What visual asset news my name is Rob, but today I want to talk to you about is What I am buying every single day as far as crypto and what I am buying every week And the reason for this is I want to make things crystal clear because I've been pretty bearish on this channel But I'm gonna talk about the bearish side I need to talk to you about the bullish side and as to why in the long term I am incredibly bullish. Also, I want to talk to you about not just what I'm buying But why I am buying it in this specific fashion I think the why is more important than the what and lastly we're gonna talk about why now is the time in my Personal opinion for me to buy I see some pretty big dangers head So the first things first is what crypto I'm buying and this should be no shock to anyone I am buying Bitcoin every single day and What I want to do is I want to show you just Some past Examples and what we're using here is DCA dash CC calm links in the description do this yourself and just check it out I want to make this very simple and we're gonna go back all the way to 2018 I'm gonna say that I'm gonna buy a hundred dollars per week of Bitcoin starting on 2018 and ending in 2022 in December now. Why do I talk about 2018? It's because if you've watched the channel I'm a big believer in of course the four-year cycles and of course everything starts with a halving Which the first one was in 2012 then a year after we usually get an all-time high and then a dip and a reset Same thing happened in 2016 We had a halving all-time high a dip and a reset and then we just had another again in 2020 We had a Bitcoin halving then we hit the all-time high in 2021 now We're going through a dip 15 7 was the lowest right now. It is December 29 2022 I don't see it's gonna go much lower than 15 7 this year and then maybe we'll see More things happening in 2023 and I'll just repeat again and so on and so forth But now of course when we talk about these things past performance doesn't indicate future results But if we take a look at where we've been we can kind of take a look at where we're potentially going So take us with a grain of salt, but if we do a hundred dollars per week and start in 2018, which would be After the all-time high in 2017 2018 We had that big dip and a reset if I would put a hundred dollars per week into Bitcoin You're gonna see right here that I'd be eating it. I'd be Eating crow for quite some time. You can see the total investment here is $200 on the second week The balance and fiat is 212. You can see that actually my investment Is not doing so good for quite some time and actually I'll be underwater For for quite a quite a bit of time. Why is that important? It's because as time goes on things work out But you can just see here that throughout the whole year of 2018 Maybe not a good idea to invest But if I just had some extra cash laying around sure enough and I would be underwater until roughly 2019 and then of course as time goes on of course those those past buying opportunities at 3,000 Bitcoin or 4,000 Bitcoin or 5,000 Bitcoin would have paid off handsomely if it would have timed it perfectly the total investment would have been 20,000 and I would have had a balance of 146,000 dollars, which is roughly a 7x now same thing happens here What if I would have just started in 2019 and just said okay? I'm a dollar cost average a hundred bucks starting on January 1st 2019 all the same thing I'd still be underwater, but it would have taken me a lot less time To get into it and actually have been positive in that same year However over here as we take a look at the gains I would have invested 15,000 at a hundred thousand dollars roughly which I gotta tell you In my personal opinion that would have been a better option for me because I would have still be roughly at a 7x So if we take a look back 2019 would be two years after the all-time high 2023 will be two years after the all-time high of Bitcoin in 2021 so I think that might be a better time frame now Let's take a look here and just say well well Rob. What if I don't know What if I just would have invested in to the bull run in in 20 and or a year before in 2020? So if we had done that 2020 what it looks something like this Wouldn't have been too great I don't really see it 9,800 so The deeper the bear market that I invest in to cut through all the money's made the more gains I have later on then of course I would have done in the bull market bull market started in 2021 You can see that I would have done so hot quite honestly I would have done okay. I would have invested $4,600 and would have had a whopping 6,075 so again not even a not even a 2x which is pretty sad now That's just Bitcoin. That's why I buy Bitcoin every single day I think it'll be pretty do pretty well. We're gonna talk a look at why but let's just take a look at a Ethereum so if I would have put $100 weekly for Ethereum again in 2018 started over here and just in that every single week for Ethereum by 2021 I would have put in 20,000 and got 329,000 so as we go down the list as far as altcoins You can see that there's a a much bigger gain here than what it was before so look at what 1416x I'm around there Ethereum let's say we started in 2019 and done the same thing. Well, this one But it's still been pretty good. And again, I still think if we're looking for risk to reward I think in 2023 we're looking at the four-year cycles still a pretty good time and of course Ethereum if we did it in 2020 We would have had about a 10x which is still pretty good. And if we were done in the Bull market and 2021 you can still see that we wouldn't done much So that's again why I say if we're going to invest I personally believe it's best to invest In the bear market when nobody wants to invest and it is super Duper boring and we talk about that here when things are boring nobody wants to invest in shopping sideways That's when you that's when I dollar cost average You can do whatever you want to not your dad, but that is what has worked for me So then we take a look at that here are the cryptos that I am buying every single week and I know that there's Difference of opinions here about how we can we can still fall and I agree we still could fall But I'm buying polygon and chain link Ethereum Algorand Cosmos and Cardano every single week on different days dollar cost averaging will they go down? Probably they probably will go down and I'm okay with that because if we take a look at the rules underneath me I just have to assume that I am investing what I can afford to lose. It's all gone Everything's a scam until otherwise the only man in exchanges don't use leverage and take profits along the way We'll talk about in a second so that's what I am buying right now every single week and again past performance doesn't guarantee future results and Talking about that This is the thing. I Still believe we're gonna go lower. So why don't I just hang on? I'll tell you in a second. So if we take a look at the Bitcoin price from the four-year cycles Cycle one from the top of 2013 down to the bottom of 2015. That was an 85% drop Cycle two 2016 2019. It was an 84% drop cycle three We thought the bottom was in June and everybody was Blasting about how they were right and how they knew it was June and they were wrong and Actually, the bottom so far is the 9th of November at 157. That was a 77% drop That's why I don't believe anybody and that's why I continue to dollar-cost average Because I don't know who's right and I can't time the markets, but I will do this see this thing called dynamic DCA. I am not Dollar-cost averaging as much as I used to because I'm unsure However, what I like to do is just take a look at and go okay if I'm gonna buy I don't know $40 of Bitcoin every single day Let's just say for example Then once we start to hit into the $15,000 level of Bitcoin and below I will increase that by 10% so then every every single day I will buy 44 I'll just round up 45 bucks and then when it goes to $14,000 that's another thousand dollar drop. I will increase by 10% again 13,000 10% 12,000 10 more percent 11,000 and so on and so forth and I dynamic DCA down because the risk is not as high Because things are just kind of collapsing. It's a counterintuitive way to think but I think that that's what will happen Moving forward and also when you take a look at some things we've been talking about as far as 10 year bear markets Now we've talked about this Not extensively, but a couple of times here and there we've had Jordan. We're son and we've talked about 10 year Bear markets Historically in the housing market and also historically in the S&P 500 This is looking at the S&P 500 over the last hundred years or so back from 1929 and one thing that we've been talking about is what Stanley Druckenmiller talked about one of the investing legends He said look he goes in the 1960s. We were we never we didn't hit a hair all-time high for 10 years and he said in 1968 we're looking at 870 870 for the S&P 500 and look how long it took to get back to 870 in the S&P 500 it actually took quite some time and if we just keep looking at it 870 was roughly around oh No here 1992 So if you want to talk about getting back to the original levels, that's how long it took for the all-time highs however That was quite a bit of time right but look at this one in 1929 great depression to get up to 519 you know how long it took All the way over here in 1956 That's 30 years and then also take a look at this and the S&P 500 which no one talks about this I don't know why it's right in front of our faces in 2000 to get back up at the all-time