Archive for the ‘Children’ Category

24 Karat Lead Bicycle

Late last January, the Consumer Product Safety Commission (CSPC) slipped manufacturers and importers of children’s products an 11 month extension of the stay of enforcement for testing and certification of lead content in children’s products (other than metal components of children’s jewelry).

Photo by Albert Jankowski. Some rights reserved.

This was the third (and ostensibly final) extension of the stay of a portion of the rules originally scheduled to become effective in February of 2009. These rules – published as Section 101 of the Consumer Product Safety Improvement Act of 2008 (CPSIA) – were designed to reduce children’s exposure to lead by setting new limits for the lead content in children’s products and the paint used on the products. Specifically, no children’s product should have more than 300 parts per million (ppm) of lead content. This limit will drop to 100 ppm in August, barring further CPSC interference.

CPSC is quick to point out that, while manufacturers and importers will not be subject to testing and certification requirements for the duration of the stay, they are not exempt from compliance with restrictions on total lead content. Once the stay has lifted, however, those subject to the rules best have “the appropriate certificates demonstrating that their products comply with the CPSC-approved third party laboratory testing requirement in order for their products to be sold in the United States,” reminds law firm King & Spalding in a recently published Alert.

EPA Takes You To School

Earlier this week, the EPA released draft voluntary guidelines intended to help local officials and community members select safe locations for establishing new schools. According to the EPA, more than 1,900 new schools (serving about 1 million children and costing more than $13 billion) opened in the 2008-2009 school year. In the case of such large scale projects, prevention is key. As the EPA points out, “the potential impacts on children’s health and education, as well as the damage to the community when school environmental hazards are later identified, are significant.”

Photo by The-Lane-Team. Some rights reserved.

The guidance materials were developed pursuant to a provision in 2007’s Energy Independence and Security Act (see Subtitle E—Healthy High-Performance Schools) that required the EPA – along with the Departments of Education and Health and Human Services – to develop model guidelines on school siting that took into consideration “special vulnerabilities of children to hazardous substances or pollution exposures in any case in which the potential for contamination at a potential school site exists,” as well as transportation availability and energy efficiency.

While I scoured the EPA website for “the draft guidelines” document, it turns out that the guidelines, at this point at least, are only a collection of topical webpages that include tables, charts, FAQs, and lots and lots of bullet points. The three main content areas are: siting criteria, environmental review process, and public involvement, but the information is also broken up by stakeholder, and there are sections for parents/teachers, local officials, state officials, and tribal officials. Siting criteria range from “air quality” and “impact on community’s long range vision” to impacts on the environment from the school, such as “changes to surface and storm water drainage patterns” and “loss of habitat, including for endangered species.”

Initial versions of the guidelines were refined based on input from a special task group comprising a wide range of stakeholders. If you weren’t lucky enough to sit on the task group, it’s not too late to give feedback. Once you have reviewed the draft guidelines, you can submit comments here. Comments will be accepted until February 18, 2011.

%d bloggers like this: