Cheryl Falvey, general counsel to the CPSC, responded to a letter from Allan Adler concerning books and the Consumer Product Safety Improvement Act of 2008. Falvey's response appeared to exempt "ordinary books" from the law, BUT, wait, she goes on to contradict herself in the course of her "clarification."
Quoting Holly Jahangiri, from her blog Do I Have to Spell It Out:
I'm confused - and a little irked. Contrary to popular belief, using clear and unambiguous language in legal writing - as opposed to obfuscatory "legalese" and weasel words - is a good thing. What we have in the latest Falvey memorandum is weasel words. The CPSC could point to this one document and say accurately that "ordinary books for readers of all ages" are exempt from the requirements of the CPSIA, but that those same books, if "intended primarily for children" are not. The same books. Regardless of who's actually reading them. And who determines intent?
Holly ends her blog post with the following paragraph:
The only thing clear at this point is that many individuals and small businesses that are centered around making quality products for children are playing it safe: holding deep-discount "CPSIA sales," laying off employees, destroying their inventories of children's merchandise, closing their doors, and in some cases, declaring bankruptcy. The damage has already begun, and February 10 - National Bankruptcy Day - is less than a month away. How is it that this law is only now making headlines, at the eleventh hour? This is, indeed, cultural genocide - and not just against Native Americans. With each passing hour and day, any hope of a clear, unambiguous stay of execution from the CPSC fades away.
Everyone needs to read Holly's complete blog post. I did, and I agree with her 100%.
Do I Have to Spell It Out
If this law isn't repealed or halted in some way, immediately, we'll more than likely have to say, "Goodbye, 4RV Publishing. We'll miss you."
NOTE: More "Weasel Words"?
Another memorandum from Cheryl A. Falvey, General Counsel CPSC, "clarifies" the effect of the CPSIA on inventory.
After reading it several times, I'm still confused.