A book publisher contacted us with concerns about the impact of the Consumer Product Safety Improvement Act (CPSIA) on print on-demand production of books:
We are a book publisher who thanks to your newsletters have become aware of the benefits of using print-on-demand when introducing new titles or reprinting slower selling titles. Since most of our titles are for children the CPSIA legislation will make it impossible to use print-on-demand for books designed for children 12 and under. At that time third-party testing of at least one book from each and every print run is mandatory. The cost ranges from $120 and up. Your articles project large increases in digital print. How will the loss of the children's book market affect digital print companies? Are digital printers looking at ways to address this problem?
Has anyone addressed this issue with customers? What recommendations are you giving your customers?
On the legislative level, the industry associations are working with the Consumer Product Safety Commission and legislators to find relief for printers.
The PIA Legislative Action Center has an active action alert on this issue: Tell the Consumer Product Safety Commission to Provide Relief to Printers. The Printing Industry of Minnesota has compiled a page outlining the current status of CPSIA with regards to printed products. The Association of American Publishers is also tracking this issue.
Update 1/29
This was just sent out by the PIA imPrint:
Printing Industries Joins Petition to Delay CPSIA Printing Industries this week joined the National Association of Manufacturers and other associations in a petition calling for a delay in the implementation of the Consumer Product Safety Improvement Act (CPSIA). The petition asks the Consumer Product Safety Commission (CPSC) to delay the effective date of the regulation until 90 days after final comprehensive rules are issued. Final rules are not expected until the spring. A delay would allow more time for Printing Industries and allies to get an exemption from the law for ordinary children's books (see below).
Discussion
By Andy McCourt on Jan 27, 2009
That's a fascinating and insightful observation/challenge. If the print run is 'one' how can a copy be submitted for CPSIA, or a country's equivalent thereof, for the okay to put in the hands/mouths of our children? My view is that it requires a re-think and the involvement of the equipment manufacturers, who often also supply the paper, toner or ink. A generic process-based approval could then be possible; that is the book if printed digitally (and therefore locally to market where standards can be enforced), is certified safe by the CPSIA on the basis that it has been produced by a fixed, known production method. Companies such as HP, Oce, Xerox and Canon should engage with the CPSIA in order to achieve this certification of safety. In the offset world, where so many children's books are printed in China, Thailand and increasingly India, it is essential to have the copy analysed as there have been cases of toxins finding their way into the printed product; either from the paper/board source (dioxin) or the inks and adhesives (lead, pigments, formaldehyde). For 'kitted' children's books; the safety issue is a non-printing one such as stick-on moving 'eyes', tip-ins, sharp edges on pop-ups etc.
So my suggestion is to certify the processes and have the printer sign an agreement that, if the digital process varies (unlikely), he will submit another generic book copy for CPSIA approval. This will also help to bring the printing of short-run children's books back into the countries where they are sold.
By George Alexander on Jan 28, 2009
The AAP is among the organizations taking the lead (pun not intended) in getting this cleared up. A report on the latest activity is at http://www.publishersweekly.com/article/CA6631645.html.
It looks like it will be resolved either by (1) a specific exemption for books (the preferred resolution, of course) or by (2) what is called "component testing" -- the certification by manufacturers of paper, toner, binding adhesive, lamination film, etc., that their ingredients in the process are lead-free.
There is reason to hope that this particular episode will be resolved without too much impact on printers.
By Michael Josefowicz on Jan 28, 2009
It does raise the fascinating question of how regulations have unintended consequences to shape the market.
I like that approach of setting standards as Andy McCourt suggests. The nice unintended consequence of that approach might be . . .
"This will also help to bring the printing of short-run children’s books back into the countries where they are sold."
It's the same big force that is driving Wal Mart to source their produce locally whenever possible. it's not about green. or even about saving money. It's about risk management.
The old saw is that people make decisions driven by fear or greed. My experience is that most often it's really about fear.