high of 2466 you know how long it took 2466 It took you to 2014 2013 now 2014 to get you all the way back That's 14 years to get you all on all the back this and I don't know if you if you remember 2000s, but I had no problems making money back then as far as a business owner a small business the different things I started up with so evenly S&P 500 make tank and we have problems here Doesn't mean that the rest of the markets will however We are in lockstep right now That's what it is But I want you to focus on a couple of things first of all even though we don't hit the all-time eyes There's still gains to be had and that's just to say that's what's happening But if you can go down here by down here look at this one in 1929 not to get the all-time eyes you were looking at 96 if you would have bought in 32 and look over here 1936 Seem to be doing pretty good the same thing over here in 2000 and so on so forth So when I talk about a 10 year bear market, it doesn't mean there's not opportunities there's huge opportunities and that will get to a couple things of When I'm gonna personally sell there's a website Dan teaches crypto. We're just gonna log in real quick Of course, that's a hundred percent free very simple to use. I put all my best information here It only cost you an email to sign up. I don't even spam you I make this free so you can learn from it under module three investing. I've got some pretty In-depth videos here about risk wide dollar cost average for your cycles But this one 2025 bull run exit strategy and of course we talk about this and of course when I'm gonna sell 80% of my crypto That's to that's to assume that we go into 2025 like we talked about over here That's to assume That's we hit an all-time high in 2025. But what if it doesn't? What if it doesn't what if we extend out because of this new paradigm shift in the global economy? Could you handle it if you were able to accumulate in 2026 and maybe? 2027 is the new all-time highs or whenever it is again think back till we took a look at over here for Bitcoin and Ethereum and the longer that things took Just the better after it was actually moving forward So again take a look at that video also when I talk about and it's right below me taking profits There's an app I use I have no affiliate link with this. It's called Delta Delta dot app I'll put a link in the description. It's not affiliate They didn't pay me or nothing like that But it's very simple because it's free and you can plug in your information here And it can tell you like on one day three day or one week How much you were up or down on your crypto? So as time goes on if you want to take profits like well, how much should I take well? It's gonna be right there and it makes things super simple I think that's the best way for some people you can do whatever you want to do But this then gets down to the most important question. Why? Why do I continue to buy and it goes like this very simply? Our market cap again December 29, 22 is 831 billion We used to be at three trillion dollars. That is paltry. That is nothing Apple has more of a market cap than the entire crypto market put together and when I take a look at that and go Okay, if we take a look at how much funds are floating around or money that's floating around in the world This is the stock market and roughly this is in 2020. So there's more there Let's just say a hundred trillion if we take 1% of a hundred trillion from the stock market where people like, you know what?  Let's say everybody does that 1% of a hundred trillion. Let me do some quick math Oh, yeah, it's about 1 trillion. So you take 1 trillion from the stock market gold is roughly 12 trillion Let's just say we take 500 billion from that people like, you know what? Well, it's not really doing too much or maybe they don't maybe they diversify like people are talking about Here's the money supply a hundred trillion. It's more now Let's say 1% goes into crypto global debt 233 trillion. Let's just take I don't know other 1% of that we're doing pretty good as far as like two and a half trillion or somewhere around there global real estate Let's say people like, you know what? Just like what Jordan Wears was talking about maybe there's not a good plan for real estate Maybe we're gonna see more of a collapse. Maybe I should diversify a little bit more Maybe get into crypto. Maybe we'll take I don't know 1% of that and then maybe the global wealth That's at 300 and something trillion dollars or maybe we go into the derivatives market Which is oh, you know the little stuff like futures forwards options warrants swaps, which is one quadrillion We take one or two percent of that. What do we got? We got a heck of a lot more than three trillion dollars and That's where the magic is now. Could this happen? No idea, but I can tell you right now. I think There's gonna be more of a fireworks later on and then lastly and this is the thing that I get we we heard from Larry Fink He talked about tokenization is the future and people would say but Robbie don't understand when Larry Fink talks about that He's talking about he's gonna have his own private blockchain Could I think it's a huge mistake and would tell you why because big businesses? They don't have time resources Management just to spin up their own blockchain. They could I mean they definitely could but here's an example Take a look at Facebook Facebook back in the day. This is we're looking at 2005-2006 when they first started up they knew to get to the finish line faster They're just gonna start buying everything up It's a lot easier than creating your own and they could create their own I can tell you right now this fright Friend feed or whatever the heck this was parakeet connect you they could have just made this they could have just let these guys collapse But they're like no no no we're gonna buy it 15 15 billion What I want you to notice is this time goes on how much they are spending on buying up other things or building on top of those Things here's 2011 50 billion dollars. They bought snap two datums. So I don't know what this stuff is 83 billion they bought this thing called Instagram Don't you think they could have made a pretty easy way of an Instagram?  No, they bought it because they want to be the bigger ones acrylic Threby karma face Honoville onyx, but look at the prices in 2013. They spent 75 billion thousand fourteen hundred forty five billion thousand sixteen two hundred seventy five 520 billion and so on and so forth so when we talk about how like these banks are going to do their own private blockchain And just build it all up and get all they could do that But I think the faster better easier option is just to build on top of other existing blockchains or Just buy something up and do it that way which would be a public blockchain. So that is why I continue to buy and This comes down to why I think now is the best time or is the time because I see some dangers ahead Look things aren't getting easier out there, but I think things are going to accelerate especially with AI and AI and robots and when people talk about this and like I don't ever take my job just Take a look at something like this. This would be like in a warehouse if you're looking at working on the warehouse This is the future for you. Unfortunately, here's some crazy robot doing God knows what and and You know picking off and oh Yeah Recyclables and things like that and then I'll link this video as well Again, all these things just start to eating up your job and not only is stuff like that But we can also see like AI as far as in the creative side Chat gpt Everybody's been talking about this. I want to show you something If you're a creative person, this might scare you or it might incentivize you and make you say well I can super charge things. I just put in here write a blog post and a friendly voice on decentralized public blockchains Versus private bank blockchains, which we're just talking about. I'm gonna click go and watch this Hello, everyone. I want to talk about this means and I didn't think that it could be this accurate But here it talks about in real-time a Blog post which you could put this into another program run it through a voice synthesizer and then put Backgrounds of videos and become an influencer on YouTube just saying my job is at risk as well Thankfully, I have other things in real estate and stuff like that But you can just see Pretty much how accurate actually is Private blockchains are typically permissioned systems only open when I've done two blackchains one major difference in terms of accessibility You know the key difference in security again just goes on and on and on and it doesn't stop there How about this? You know, everybody's talking about learn to code learn to code load occurred learn to code I just said this write a code and HTML for a travel website and Sure, here's some sample HTML code for a travel website now again. This is just an HTML I'm pretty sure it can do it in other languages and I'm pretty sure it's not a hundred percent accurate But how much time would this take? Especially if you're a small business owner and don't want to pay somebody to do something like this just say create my website Here we go and not only that for different products that are out there And then for more creative people take a look at this I put in there This one's called crayon.com C. R. A. I. Y. O. N. I said put a YouTube thumbnail of Bitcoin in the world Not too great But this is the first iteration and I did it over here as well Bitcoin in the world and just spun up stuff like this and there's a ton more coming so when I talk about now is a time what I'm talking about is This is the time to start to invest and get into things that Can pay off later for future generations me personally I like real estate because as much AI comes about people are still gonna need a place to live a Place to hopefully work and just a place to to set up camp also for crypto digital assets as time moves on I just give you a pretty much an idea of where things are potentially going because I mean that's what it's gonna be now But we take a look at the things that are AI Let's say that jobs get stolen like that where are you left with now? So I think it's a good idea to take a look at the things that you can invest into now and move forward But again, it could be wrong anyhow. That's it for today's video like today's video give it a thumbs up Consider subscribing we talk about most of the news every day, but we throw in different videos like this just to show people Where my mind is that that is it? So thanks much for stopping by appreciate it. I'll see you on the next one


