AAP, BMI and PIA Statement on House Subcommittee CPSIA Hearing
Thursday, 17 February 2011
Statement from the Association of American Publishers, the Book Manufacturers’ Institute and
The Printing Industries of America Regarding the February 17 Hearing
Held By the House Subcommittee on Commerce, Manufacturing and Trade Hearing Concerning
“A Review of CPSIA and CPSC Resources"
National organizations representing U.S. publishers, printers and manufacturers of children’s books praised the House Energy and Commerce Committee for holding a hearing early in the new Congress to review the troubled implementation of the Consumer Product Safety Improvement Act.
Popularly known as CPSIA, the regulatory statute was enacted in August 2008 and established stringent requirements for total lead-content testing and certification for children’s products following news reports of dangerous levels of lead content found in children’s toys imported from China.
The three national organizations urged the House committee to begin a process for considering amendments to the statute that would address at least one of the unintended consequences of its enactment: its application to ordinary paper-based children’s books and other printed, paper-based materials produced for children.
Representatives of the Association of American Publishers (AAP), the Book Manufacturers’ Institute (BMI), and the Printing Industries of America said, “While obviously well-intended, the statute’s sweeping definition of ‘children’s product’ extends CPSIA’s costly and burdensome total lead content testing and certification requirements to things such as ordinary paper-based children’s books and other printed, paper-based children’s materials that previously were not “regulated products” within the jurisdiction of the Consumer Product Safety Commission and have no history of risking the exposure of children to toxic lead content. Moreover, CPSIA imposes these requirements without any provision for risk assessment, which has been the key methodology underlying extensive studies of children’s exposure to lead that have been conducted by other agencies of the federal government such as the Environmental Protection Agency.
“Based upon test results provided to the Commission by children’s book publishers, printers and manufacturers, the component materials comprising ordinary paper-based children’s books and other printed, paper-based children’s materials — such as flash cards, posters, bookmarks, and worksheets — consistently fall well below even the lowest levels of lead content permitted for children’s products under CPSIA. In fact, the Commission has already excluded the paper, ink and adhesives that typically comprise most of the mass and weight of these products from CPSIA’s testing and certification requirements, but has been unwilling to exclude the finished products themselves pending further research into certain laminates and binding materials that are sometimes elements of ordinary paper-based children’s books.”
“If Congress considers the facts in connection with these particular types of children’s products, which are not toys and are so important to children’s literacy and other areas of educational development, it will become clear that a statutory exclusion of ordinary paper-based books and other printed, paper-based children’s materials from CPSIA’s total lead content testing and certification requirements is both warranted and appropriate. If Congress should decide that there are simply too many children’s products that are subject to CPSIA to consider statutory exclusions for specific products, then it should recognize that the addition of meaningful ‘risk assessment’ standards and procedures to the statute, which would permit consideration of relevant existing ‘risk assessment’ studies conducted by or for other federal agencies as well as the conduct of new ‘risk assessment’ studies, will be a critical way to ensure that CPSIA’s testing and certification requirements are more workable and imposed only where they are justified by an assessed risk of harm to children. Otherwise, CPSIA’s broad, sweeping imposition of these costly and burdensome requirements will continue to needlessly pose a threat of higher prices, fewer products and lost jobs for the businesses that create these important children’s products.”
AAP is the principal national trade association of the U.S. book publishing industry, and represents some 300 member companies and organizations that include most of the major commercial book and journal publishers in the United States, as well as many small and non-profit publishers, university presses and scholarly societies. AAP members publish literary works in hardcover and paperback formats in every field of human interest, including trade books of fiction and non-fiction; textbooks and other instructional materials for the elementary, secondary, and postsecondary educational markets; reference works; and scientific, technical, medical, professional and scholarly books and journals. In addition to publishing in print formats, AAP members are active in the E-book and audiobook markets, and also produce computer programs, databases, websites and a variety of multimedia works for use in online and other digital formats.
BMI is a leading nationally recognized trade organization whose members are book manufacturers and companies that provide materials, equipment, and services to that industry. Our member companies produce the great majority of the books ordered by the U.S. publishing industry.
PIA is the world's largest graphic arts trade association, representing an industry with approximately one million employees. It serves the interests of more than 10,000 member companies involved in every stage of the printing industry from materials to equipment to production to fulfillment. General commercial printing--magazines, books, brochures, advertisements, and more—comprises the largest segment of the printing and graphic communications industry. Packaging printing, ancillary services, and digital printing also round out the industry's diverse product line.