Section 103 - Tracking Labels => Topic started by: Frog on August 05, 2011, 01:53:59 PM

Title: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 05, 2011, 01:53:59 PM
job is due in one hour.
Does resposibility now fall on the client?
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Clark on August 05, 2011, 02:19:19 PM
Perhaps a bit more information.

Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 05, 2011, 02:25:14 PM
Sure, it's simple. When I run a youth shirt for an end user customer, I have a label I add with contact information, date and individual ID number (which in my files, corresponds to ink batch numbers and so forth. To some, even this isn't sufficient, but that's another issue.
With contract type work, wouldn't the label have t reflect their information?
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Fresh Baked Printing on August 05, 2011, 02:27:51 PM
Not to muddle the thread with my comment but what a joke that the CPSIA crap is so convoluted that even the CPSIA can't tell us what the rules are.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: tpitman on August 05, 2011, 03:12:04 PM
I'd assign it a number code and put their info on it. Give you customer the info regarding the ink and shirt. Tell them by law they have to keep records, and keep records for yourself as you normally would just to cover yourself.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 05, 2011, 03:35:01 PM
Obviously the safest solution, with a little bit more of a charge to make the "custom" label. as opposed to my stock one with only the number changing.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: whitewater on August 06, 2011, 08:25:34 AM
Where are these rules for this labeling? I am a business and not one person has ever contacted me about this..If i was not on these boards I wouldn't have a clue about this so called law...

Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: tpitman on August 06, 2011, 10:07:38 AM
It's the government. They're making up the rules as they go along.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: pwalsh on August 06, 2011, 10:40:17 AM
Sure, it's simple. When I run a youth shirt for an end user customer, I have a label I add with contact information, date and individual ID number (which in my files, corresponds to ink batch numbers and so forth. To some, even this isn't sufficient, but that's another issue.
With contract type work, wouldn't the label have t reflect their information?

Andy:  I know of at least one larger screen-printer that "discreetly" incorporates a tracking number directly into the design that they print onto the garment.  I can't tell you with any certainty if this approach meets the legal requirements, and my contact at the company did report that their customers were initially not so happy at having a tracking number incorporated into the graphic design. 

Although, as soon as he explained the legal requirement to track the garment and the materials used in its manufacture his customers were normally ok with it.  If you can get your customers on board, this approach is more permanent, less expensive, and a whole lot less hassle than adding your own custom label to the garment.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 06, 2011, 10:55:39 AM
Peter, I offer both methods. Some designs are simply more conducive for the "incorporated" choice, and like you mentioned, some simply don't want it there no matter, and will pay for the additional label.
My specific problem is dealing with the contract aspect.
Though I seldom do contract work, I will now offer the same two alternatives, but with their contact information.
Fortunately, this comes up seldom. Pierre, on the other hand, probably sees it regularly. He also uses a cool rubber stamp.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: whitewater on August 08, 2011, 04:23:58 PM
Where are these rules for this labeling? I am a business and not one person has ever contacted me about this..If i was not on these boards I wouldn't have a clue about this so called law...

no answer to this from anyone?

Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: ErinAllenLamb on August 08, 2011, 04:25:44 PM
I think I would reference the website. I know that isn't that helpful, but at least they may have some recommendations.

http://www.cpsc.gov/about/cpsia/cpsia.html (http://www.cpsc.gov/about/cpsia/cpsia.html)

Erin
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on August 08, 2011, 05:11:10 PM
I think I would reference the website. I know that isn't that helpful, but at least they may have some recommendations.

[url]http://www.cpsc.gov/about/cpsia/cpsia.html[/url] ([url]http://www.cpsc.gov/about/cpsia/cpsia.html[/url])

Erin


here is a better link:
http://www.cpsc.gov/about/cpsia/sect103.html (http://www.cpsc.gov/about/cpsia/sect103.html)

One of the other business I started recently is 103recall.com (http://103recall.com) which provides tracking number management. We are finally in the beta testing phase so feel free to check it out. Beware, lot more cosmetic work is need and some of the functionallity is a little difficult (working on it). Anyways, the point here is that I had to dig deep to see what the deal is with all the CPSIA rules and am ABSOLUTELY CERTAIN that all the garments for kids 12 and under have to have a recall label. More info is available by following the above link. As far as responsibility, the manufacturer is the one ultimately responsible. Think of our contract customers as Ford (or Chevy) and we are subcontracted for certain components, features or operations. So from what I understand Andy it is your customer's responsibility.