Alright, so let's treat an example of a particle in a box with some quantitative calculations. And in fact, we're actually going to compare two different examples of particles in boxes. We've seen that we can use the particle in a box molecule, sorry particle in a box model to describe both electrons confined to a molecule, a conjugated section of a molecule. An example of that would be something like, I'll draw three fused benzene rings. That's an anthracene molecule. If we measure the frequencies of light absorbed by anthracene, anthracene absorbs light at around 375 nanometers. So that's the photon of light that has a wavelength of 375 nanometers. That value is at least approximately 10 to the minus 19th joules. That's the energy of a photon absorbed by an anthracene molecule. Remember that that corresponds to there's a pair of energy levels separated by this much energy. And then when I shine a photon with the same amount of energy, it can excite the electron from the lower energy level up to the upper energy level. So a photon with 375 nanometers has this much energy. It's enough to excite the electron between a pair of states that differs by exactly that much energy. And those correspond to states that we can predict reasonably well with the two-dimensional particle in a box model. Mention the energy just as a way of pointing out that this value compared to kT. Remember the value of kT at room temperature is about 4 times 10 to the minus 21 joules. So the 10 to the minus 19th joules that represents a photon on the red end of the visible spectrum is quite a bit, I'm sorry, that's the wrong direction, 10 to the minus 19th is quite a bit larger, several orders of magnitude larger than kT, which has a magnitude of about 10 to the minus 21 joules. So this energy level spacing between levels for the anthracene molecule is much larger than kT. We immediately know by comparing those energy differences to kT, several things. For example, we know that because it's so many kT, 100 or so kT to get up to this state, the upper state is not going to be very populated. Most of the electrons in this molecule, an overwhelming majority of the electrons in this molecule will be on the lower energy levels. We also know, for example, if we were interested in the partition function because the only states that are populated, the states low compared to kT, that the partition function is going to be relatively small for this molecule. Those factors both contrast with the other example we've talked about using the 3D particle in a box model for. If the particle is not an electron but an actual molecule, so let's take the example of a molecule like a molecule of nitrogen gas. Instead of confining an electron inside of a molecule, it's confined an electron inside of a physical box. So nitrogen as a gas will stay confined to a box that you place it in. And we can take, as an example, maybe the room that I'm standing in or perhaps the room that you're sitting in. Just as a rough estimate, let's say we're in a room, a cubic room whose length, width, and height are all about 5 meters, roughly 15 feet on a side. So if I have a gas molecule, one of the nitrogen gas molecules in the gas in the air that I'm in, confined to a room that's about 15 feet on a side, we can use the 3D particle in a box model to describe the energy levels of that system. So we can ask similar questions, what's the difference in energy levels for that system? To do that, we need to know for a cubic box, the energy levels look like h squared over 8ma squared plus the sum of nx squared and y squared and nz squared. So in order to calculate these energies, I need to know, I certainly know what Planck's constant is. I've assumed a value for the size of the box, the mass we need here. Remember that we're not talking about an electron anymore, we're talking about a nitrogen molecule, so we would need the mass, the molar mass of a nitrogen molecule, so we know that value. And we also need these n values. So if we go to perform this calculation, Planck's constant, 6.6 times 10 to the minus 34 joule seconds, that gets squared in the numerator. I've got an 8 in the denominator, nitrogen has mass 14, so n2 has mass 28, that's in units of grams per mole. Stop and ask if grams are the units that we want to have our mass in, grams per mole. And it's not, we want the grams here to cancel one of the kilograms that's hiding inside these units of joules. So we need to convert grams to kilograms. And also we need to get rid of this factor of moles in the denominator of the denominator. So Avogadro's number of molecules in a mole. So far I've managed to cancel moles and grams, so that takes care of the mass still in the denominator. We're going to use 5 meters for our box size. That number gets squared, and then we're going to multiply by this sum of n's. And I'll actually leave that unsubstituted for now, and I'll just say that regardless of whether we want, let's say I draw an energy ladder. Depending on whether I want to talk about that excitation or that excitation or this excitation, I'll use different values for the n's, but this number is going to be, if I'm going from the 1, 1, 1 to the 1, 1, 2 energy level, then I need a difference of 3. Or the 1, 1, 1 to the 1, 1, 3 energy level, I need a difference of 8. No, sorry, 10. But regardless, this number is going to be a relatively small integer. So the exact value is going to depend on which excitation level I'm interested in. But let's just calculate this first prefactor term first. And for that, I need a calculator, or I need to have done the calculation ahead of time. And what I find is that this number works out to be about 10 to the minus 42 joules. So that's the quantity for which I have numbers. And then again, without plugging in specific values for the n, I'll just say I'm multiplying by a relatively small number. I'm multiplying by a few. The important thing about this value, 10 to the minus 42 joules, and let me just point out that the units do in fact work. I've got kilogram meters squared in the denominator, second squared in the numerator. A kilogram meters squared per second squared is a joule, so that cancels one of my joules in the numerator, leaving me with just one joule. So those energies of 10 to the minus 42 joules, that's roughly speaking, the difference in energy between these states is a small number times 10 to the minus 42 joules. Compared to KT, remember KT is 10 to the minus 21 joules. So there's not just two orders of magnitude difference. There's 20 or more orders of magnitude difference between the energy level spacing for the nitrogen molecule in a room-sized box. And the value of KT. So in particular, the inequality works the other way around. This energy level spacing is considerably less than KT. In fact, saying just much less than is an understatement. 20 orders of magnitude is so small as to be negligible. So in fact, the energy level spacing for molecules confined to a box, that energy gap between levels, 10 minus 42 joules, is so small that we can't possibly measure it with any technology that we currently have. It's so many orders of magnitude below energies that we can measure. So those energy levels essentially are super closely packed together. So closely packed together, we can find an energy level almost at any energy we wish. So it turns out that significant difference, the fact that electrons confined to molecules have energy differences that are quite large compared to KT. Whereas molecules confined to boxes have energy spacings that are incredibly small compared to KT. That's going to turn out to be a very important difference that arises from two different factors. The masses are different and the box sizes are different. We've changed two numbers when we went from electrons confined to conjugated hydrocarbons to molecules in boxes. A nitrogen molecule is heavier than an electron by a couple thousand folds, so that's part of the answer.  So that's roughly 9 or 10 orders of magnitude. When I square that number, it becomes enormous.  It's not much of a confinement at all to confine a nitrogen molecule to a whole room, so the energy levels are not very discretized. So as we'll see coming up relatively soon, this very, very small spacing between the energy levels for a gas molecule in an actual macroscopic sized box is going to be convenient. It's going to allow us to calculate several properties of gases by using those energy level spacings as well as some statistical mechanics. So that's the next step.


