Dear Chairman Stratton:
We respectfully request that you extend the comment periods (The February 28 deadline for presentation materials, the March 17 hearing date, and March 28 deadline for written comments) on the Consumer Product Safety Commission’s briefing package on petition HP 01-3 requesting a ban of chromated copper arsenate (CCA)-treated wood in playground equipment.
These comment deadlines provide unusually short notice for comments on an important and complex topic that has the potential to significantly impact thousands of small businesses and local governments as well as millions of consumers. Many interested parties are just now learning about the hearing and many more have yet to hear about this opportunity to express their views. Moreover, analysts and other interested parties deserve more time to ensure thorough review of the CPSC study on the topic.
Many small businesses and local government officials only learn of such comment opportunities through association newsletters and publications that are published weekly, monthly, or quarterly. Several weeks’ notice does not provide sufficient opportunity for these affected parties to make plans for appearing or even drafting adequate written statements. Accordingly, we request that you extend all three deadlines to provide the more customary 60-days notice.
Rule making is a serious process — not something to be rushed through before the affected parties can have an opportunity to comment.
Fred L. Smith,President,Competitive Enterprise Institute
Andrew Langer,Manager, Regulatory Policy,National Federation of Independent Businesses
Gilbert Ross, M.D.,Medical Director,American Council on Science and Health
Frances B. Smith,Executive Director,Consumer Alert
Paul Weyrich,President,Free Congress Foundation
Darrell McKigney,President,Small Business Survival Committee
Amy Ridenour,President,National Center for Public Policy Research
H. Sterling Burnett, Ph.D.,Senior Fellow,National Center for Policy Analysis