Comment from David Richter

This is a Comment on the Consumer Product Safety Commission (CPSC) Proposed Rule: Safety Standard for Magnet Sets

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There are three principal arguments against the ban.

First, magnet sets are not defective in any way. They do exactly what they are designed to do. Moreover, they are perfectly safe when used as directed. In this way, they might compare to hobby knife blades. Hobby knife blades are sold with a clear warning which, by design, becomes separated from the packaging while in use. No one at the CPSC is proposing to ban hobby knife blades.

The other problem is that the ban is arbitrary and therefore sets a dangerous precedent. We live in a world with many recreational items which are dangerous (even when used as directed) and still legally obtainable. It would be impossible to list all of them, but one immediately thinks of balloons, trampolines, skateboards, surfboards, fireworks, handguns, baseball bats, hockey sticks, motorcycles, personal watercraft, downhill skis, and so on. All of these products have proven to be dangerous and the CPSC has not banned them. The CPSC is supposed to protect the public from defective products and issue warnings about hazardous products. Therefore they shouldn't waste their resources on magnet sets, which, as the statistics show, are safer than any of the products listed above. This ban on magnet sets could therefore potentially put the CPSC on a road towards irrelevancy.

The third argument against a ban is that it couldn't possibly be effective and it would only lead to a black market. Magnet sets are popular because they are fun. Millions of kits have already been sold to consumers in the US. Most of these people will not return their sets to merchants because of a CPSC recall. If the CPSC establishes this ban, millions of sets will still be in the hands of US citizens. If there is a ban, a black market will inevitably emerge. This would be more pernicious because then we would then have many magnet sets sold without the CPSC-required warnings.




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Comment Period Closed
Nov 19 2012, at 11:59 PM ET
ID: CPSC-2012-0050-0036
Tracking Number: 81114fb0

Document Information

Date Posted: Sep 13, 2012
RIN: Not Assigned
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Submitter Information

Submitter Name: David Richter