I managed to repair my broken headphones with a little 3D printed part, and now I'm just obsessed with mending everything around the house with little bits of plastic. I gotta get my fix. When you think of companies associated with design, Apple was probably one of the first names that pops into your head. Since the 90s, the $2.4 trillion tech giant has developed a brand around their dedication to design. Every press release store and billboard stresses a commitment to sleek minimalist styling and meticulous curation of their users' experience. Apple's former chief design officer, Johnny Ive, has said of Apple, Our goal isn't to make money. It sounds a little flippant, but it's the truth. Our goal, and what makes us excited, is to make great products. From that lofty position, it might surprise you to learn that the very first product the Apple Computer Company produced was more of a hobbyist kit than a polished device. The 8-bit Apple Computer One was engineered by Steve Wozniak and first presented to the Homebrew Computer Club in Palo Alto, which had inspired him to make it. Wozniak and his friend Steve Jobs handed out free schematics for the kit, and he was happy to help his fellow Computer Club members build and troubleshoot their own versions. That sort of hacky homebrew attitude is a distant memory for modern-day Apple, which has received a great deal of criticism for its protective animosity towards unsanctioned uses of its products. The company has repeatedly blocked and discouraged jailbreaking iOS devices to circumvent Apple's restrictions on things like custom ringtones or multi-recipient text messages. It's been extraordinarily protective of diagnostic tools and technical documents that might be helpful for any adaptation or remixing of their hardware for potentially unsanctioned uses. Even their marketing often implies that there is a right way to use Apple products, perhaps best illustrated by Steve Jobs' now infamous response to widespread complaints that the iPhone 4 couldn't get a cell signal if the user held the phone a particular way. Just don't hold it that way. This cloistered posture, equal parts protective and authoritative, has been especially troublesome when it comes to the repair of Apple devices, which are, by many accounts, unfriendly to anyone trying to fix them. They are absurdly tamper-proof, using proprietary screw heads, adhesives, and one-way assembly methods to discourage any but the most dedicated tinkerers. They use hardware ID handshakes to verify that parts used for repairs are official Apple components, sometimes disabling key features if someone has the audacity to use aftermarket parts. The company, until very recently, has refused to sell those licensed components, preferring to keep all non-warranty voiding repairs in-house, and setting prices that often approach or exceed the original cost of the broken device. These policies have made Apple a fair amount of money. They have also made a lot of people, both users and repair experts, pretty angry. Under increasing pressure from the Right to Repair movement, a political coalition of regular consumers and super nerds fighting against a trend of unnecessarily unfixable designs, Apple has retreated a bit. You can, now, with a set of proprietary screwdrivers, a heat gun, a study hand, and a good instructional video, replace the screen on your iPhone 13 without permanently disabling its face ID. But trust and goodwill are hard to earn back, and Apple does not seem to be bending over backward to reverse its reputation for making life miserable for anyone who wants to fix their stuff. That antagonism towards repair can be thought of as a corollary of Apple's much-lauded obsession with design. What Right to Repair activists and CEO of iFixit, Kyle Wiens, described as wanting complete control over the device from the moment that you buy it all the way through to the end of life. To ensure that every single user's experience of Apple products has the correct, slick, and polished aesthetic quality, the company has tried its best to stamp out any activity that might disrupt that experience, a custom OS that might be uglier, an aftermarket screen that might be less crisp, even a glance at the ugly circuit boards and ribbon cables inside the device might ruin the vibe of unimpeachable monolithic design. Don't look behind the curtain. We have thought of everything, considered every angle, and we have everything under control. You are in our capable hands. Trust us. Unfortunately, it's insanely hard for even the greatest designers to predict just how their designs will stop working. Take the OLPC project, as described in this 2014 paper by Rosener and Ames, a humanitarian effort to get cheap laptops into the hands of children with no other access to educational materials. The designers of the OLPC pitched it to prospective donors as being impervious to damage, flinging it across the stage mid-presentation to demonstrate its resilience. Unfortunately, they had no way of knowing what other problems it would experience in the field. Screens were a major issue. Children would often hold their laptops open and use the selfie camera to take pictures, sometimes dropping the device onto its fragile screen, rendering it inoperable. A gigabyte of storage space may have been more than enough for educational activities, but it was rapidly filled by downloaded media. Fidgety kids would pick the plastic membrane that covered the keyboard, eventually destroying it. Even the highly publicized impact resistance proved insufficient, or possibly even self-defeating. Some post-mortem analysis suggests that the sales pitch of an indestructible laptop may have prompted kids to treat their OLPC with less care than they would otherwise, leading to disaster. None of this is to say that the OLPC engineers did a bad job. It's unreasonable to expect any designer to anticipate and compensate for enthusiastic photographers, insatiable media consumption, boring classrooms, and the power of their own marketing to shape behavior. But the struggle to keep the machine's operational does help to illustrate the scale of the problem Apple is trying to design their way out of. No plan survives first contact with the enemy, and no design, no matter how smart or robust, survives forever. Things break in a countless variety of ways, and assuming that they were fulfilling some human need before they broke, there are really only two possible responses when they do. Replacement is the solution Apple implicitly prefers. Extract the necessary resources from the environment, process them into usable materials, ship all those materials to a factory, shape and assemble them into a duplicate of the broken object, ship the duplicate to the person who needs it, swap them out, and finally ship the broken one to be laboriously recycled or dumped into a landfill. As we continue to accelerate headlong into a worsening ecological catastrophe, I will leave it to you to fill in the blanks as to why this approach leaves something to be desired. The other option is repair. But repair is messy, idiosyncratic, unpredictable. Every failure of a device, even if it's a common failure, is unique in its details and expression. Many tablets will suffer a broken screen, but no two shattered screens are exactly alike. And there's a degree of craftsmanship necessary to respond to the specific challenges posed by this or that particular sort of screen breakage. Unlike assembly lines, repair is not conducive to automation or broke procedure. It requires a sort of artistry, problem solving, and expertise in the workings of the technology, with the time necessary to experiment and find the best way to go about restoring it to working order. Fixing stuff is artisanal work, and compared to turning the crank on an assembly line, it is an expensive sort of labor. Also, while design may be 99% invisible, we generally prefer repair to be totally invisible. We describe the most masterful restoration work as making a previously broken object like it's brand new, that is to say, like the repair never happened. This is the only way Apple will allow its devices to be fixed. You'll never get your MacBook back from the genius part with a piece of gaffer's tape holding the bezel on, even if that's all you really need. While designers can hold up any of a thousand manufactured doodads and say, this is what my efforts have produced, the most skillful mending and maintenance work vanishes into the background, only drawing our attention when it's done poorly or not at all. So there's this tension between the designer's aspiration for control and the infinite idiosyncrasy of failure, between highly visible and easily automated design, and a highly invisible artisanal repair. In this 2016 paper, Values in Repair, a group of ethnographers at Cornell and the University of Washington, Seattle, highlight yet another way that Apple's obsession with design might bring it into conflict with homebrew types. Where the value of a technology comes from. As much as we'd like to imagine technology as being ideologically inert, design doesn't just dictate how an object looks and behaves. It demonstrates, as Johnny Ive puts it, the designer's value system, what they care about. For fully functional products working as their designer intended, a set of values is imposed on the user and the world around them. Like, say the designer of a video game controller thinks that recording and sharing your gaming exploits is important, a thing that any reasonable gamer should want to do. So they build the controller with a share button that makes it trivial to take screencaps and videos of your game. The ease of that behavior is now an essential part of what it means to use the controller, as much as its shape or weight. Even if the user doesn't really care about taking screenshots, or explicitly doesn't want to, every time they accidentally take one by jostling the controller the wrong way, you can see the designer's values manifesting, struggling to find purchase. Are you sure you don't want to share this? Are you sure? Are you sure? There's a fair amount of discourse about ideas like ecological design, design for accessibility, human-centered design, and so on. The gist being that if designers look for ways to express certain values in the objects they help create, the world will be better for it. It's true that designers play a significant part in