The reality is though, most of my customers are sitting in an office and have no means of marking the garments. We offer it as a service and charge $0.10 per garment to stamp it and $5 per order to generate the number. We are finding out that $0.10 is not enough and have already notified our customers that starting next year it will be at least $0.15 if not $0.20 per garment. We use a rubber stamp (with garment ink) to mark the inside of the shirts with the web address and the recall/batch number.

I remember reading that the first offense penalty was $5k-$50k and the second offense was $100k - $10M. I could remember wrong though, but it was steep!

pierre
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 08, 2011, 05:34:44 PM
Where are these rules for this labeling? I am a business and not one person has ever contacted me about this..If i was not on these boards I wouldn't have a clue about this so called law...


Please, use the link and look into this on your own. It is no secret, but you are not alone in those who have either never heard of it, or are playing ostrich. NO ONE WILL CONTACT YOU, at least not just to pass on information.

It is, without a doubt, muddled and confusing, It is, nonetheless, the law, well-intentioned though albeit somewhat of a knee-jerk reaction to Barbie spending the last few years in China, and returning with a case of lead poisoning. Whoda thunk that that was communicable?

My label, when used,  is the size of a small postage stamp and is applied to the back of the shirt's tag. It is, however, labor intensive. Pierre's rubber stamp and data base seems much quicker.

http://www.cpsc.gov/about/cpsia/sect103.html (http://www.cpsc.gov/about/cpsia/sect103.html)
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: mk162 on August 09, 2011, 01:24:16 PM
Do you guys see why I LOATH big government?  The government can't even prevent e. coli and salmonella from entering the food supply.  This is just knuckin' futs.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 09, 2011, 01:39:42 PM
Do you guys see why I LOATH big government?  The government can't even prevent e. coli and salmonella from entering the food supply.  This is just knuckin' futs.

moot point.
It is what it is and we have better learn to deal with it.

Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: mk162 on August 09, 2011, 01:57:30 PM
It's not a moot point, this is what you get when you elect the nanny state.  Maybe we should grill ANYBODY running for office about what they are GOING to do about this, rather than what they would do.

This law will do NOTHING but cost the US jobs.  The economy is in a tailspin, it is legislation like this that needs to go...and it needs to go NOW.

On that note, I am going to write my reps on this.

Moot point my butt.  WE HAVE TO DO SOMETHING ABOUT THIS.  This increases the cost of business, a cost that will be more easily absorbed by larger companies, it will run a lot of shop out of business.

Sorry Andy, your comment "moot point" ticks me off.  Just roll over and let them have your way with you, why not, they are already on top of you...why try and stop them.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 09, 2011, 02:09:25 PM
Okay, so like the folks who advised Welsey Snipes to not pay his taxes, you are advocating that you and others ignore these requirements? That's the possibly deadly ostrich attitude I mentioned.

It's like any law. Whether one agrees with it or not, a smart person or in this case smart business person, learns all about it and what can negatively affect his or her business or in some other cases, life and freedom.



Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: tpitman on August 09, 2011, 02:16:29 PM
At this point we need to demand clarity in the requirements and enforcement of the rules that will address the issue of any real toxic potential without hobbling an industry like ours that is predominantly small business. When official consensus seems to be lacking on what comprises compliance after this thing has been on the books for a few years now, and after several half-assed moratoriums that expire without the solution, it's a classic example of government with no practical knowledge of the issue, but acting with all the "best intentions" whether or not the law remedies the problem. They'll cut your leg off to keep that ingrown toenail from getting infected.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: mk162 on August 09, 2011, 02:25:16 PM
I am not advocating ignoring it, I am advocating fighting it.  Look at what the government has done to the economy the last 2 weeks.  Over the last 4 years?  It is strangling us and will only get worse.  Excessive regulation like this is what drives jobs overseas and consumers to pay higher prices.

What the f*ck are we trying to protect kids from?  How many kids per year get sick from lead poisoning from toys?  Seriously, this is one of the worst laws ever.

I think we should mandate that at all time and at all places anybody under the age of 16 should wear a helmet and full body pads.  And while we are at it, lets cut out all running, swift walking and any sort of "activities" that could lead to injury.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on August 09, 2011, 02:28:59 PM
I see  tags from the mills. Most ink companies as well as heat seal folks have compliant products with certification available.
So, the real hassle is record keeping and the actual placement of our (or our client's) tracking label.
 Yep, a pain, but that does not change the fact that we need to make a reasonable effort to comply to the regulations as we understand them right now.