By Linda White on Jan 28, 2009
On our website, we have a letter provided by Printing Industries of America that is meant to be sent by printers to their clients, clarifying this new law. In reality, this should only affect a very small portion of printers, but the confusion potential is vast. If you click the link in the CPSIA item on our home page, you will find we have a page of material, including the client letter template. We are constantly updating this as the Printing Industries of America continues to provide information on their efforts.
By Bob on Jan 29, 2009
Until the legislation is changed to exempt "ordinary books" intended only for reading, you are only required to have in place a "reasonable testing program".
If your process doesn't change, send a sampling of books and or materials to a lab for testing. You should continue to do this under a "reasonable" frequency testing program. This is yet to be determined by the CPSIA General Counsel.
February 10 is approaching quickly. Normal time frames for having books tested have been anywhere from 3-7 weeks. The accredited labs will become more overwhelmed with testing products as any manufacturer that provides a product that falls under the definition of the legislation is also required to have their products tested.
By Michael Josefowicz on Jan 29, 2009
"Normal time frames for having books tested have been anywhere from 3-7 weeks."
Another example of how the time/space of big formal organizations is not the same time/space as the real world.
Is there really any good reason this should take 3 to 7 weeks? It would nice if NoDrama Obama invents Government-On-Demand. Maybe he will hire all the baby boomer printers who have been through this for years as advisers and managers.
How's that for an economic stimulus program?
By Bob on Jan 29, 2009
Michael;
The reason the time frame is (or was) 3-7 weeks is that there are only so many "accredited labs" that can test for the materials that fall within the legislation. They are listed on the CPSIA website.
As stated earlier, this time frame will surely be extended even longer due to all manufacturers that produce produce towards the targeted age group will also be required to use these same accredited labs.
By Michael Josefowicz on Jan 29, 2009
Bob,
So what does it take to be "accredited"? Is it a technical issue? Is it really that hard to test the stuff? Are the specs posted on a website so that printers could do it themselves?
My point is that legacy practices that worked in a slow economy lead to silly situations in a google-mart economy.
By Sarah Natividad on Jan 29, 2009
Andy McCourt's idea is a good one. Sadly, there is no provision in the CPSIA for using process standards to certify lead levels. The law is very specific about finished products being tested.
By Michael Josefowicz on Jan 30, 2009
Maybe it would be a good idea for PIA to encourage the CPSIA to use process standards and significantly speed up the certification process. And issue some statements to that effect.
The discussion between government and business is usually framed as government is on the side of the angels, business is not. Business responds with "jobs.jobs." And some compromise is reached.
Maybe this small issue is an opportunity for the Print industry to start to change that. As in Print,"Yes ,we agree that is a worthy goal to protect the consumer.But you, Government, is too slow to get it done in the real world. So, to protect the consumer and make our industry better, you, Government, have to do it faster, better, cheaper.
The much bigger issue we are already facing is Do Not Mail. As it continues to bubble through the state legislatures sooner or later it's going to emerge as an "issue" for some politician, somewhere. Getting on the wrong side of that one, is going to hurt every "Print is good" marketing campaign.
Many creatives and students, who tend to dominate the blogosphere discussion, already think Print is "Bad for the Environment" Save the trees!!
Yes, we know that mostly they are wrong. But to the extent that we are seen as the "bad" guys creatives and students will to have a "reason" to not see the value of Print in multi-channel campaigns and furthering the growth of knowledge.
By Tom Graham on Feb 04, 2009
On Jan 20, 2009 the CPSC recently posted a one year stay of testing and certification requirements for certain products regarding the certification and testing of total lead and certain phtalates in children's toys.
The stay should be read carefully as it does not apply to all requirements regarding lead.
By Michael Josefowicz on Feb 04, 2009
Tim-
Am I right in understanding that the government dealt with the problem by delaying the implementation?
If that's true, it's another example of a big formal organization dealing with a problem by putting it off till next year.
Wouldn't it be neat if Printers could do that?
By Heather Idoni on Feb 25, 2009
Dr. Seuss Meets the CPSIA
http://www.easyfunschool.com/the_CPSIA_meets_Dr_Seuss.html