deciding what meaning their devices will ultimately bring to the world, but the paper's author suggests that by obsessing over that initial moment of creation, we're missing a big part of the picture. Repair can be another way for people to create meaning for technology, independent of the designer's intent. Deciding for themselves what values ought to be instantiated in a particular object's form and function by restoring it to working order, whatever that means for them. Say I drop my controller and the share button breaks on impact. Now I can't even play games with the thing because it keeps taking screenshots and videos at random. I call a friend who's handy with a soldering iron, and we spend a Saturday afternoon taking the thing apart and figuring out what's wrong with it. She shows me how the switch under the button has been damaged and tells me that she can order a new one, solder it back in place, and fit everything back together good as new. But honestly, I don't care about that feature at all, and I ask her to show me how to just take the broken one off. Now that controller is special in a way that it wouldn't be if I had just thrown it out or returned it under warranty. The share button doesn't do anything the way I like it, and every time I pick it up or fiddle with the inert button, I think of how fun it was to see the insides of the thing, how I've learned the right way to remove soldered components, and how my friend helped me out. These aren't values that could be designed into the controller by anyone at Microsoft. They might facilitate my journey by making the thing easy to take apart in service, but even then, I have to decide how to restore its functionality for me, and that decision may change or subvert the values of the designer. Apple's approach to design is meticulous. There's no doubt about that. They pay a whole lot of very skilled people a lot of money to think carefully about how to express Apple's philosophy in every facet of everything they create. Unfortunately, that philosophy, no matter how robustly implemented, can never fully encompass the variety of problems their users will ultimately face, and their obsessive control over how everything with an Apple logo should operate is corrosive to the maintenance of those devices and their users' potential to create meaning by maintaining them. It's not entirely their fault. We have a clear preference for the artifacts we use every day to look new, not well-worn or lovingly repaired. We tend to practice making much more than fixing. I'm certainly guilty of compelling friends to stop wasting their time trying to restore old technology to working order instead of just buying something new. Even though I've experienced how trying to repair something can be an empowering, enriching, educational, and enjoyable exercise in craftsmanship, Apple's policy towards repair plays to one of those impulses, not the other. Considering that Wozniak himself has become a right to repair activist, you can guess which side of it he comes down on. Do you think repair and maintenance will become more valued as we face increasingly dire consequences of overconsumption and climate change? Do you think that the best designs are the ones that empower their users to create their own meaning, regardless of the desires of the designer? Have you looked into starting or joining a local repair cafe? Please, leave a comment below and let me know what you think. Thank you very much for watching. Don't forget to blah, blah, subscribe, blah, share, and don't stop thunking.


After a sweep in their final try match at home of the season, Stevenson defeats Lebanon Valley and stocked him by 3-0. Here with head coach Dave Trumbo. And Dave, after a last night, we'll talk quickly about last night with the match against Johns Hopkins, went five sets to get the ninth-ranked team in the country.  Well, we talked about the difference between a good team and an excellent team. Excellent teams are going to lose matches. It's how you're going to rebound after that. Are we going to feel sorry? Well, we went five last night. We got home late. Now we've got to play two matches. Are we going to really be excited to play? And I was a little concerned, but I was very proud of the way they came out and just set the tone in both sets of both of those matches. Hopkins are really super team. And that's how we get better. And your warts get exposed. Now we've got some stuff to work on as we're going down, closing towards the end of the season. And today, there were times we were unstoppable. In that first set against Stockton, we hit 542 and sided out 10 out of 10 times. We just were on fire when we could have just said, oh, I'm a little bit tired. But no, we didn't do that. And these were two quality teams. The Lebanon Valley team, that's obviously you've known in the past now. They're on the other side of the conference in the McFreedom and a Stockton team that's made the NCAA tournament. So these are two good quality teams. And you talked about the Stockton match, where you hit well in the first set. Go back to the Lebanon Valley match. What did you guys do well against the Flying Dutchman? We did just about everything well. Every once in a while, we have a little glitch in the passing. And then we make a couple errors. But first, we dominated the middle. Darien was 9 out of 10 and didn't make an error. So she hit 900. And then our setters were out to go out to the pins. Julia Vigliata had hit over 400 in both matches. So that's huge for her. She had a really rough game against Hopkins. She rebounded and had a really nice Saturday. And it was great to see for her. And now jump back into Commonwealth play. You got Widener on Tuesday. What can we expect out of the pride? It's never easy going up 95 and playing Widener. With the traffic and everything, we're always just happy to get out of there, hopefully, with a W. Widener's been up and down. So they've lost to some teams. We're getting a lot of eyebrows raised. But then they've beaten some really pretty good teams. So not sure what to expect. But I've already watched so much tape this week with four games and four days. So I've got to watch Widener. All right. Good luck, coach. Thanks, James. All right. So the Mustangs on Tuesday will be at Widener with back home on Thursday as they host St. Mary's. As always, you can find all the action on GoMustangsSports.com. Thank you for watching and Go Stangs.


I now call on the observer for the International Institute for Democracy and Electoral Assistance. Madam President, Excellencies, I would like to thank you for convening this important meeting. As an intergovernmental organisation that brings together 34 member states dedicated to strengthening democracy, International IDEA strongly supports parliamentary development and cooperation as a key component of this endeavour, affirming the importance of legislatures in advancing peace and security, sustainable development and human rights. International IDEA is committed to peer-to-peer collaborative experience sharing through global and cross-regional dialogues as well as capacity development initiatives. The effectiveness of parliamentary processes and institutions in terms of representation, oversight, lawmaking, debating and budgetary processes is central to the assessment of the quality of democracy, as is reflected in our global state of democracy reports. Since 2019, IDEA has implemented InterParis, the European Union's flagship programme for parliamentary strengthening, which to date facilitates 15 partnerships between EU member state parliaments and partner parliaments around the world, supporting the partner's development priorities. This includes the Sustainable Development Goals, as the Agenda 2030 foresees the unessential role of national parliaments for the effective implementation of these commitments. The Interparliamentary Union is a valued partner of the InterParis programme in which IDEA and the IPU work closely together in the implementation of common priorities. These include parliamentary innovation through digital technology and the development of indicators for democratic parliaments, enabling parliaments themselves to assess and enhance their fundamental role as quintessential institutions for democratic governance. This approach to parliamentary strengthening also demonstrates the value of a coordinated approach in which the capacities and commitments of EU member state parliaments are leveraged to support parliamentary strengthening globally. Such a collaborative approach provides an excellent model for addressing key policy areas relevant to the action of the UN, such as gender equality and climate change. IDEA is also involved in supporting parliaments through its regional and country offices around the world. At times, we face setbacks of democratic transitions, and parliaments and elected MPs are often among the first targets of anti-democratic reversals. In Myanmar, for instance, a parliament was democratically elected in 2020 but was prevented from convening by a military coup. Dozens of elected MPs have been persecuted and many were forced to flee or hide. The parliament has continued to function under extraordinarily difficult circumstances. The IPU and many parliaments around the world have played a critical role in supporting Myanmar's legitimate elected representatives. This highlights the continued importance of providing protection and assistance to parliaments and MPs on the threat, and we are grateful for the IPU's leading and principled role in this regard. International IDEA has been and will remain an active participant in this collective effort. Madam President, IDEA will continue to partner with the IPU in support of the advancement of UN agendas. We will focus on contributions to parliamentary development, political participation and representation, electoral processes, gender equality and inclusion, as well as constitution building. IDEA values its partnership with the IPU based on shared commitments to fostering the values of democracy in multilateral fora like the UN. We will therefore further enhance our joint advocacy work and regular consultations on the democratic governance dimensions in the agenda 2030, and in particular transparent, effective and accountable institutions. I thank you, Madam President. I thank the observer for International Institute for Democracy and Electoral Assistance.