Those with a shop full of employees, probably have a lot more time to fight this than a small one person shop like mine.
I don't have the time or the wherewithal to spend time in court protesting a fine if that were to come.

Bottom line to me is study, complain, even protest, but comply as best as is needed as long as is needed.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: tpitman on August 09, 2011, 02:33:37 PM
Bottom line to me is study, complain, even protest, but comply as best as is needed as long as is needed.

Absolutely. But, dammit, why do they have to make things so hard? A sober look at the problem with carefully crafted development of the regulations would go a long way into fostering compliance.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: mk162 on August 09, 2011, 02:37:18 PM
I think the Smithsonian logo for the Department of Innovation says it all too well...
(http://t3.gstatic.com/images?q=tbn:ANd9GcQbC7CWSHPhQTu846tgAEZzOgsXtHhfm7uMPWGfBtFzzvR9jbi2ww)

Notice a problem with it?
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: tpitman on August 09, 2011, 02:41:09 PM
Notice a problem with it?

Yeah, the sand is missing. Or maybe the monkey wrench.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: mk162 on August 09, 2011, 02:43:08 PM
3 gears cannot interlock like that.  1 is going to get sheared, if it even has enough power to get moving.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on August 09, 2011, 03:25:17 PM
3 gears cannot interlock like that.  1 is going to get sheared, if it even has enough power to get moving.

I thought that was the inovation part, they figured out how to make that work!
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Prosperi-Tees on January 16, 2012, 02:38:12 PM
Where are these rules for this labeling? I am a business and not one person has ever contacted me about this..If i was not on these boards I wouldn't have a clue about this so called law...


Please, use the link and look into this on your own. It is no secret, but you are not alone in those who have either never heard of it, or are playing ostrich. NO ONE WILL CONTACT YOU, at least not just to pass on information.

It is, without a doubt, muddled and confusing, It is, nonetheless, the law, well-intentioned though albeit somewhat of a knee-jerk reaction to Barbie spending the last few years in China, and returning with a case of lead poisoning. Whoda thunk that that was communicable?

My label, when used,  is the size of a small postage stamp and is applied to the back of the shirt's tag. It is, however, labor intensive. Pierre's rubber stamp and data base seems much quicker.

[url]http://www.cpsc.gov/about/cpsia/sect103.html[/url] ([url]http://www.cpsc.gov/about/cpsia/sect103.html[/url])


Hey Frog could you post a pic of your label?
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Screened Gear on January 16, 2012, 03:01:57 PM
So this law is for just shirts intended for kids under 12? Does that mean we only label the ones for kids or the whole patch? Do we have to label all items we print even if they are not intended for kids?
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on January 16, 2012, 03:13:08 PM
So this law is for just shirts intended for kids under 12? Does that mean we only label the ones for kids or the whole patch? Do we have to label all items we print even if they are not intended for kids?


there is some good info here:
http://www.theshirtboard.com/index.php?topic=2322.0 (http://www.theshirtboard.com/index.php?topic=2322.0)

pierre
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Screened Gear on January 16, 2012, 03:25:36 PM
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.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on January 16, 2012, 03:30:45 PM


My label, when used,  is the size of a small postage stamp and is applied to the back of the shirt's tag. It is, however, labor intensive. Pierre's rubber stamp and data base seems much quicker.


Hey Frog could you post a pic of your label?

Maybe still not completely compliant, but when I started doing this, compliance was virtually zero on some boards, and woefully low even here. I figured that my attempt to comply would count for something
The tracking number can be cross referenced to the specific ink or transfer information, and exact date, while the number itself reflects that this is the 63rd youth job, and it was done in October, 2011
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on January 16, 2012, 03:41:50 PM
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
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Ripcord on January 16, 2012, 03:42:36 PM
It's not that big of a deal...I use a code like this: NSW- 80002 - 303-555-7777 - 12/2011 - #123

This identifies myself (initials), location (zip code), phone number (contact info), manufacture date (month and year), and lot number. Any customer who wants to know what ink I used can call me with the lot number and I can give him the batch number(s) of the ink(s) used for the job, because I keep a log.

I print this code as a single line of 12 point type on the inside of the shirts near the bottom hem. No flash, just a quick stroke, and into the dryer. I could easily do 200 an hour if I had a larger dryer.

It's an extra step, and I try to get a little extra money for youth shirts to cover it...I don't necessarily agree with the regulation, but I don't disagree with government regulations in general. Can you imagine if food and medicine could be manufactured without any standards? Or if restaurants weren't required to handle food properly? Yuck. 

Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on January 16, 2012, 03:48:53 PM
we actually ordered a stamp that can have the text changed. We stamp the shirts at the same location as you and can do 4-500 per hour without having to send them through the dryer and burning a screen. It is very, very easy to do.
What seems to take the most time is getting the lot numbers from the shirts. Some companies like Jersees have individual numbers for each shirt and it takes a long time to make a list of all the shirts used (we just drop the last digit or two to reduce the number of entries to one for 100 or 10 shirts depending on how big is the order).

Currently we charge $0.10 per shirt to process the info and stamp them. It is not enough though and I have notified our customers that the price will go to $0.20-$0.25 this year. We also charge $5 to have the tracking number set up.

pierre
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Homer on January 16, 2012, 03:52:39 PM
 who is going to go around checking to see if you are following these "rules"? How do you decide what size shirt is intended for a 12 year old /3 year old? We have a few ideas on tacking and logging our info. It should be done anyway for our own good - but- atleast you get some advertising out of the deal.

P - what ink are you using in your stamper? We tried a few different ones and they are all illegible after washing. We switched to a direct print.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: CastleKing on January 16, 2012, 03:53:00 PM
The way I am interpreting CPSIA is that if you run multiple lots of ink, then each lot needs to have certification documents.

So, lets say you have a 10,000 piece run, you can have it certified  one of two ways. The first is tested as a "whole" shirt. You send your finished garment to be tested for lead content. The problem here is that we all know that we may not run the entire production order with the same ink lot numbers; consequently, there should be multiple samples tested throughout the print run

The other way to certify is to have "batch" certification on the inks, which means you send wet samples of all of your colors and bases to be tested.  Not only is this extremely expensive to do, but still poses the same problem once you open a new drum of ink.

Sounds like the regulators haven't done their homework to fully understand the printing process.

We are going to print tagless labels along with our internal PO# to track and identify the print date but I'm not sure how we will manage testing "whole" or "Batch"
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Prosperi-Tees on January 16, 2012, 03:54:17 PM


My label, when used,  is the size of a small postage stamp and is applied to the back of the shirt's tag. It is, however, labor intensive. Pierre's rubber stamp and data base seems much quicker.


Hey Frog could you post a pic of your label?

Do you just use an avery label or something of that sort? Wouldn't these come off after the first wash?
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on January 16, 2012, 03:58:46 PM
who is going to go around checking to see if you are following these "rules"? How do you decide what size shirt is intended for a 12 year old /3 year old? We have a few ideas on tacking and logging our info. It should be done anyway for our own good - but- atleast you get some advertising out of the deal.

P - what ink are you using in your stamper? We tried a few different ones and they are all illegible after washing. We switched to a direct print.

If it marketed to the 12 and under it has to comply. If it is an adult shirt that a kid is wearing, it does not have to comply. My understanding is that the marketing/intent is how you determine. . .

don't know where I got the ink, but it was specifically designed for fabric marking with a stamp. Look for a fabric stamping kit, it will come with ink. I have since purchased the ink and did a couple of washes without much degradation. That was black ink though, I should check the white just to make sure.

pierre
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on January 16, 2012, 04:02:21 PM

Do you just use an avery label or something of that sort? Wouldn't these come off after the first wash?



Digital Heat Transfer. Used to use CLC on Neenah Photo Trans, now ite ink jet with Neenah Jet Pro Soft Stretch
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on January 16, 2012, 04:04:03 PM
The way I am interpreting CPSIA is that if you run multiple lots of ink, then each lot needs to have certification documents.

So, lets say you have a 10,000 piece run, you can have it certified  one of two ways. The first is tested as a "whole" shirt. You send your finished garment to be tested for lead content. The problem here is that we all know that we may not run the entire production order with the same ink lot numbers; consequently, there should be multiple samples tested throughout the print run

The other way to certify is to have "batch" certification on the inks, which means you send wet samples of all of your colors and bases to be tested.  Not only is this extremely expensive to do, but still poses the same problem once you open a new drum of ink.

Sounds like the regulators haven't done their homework to fully understand the printing process.

We are going to print tagless labels along with our internal PO# to track and identify the print date but I'm not sure how we will manage testing "whole" or "Batch"

there are three CPSIA regulations: 101, 102 and 103. they address the tracking, lead and phthalates. We are talking strictly about the tracking info here which does not have any exemptions and does not require a certificate.
Lead and Phthalate compliance require a certificate even if the testing is not required.

SO those are two separate issues that we have to comply with.

pierre
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on January 16, 2012, 04:09:25 PM
The way I am interpreting CPSIA is that if you run multiple lots of ink, then each lot needs to have certification documents.

So, lets say you have a 10,000 piece run, you can have it certified  one of two ways. The first is tested as a "whole" shirt. You send your finished garment to be tested for lead content. The problem here is that we all know that we may not run the entire production order with the same ink lot numbers; consequently, there should be multiple samples tested throughout the print run

The other way to certify is to have "batch" certification on the inks, which means you send wet samples of all of your colors and bases to be tested.  Not only is this extremely expensive to do, but still poses the same problem once you open a new drum of ink.

Sounds like the regulators haven't done their homework to fully understand the printing process.

We are going to print tagless labels along with our internal PO# to track and identify the print date but I'm not sure how we will manage testing "whole" or "Batch"

as far as I can tell, the best way to resolve this issue would be to have the distributors test some batches and charge extra for the ink with the certificates. this way we could just order the ink we need for the upcoming jobs and even if we open another batch, all we'd have to do is add it to the list of the batches used in production. We would not need to create another certificate or a recall number.

Unfortunately, so far no distributors have stepped forward and offered that solution. I have heard from a couple of manufacturers that they are still trying to wrap their head around this and that they have no idea right now of how to proceed.

We'll just have to wait and see . . .

pierre

pierre
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: mk162 on January 19, 2012, 09:33:54 AM
it's a pain.  write your congressmen about this.  I have been staying on top of ours.

Not to move this in a direction that is political, but this is the type of regulation that stifles small business.  I can't afford to hire an employee to tag shirts and arrange the tracking system.  Large companies can, these types of laws only hurt the smaller companies, and remove competition for larger ones.

It's sad that I have to list ANOTHER government agency I fear an audit from.

As for tracking this BS, I am hoping the law is rewritten or appealed.  Most of the components they have problems with are not available in the US anymore.  So, if they aren't available, how am I going to use them?

House painters should have to test every batch of paint before they paint kids rooms then. 
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: DKgrafix on January 19, 2012, 09:51:15 AM
it's a pain.  write your congressmen about this.  I have been staying on top of ours.

I like this.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Shawn (EIP) on January 19, 2012, 09:52:57 AM
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?
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on January 19, 2012, 10:07:27 AM
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?

it is NOT a CA thing! My guess is that they are taking it easy and giving ppl time to get onboard. From what I have seen, once they start, the first fine will be enough to set you back YEARS and repeat offenses might be enough to shut you down permanently (up to $10 mil in fines).

pierre
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Frog on January 19, 2012, 10:17:11 AM
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.


Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: DKgrafix on February 09, 2012, 12:24:25 PM
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.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: Ron Pierson on February 09, 2012, 02:16:04 PM
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$$ but I think it will be sufficient and I’m sure printers can and will be able to charge for this new found service provided by our Government. Looks to me like the Government has given me a new profit center to offer to my “compliant brokers”.  Is this veiled “win-win” for a few extra dollars and a chance for more business – might be.
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on February 09, 2012, 05:11:06 PM
Here's my take on all of this. We are a contract printer. I'm sure that the broker we print for does NOT want MY name anywhere NEAR his "blind ship" product. (Rightfully so). I think the ultimate solution in the contract aspect of all this is to have the BROKER place a disclaimer on HIS web site that states that he uses all compliant printers to produce his goods. When the ambulance chasers finally arrive at the door (they will - just a question of when), there should be a way to "back track" an order to its produced date and any information required for its process. The answer to the "back track" is the PO number issued by the broker. We could and probably should keep records of what we used in the production of "lil Jonnies baseball jersey" at the time of printing so it can be back traced.  Sure enough, some kind of a stamp with a number to reference and a record of the ink used referencing that stamp can be internally used.  Purchasing the correct inks and keeping the ink companies certificate for that ink would be a good idea. Having a lab test – say, once a quarter - for a completed product using that compliant ink would probably satisfy the issue as well. Some guy (Pierre – you listening) will probably create tracking software and a stamp (for sale) for this purpose. Printers with a mix of good and bad ink will have to throw away a lot of “bad” ink and do some sanitizing to get a good test but in the end, it may garnish more business for all the obvious reasons. Yep –it will be a pain in the a$$ 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
Title: Re: Responsibility when printing for the trade. Need answer immediately!
Post by: blue moon on February 09, 2012, 05:14:41 PM
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