Welcome. My name is Will Cusey and I'm the CPSC Small Business Ombudsman. Thank you for joining today's webinar on Art Materials at Import. I am joined today by my fellow CPSC colleagues, Stefan Lee and Jamie Strickland. Stefan will start off the webinar with an overview of CPSC's requirements for art materials. Jamie will present the second half of the session on various importing processes and procedures. With some helpful tips along the way. Now there's a few items I want to go over before Stefan gets started. Number one, there are three handouts available. The slide deck itself as well as a couple of helpful importing related overviews. And regarding questions and answers, we want to get questions from you. That's part of why we're here today to help engage with you. Please submit your questions through the system portal during and throughout the webinar. Please do not wait. Collect and sort them as we're going along and then be able to ask them to Jamie and Stefan at the end of their presentation. Don't wait otherwise we might run out of time to answer your question. Lastly, in the days following the webinar, an email will go out to all the registrants with the final slides and a recording of the presentation. Thank you again for joining us today. Stefan, please take it away. Thanks Will. So my name is Stefan Lee. I am also part of the small business ombudsman team. And my presentation today is going to be going over the general requirements of the labeling of hazardous art materials act or llama. Here's the brief agenda. We're going to do a quick background review go over the actual requirements. Have some examples of what is an isn't art material and then talk about any potential other requirements that apply for children's products and general use products. So, as I mentioned, we're going to be today we're going to be going over the labeling of hazardous materials act. These requirements are codified at 16 CFR section 1500 point 14 b eight. You can look this up at ecfr dot gov. And we also do have a business guidance page on art materials at CPSC dot gov slash art materials that's plural with an s. All right, so the basic llama requirements. There's really two of two of the big requirements that we're going to be talking about today. The first one is the toxicology review so art all art materials subject to the llama must be reviewed by review for chronic toxicity by a toxicologist per the regulations. This review must be done at least every five years and obviously anytime there's a change in the formulation of the actual art material. In addition, all review criteria must be submitted to CPSC's division of regulatory enforcement, you can find the requirement for that citation there as well. We're talking about the actual criteria and not the not the not the report or the actual talks review just the criteria that the toxicologist use for the review. If you can email this review to regulated cmt at CPSC gov. It must include a list of all art materials that require chronic hazard labeling. And then upon request submission of the actual product formula that will be done on a case by case basis. It is it is not a mandatory submission per the regulations. The conformance statement is the next requirement that we're going to be going over. This is the second kind of big requirement under llama. After a toxicologist performs the chronic hazard review, the product must bear a conformance statement. Here's three examples. You can use any one of those three, but they have to be one of those don't use any kind of practical equivalent. Just, you know, use use one of those three that are listed there. This conformance statement can be on various places. It can be on the product, the package poster or display at point of sale separate explanatory literature available on requirements at the point of purchase. And then in response to a formal request for bid or proposal, and all sounds very lengthy, but the, the gist of it is basically have it on the product or its packaging. You know, that way it'll be, it'll be simple to kind of say that you are compliant with this requirement. It's important to note that this conformance statement is required, regardless of whether the art material is going to require any kind of chronic hazard labeling. So whether or not you have labeling already on the product. This statement must be somewhere on the product, the packaging or this other, or these other places. And then we get to the actual chronic hazard. So let's say you go. The toxicologist determines that there is a chronic hazard. Then it must be labeled according to the Federal Hazardous Substances Act, chronic hazards are considered a hazardous substance. And therefore they need to be properly labeled. We do have examples of chronic hazard statements and precautionary statements under the, the codification of law more requirements. These are just examples. They don't necessarily strictly have to be followed, but we do recommend that these are the statements to go by. Children's products that contain a hazardous substance. So any, basically any children's art material that poses a chronic hazard would be considered a banned hazardous substance under 16 CFR section 1500.3 B 15 one a. There are exemptions to the banned hazardous substance classification, but those are very specific. And you can find those under the FHSA requirements. Lama labeling does differ from FHSA labeling kind of on a very, very specific case. So first things is that the Lama requirements state you have to use warning. You can't use either caution or warning. You must use the signal word warning if there is an acute hazard. So stuff that falls outside of the Lama labeling requirements. Lama regulations do state that you would defer to the acute hazard or any other kind of FHSA labeling. Also the Lama labeling requirements state that you must display the name US address and US phone number of the producer or repackager. Again, that requirement is codified there at 16 CFR 1500 point 14 B 8 to D FHSA does not specify a US address or or phone number at all. But again, this is a Lama labeling requirement for chronic hazards. And then the last difference is that Lama labeling states you must provide an information source in case of exposure so that can be a 24 hour toll free US phone number. The statement contact a physician for more health information or call your local poison control center for more health information. Obviously we do recommend that you utilize some kind of 24 hour service or refer to a 24 hour service. So that, you know, any, any consumer, no matter when they're going to be potentially exposed that they can get in touch with someone. So here's our first question. So do Lama requirements need to be cited on a certificate of compliance. So that's going to be either a children's product certificate or a general certificate of conformity. I'm going to be launching a poll. So this is interactive. Feel free to answer. And we'll go over the answer afterwards. And I'll give it a few more seconds for everyone to participate. All right. And here are the results. All right. So 69% of you said yes, and 31% said no. And so the answer. No, compliance to Lama is not based on a reasonable testing program. Therefore, certification to Lama per section 14 of DC PSA does not apply. Basically means that labeling requirements under Lama, or even the talks review under Lama. It's not a testing program and therefore it's there's no certificate requirement. Further cautionary labeling under FHSA, which is pretty similar to the Lama labeling requirements is also not based on a reasonable testing program. Therefore, cautionary labeling requirements under FHSA also do not need a certificate. Right. Here's the next question. Does the conformance statement required under Lama have a type size requirement? Again, this is interactive. We'll leave it open for about 30 seconds or so. All right. And 47% of you said yes, 53% of you said no. And the answer is no. The conformance statement is not part of cautionary labeling per the Federal Hazard Substances Act. Therefore, it's not subject to any type size or placement, prominence, conspicuousness requirements that are listed under 16 CFR section 1500.121. What this basically means is that the conformance statement can really be anywhere. It can be separate from the FHSA requirements. It can be placed vertically somewhere. It can be relatively small or large. There's no actual labeling requirements for how this label needs to be on the product. It just needs to be there. All right. So now we're going to go over what is art material. So the Lama defines art material or art material product as any raw or processed material or manufactured product marketed or represented by the producer or repackager as intended for and suitable for users as defined herein. One of the users here is then further defined under Lama as artists or crafts people of any age who create or recreate an eliminated number largely by hand works which may or may not have practical use, but in which aesthetic considerations are paramount. Now that's a mouthful. So what's the takeaway from this? Well, basically art material is any material that consumers use to create art. That's what it basically boils down to. Examples of common art materials include modeling clay, chalk, colored pencils, crayons, paints and painting kits, watercolor discs, certain types of glues such as craft glues and markers. Obviously, this is not an extensive list or rather it is an extensive list. It's not limited to these products. Basically anything that you could foreseeably use to create art and intended to create art would be considered art material. So it may be better to kind of discuss the differences between what is art material and what is not considered art material. So one clear distinction in Lama is general use products not intended to create art. So these would be common wood pencils and single colored pens markers chalk things of that nature. So in this in this example here on the left you have your common wood pencil. And on the right you have basically shading pencils intended for sketching or other forms of art. So the pencil on the left would not be considered art material. The set of pencils on the right would be considered art material. On top of the determination or sorry on top of the definition of art material rather the Commission has put out a determination on art materials. That determination basically says that certain pieces of art or rather certain certain art materials that the Commission will not enforce the requirements of Lama. So one of those are going to be tools implements furniture using the creation of art. So these are going to be brushes, chisels, he's those frames, things of that nature. These are all, you know, components used to create art, but we're not going to require any kind of chronic hazard review or anything like that. The requirements of Lama will not be enforced against for these types of products. That determination can be found on a fortress that listed here, but it is found at 16 CFR section 1500 point 14 be eight for a. The determination further goes on to say that surface materials upon which art material is applied also will not be enforced against so that's going to be things like coloring with pages canvases things of that nature. And also miscellaneous materials such as paper cloth plastics film yarn threads rubber sand would stone tile is really in metal. Here's a key takeaway from this however enforcement may occur if exposure to a certain type of chemical is possible during foreseeable use so for example if your canvas is primed with some kind of chemical. And the consumer could be exposed to that chemical during you know it's normal use, then chronic hazard review would be required, and that canvas would be subject to the requirements of Lama, including labeling. So here's another art material comparison. So on the left you hear here you have basic children's kind of play dough almost basically and on the right you have various colors of modeling clay. So both of these are pretty much plasticine based they're not actual play. But the left product would not be considered art material, whereas the right one would. Obviously there's a lot of factors to be considered here. But the key difference here is going to be the permanency and the intent to create art.  So that would be the key difference and considerations here. All right, so here's another question. Slime kits often come with glue is glue in a slime kid subject to the requirements of Lama. All right and let's take a look here. All right, 71% said yes 29% said no. And here's the answer. No, the reason being is that glue use in slime kids is not intended to create art. Typically slime would not be considered be considered art. Therefore glue specifically for the use in slime kids is not subject to the requirements of Lama. In general, however, polyvinyl acetate glue, which is also pva craft or white glue sold by itself is commonly recognized as intended for art. Therefore, if such glue would be sold separately by itself, it would probably need to meet the Lama requirements. This is kind of reference in 16 CFR section 1500 point 14 be eight for be that is also the part of the reference. Or that section citation is also part of the commission determination. Okay, and then the additional requirements for children's products. Now, many of you may already be aware that there are additional requirements and safety rules that apply for children's products. Some of them are going to apply to the art material and some of they may not. Here's a list of the general children's products requirements that that most children products are subject to applicability of each of these requirements are going to be on a case by case basis. Toys, on the other hand, have additional set of requirements on top of the requirements for children's products. This is going to be a little less likely, but there are instances where art material could come packaged with a children's toy. In that case, the art material would be considered a children's toy because it is packaged with a children's toy. Now we're on the subject of children's products. Let's go over art materials and children's product certificate for a children's art material. So the first section for a for certificate is going to be identification of the product covered by the certificate. That's pretty simple. Make sure that your product is clearly identified. Use things like model numbers or anything to specifically identify the product so that the certificate and product pretty much have a one to one relationship. The second element is just a simple citation to each CPSC children's product safety rule to which this product is being certified. For this example here where we have a watercolor set with a brush, there's likely only going to be these two requirements. So that's going to be the total lead content requirement under 15 USC section 1278 a as well as paints and similar surface coatings under 16 CFR part 1303. What you may notice here is that there is no citation for art materials. Again, art materials does not require certification or rather the requirements for our materials do not require certification. So there is no citation for our materials here. All right, element three, that's going to be the identification of the importer domestic manufacturer certifying compliance of the product. So that's just going to be, you know, the firm name, their address, maybe a phone number or website address, something like that. The next element is going to be contact information for the individual maintaining records of test results. So here we would definitely like to see some more specific information such as the name of an actual person, as well as more specific contact information so that's going to be things like an extension number, or a specific email address not just info or hello at company dot com something along those lines. This, this firm identified here or rather the person identified here does not need to be from the firm that's identified as the importer or domestic manufacturer, it can really realistically be anyone who's maintaining the actual test results. So that could be the supplier for and manufacturer something along those lines. However, it would be the responsibility of the importer or the domestic manufacturer to facilitate CPSC is obtaining of the supporting information like the test results so the firm would be responsible for requesting that the holder send a copy to CPSC or somehow be the third person in that in that conversation. The next section is going to be the date and place of manufacture the date we allow for month and year. So that's going to be the minimum requirement date ranges are acceptable provided that the product is of the same batch and is manufactured the same way. As far as place of manufacture, we would really like to see at least the city and province state of applicable as well as country, simply having the country alone is probably not going to be specific enough. The date and place of testing is going to be the next section. Again, same as before, we would like to see at least a month and year, and then the place we would like to see the city province state when applicable and country for this specific type of product. There also may be certain determinations now determinations are something that the commission basically determined that certain materials do not contain lead in excess of the mandatory requirement 100 parts per million. What that basically means is that listed materials under the under the determinations do not require third party testing for total lead content provided that they've been untreated or unadulterated. And this only applies to the specific material, not the product as a whole. So in this example here, you're likely going to have a determination for the wood in the paintbrush. Obviously, the wood has been painted here, but the base would, as long as it's been untreated or unadulterated does not require testing, provided that the black paint on the handle would be tested separately. Also, the depending on what type of brush it is maybe it's made out of actual fur animal products also have a determination. So that that fur component rather the bristles component does not require testing for for lead content. There are other determinations for the heavy metals under the toy standard as well as the phthalate requirements in various sections of the CFR. And then the last section of a certificate is going to be identification of any third party CPSC accepted laboratory. So here's just an example of an actual laboratory. If you are a small batch manufacturer, your registration number would go here. If you are relying on the small batch manufacturer relief. This section, although it does say that you need to identify a laboratory, you can put an a here if there was no third party testing conducted. That is rare, but it does. There are instances where children's products may not require testing at all. Or maybe you did all first party testing because you were registered and qualifying small batch manufacturer. You you're more than welcome to put an a here you don't need to identify any kind of you're basically you as the third party testing because you're not the third party laboratory. The last last portion here is going to be for general art materials and gcc's now we discussed previously that art materials or rather the requirements of llama do not require certification. So as far as the art materials requirements go there's going to be no certificate required. Having said that there really isn't going to be any other requirements that apply for something that's going to be an art material. One of you may refer to 16 CFR 1303 for the lead paint and similar coatings or rather lead and paint and similar coatings. There is an exception for artists paints and related materials. So, you know, if it's considered an artist paints that it does not or rather it's exempt from the scope of the band it doesn't even fall under that 16 CFR 1303. So realistically, there's not going to be any kind of art material that, you know, would meet would need to meet another certification requirement. If there are, you know, if there's a case that you guys are thinking about, you know, follow the same procedures as a certificate. Or, and just make sure that you have all of the necessary elements. All right, and now I'm going to turn it over to Jamie here, who is going to be talking about the import surveillance side of things. Jamie take it away. Good morning, my neighbors here on the West Coast. And good afternoon as opposed to everyone else. My name is Jamie Strickland. I am an investigator within the CPSC office of import surveillance. I am located in Seattle, Washington. I cover all ports along Western Washington and Pembina North Dakota. I am one of few who has all modes of transportation. So hopefully I can answer your questions at the end. In this section, we are going to talk about import surveillance activities, starting with port operations, we're going to talk about targeting, why we target some of your stuff, how we communicate with you guys and how we do screening and what happens after that. I'm going to go into some of our statistics for last fiscal year. And that's always interesting. Everyone always loves that. So I always make sure to get that information. Then I have some exciting information for you regarding some upcoming initiatives from our office. And that includes e-filing. So, let's get started. Okay, it looks like I'm having a little computer issue here as well. Port operations at a glance. I have a nice little chart here for you. And I'm going to pause here so that you can take a look at this and kind of see how your cargo that you import flows. Now, this is going to be similar for any mode of transportation, ocean, air or land border. Again, I'm going to pause right here and take a look. Okay, let's go. Typically, that screen is repeated throughout here because I want you to keep in mind that flow chart because we're going to walk through the flow on both sides. So, how are your or how are exams targeted when we are at the ports? Well, there are three ways. This is typically done either through local targeting, through which we use our risk assessment methodology or our RAM system. That system speaks directly to CBP's ACE system. And again, I apologize. I'm not sure the audience of this presentation, if you're an importer or if you're a broker, you may be fairly comfortable with a lot of these acronyms. The government is full of them. So, if I toss out an acronym that you are not familiar with, hopefully the answer is on the screen, but if not, please toss it in that chat box with a question or with a question mark. Will, we'll get back to you or I will answer it at the end. Again, so three types of targeting. We have our local targeting, which is targeting that local investigators within the port do. We see the cargo coming in. They're going to be the most comfortable with that. They're going to be able to take a look and say, we've seen this guy before. Their products are typically compliant. We can let this shipment go. We'll do a compliance check next time. Or, hey, last time they had some problems. Let's make sure that they've cleaned this up. Next, we have our national operations and programming. This is done in the DMV area, DC, Maryland, etc. with CPP. We have a person in the commercial targeting and analysis center or CTAC, commonly known as NTC as well, where they will target for all ports nationwide based on known criteria. And then the last type of targeting is going to be referrals. U.S. Customs and Border Protection is our largest asset. They see this cargo day in, day out, and we work very closely with them. So they do see the cargo. They'll give us a call. We'll come out and we will take a look as well. Next, we have two-way messaging. Now, this is new. I believe the initiation date was September, I want to say 2021, but I believe it was 2020. What this is is the way that we can communicate directly with brokers, sometimes importers depending on how you are set up, and CBP. This cuts down sending emails, hoping someone receives that email waiting for a response, etc. This will push out a message using CBP's existing communication pathways. So how does this work? You will receive an under review message after your broker has filed an entry. That message is shown in their user interface. If no exam is required, that under review message will fall away, and you will receive a may proceed message in its place. After a may proceed message has been received from all PDAs, you will receive that one USG message showing an ultimate release. However, if we decided to examine your product or a further review is necessary, then you will receive that intensive exam request, or you will get a conditional release, which is a hold-in-tact notice. And to expand on that, here are the timetables for when that under review message appears and when it falls away. I will pause here and allow you to take a look because there are a couple ifs, this, then that kind of situations. Again, it relies heavily on your mode of transport. But if entry is filed, three or more businesses before the estimated date of arrival, air and truck, that under review is going to fall away within eight business hours. Ocean is going to be 16 business hours, which turns into about two business days. So how do we screen your products? Well, if you've ever taken a look within the Code of Federal Regulations, you will see that a lot of these different acts have testing protocols. And based on those testing protocols, that's basically what we do in the field.  We will also use different types of equipment which we'll get into. So did you know some of these products are regulated under multiple acts? Shocking, I know. So that is to say, one of the products that Stefan alluded to was something that could be a children's toy that might also be regulated as an art material. A perfect example of this would be a paint by numbers pullback car. I actually just seen one of these yesterday. That pullback car was a small plastic vehicle, and it also contained one paintbrush, and a five-pot thing of paints. That is required to meet the requirements of Lama, the Federal Hazardous Substances Act, the toy standard, but then the CPSA, and then also the requirements of the Consumer Product Safety Inputment Act. Okay, so picking up with screening, this is the list of our equipment. In addition to this equipment list, we have our XRF, which if we were in person, we'd be playing with this and having so much fun. But unfortunately, this is what we have. We have a photograph of one of our investigators using this device. We also have templates that we have developed based upon the testing protocols listed within the codes of federal regulations. If you've been to any of our live events, you've seen our small parts cylinders, et cetera. These things are out there in the trade. I've been to many establishments, and I've seen small ball templates sitting on desks and things like that. In addition, we are holding your products. We are bending and flexing and pulling and dropping, treating that product just as typically child. We'd look at a lot of child's products here on the West Coast at Importer Valence, but we're going to treat that product like a child is going to treat it. And for those of you who have children, you know what that entails. If it is an art material, this is where we are going to be looking for that conformity statement on your product or on your paperwork. And if we don't see it, that's where we're going to come back and ask you for additional information. So what happens if your products do not appear to meet requirements? We're going to collect a sample. I'm going to take a sample of your products, and depending on the act that it does not appear to meet, depending on what requirement I think it needs further review for, I am going to take samples and I'm going to send that to our laboratory facility. I may send that to our compliance. Well, I'm absolutely going to send that to a compliance officer within the CPSC Office of Compliance and Regulatory Enforcement. With that, before all of that happens though, I'm going to issue some paperwork. I'm going to issue this paperwork typically to your broker as they act as your emissary as an importer of record. That paperwork is going to include a receipt for samples if it is a physical, a physical sample. And if it's a documentary sample, it'll likely only contain CPSC Form 352 if your product is being detained. And a CPSC Form 353 if your product is being conditionally released. Just one note, physical samples are not returned to the shipment. So let's get into this a little bit deeper. What's the difference between a conditional release and a detention? Well, it's where your products are held. If their product is conditionally released, that product is allowed to transit either to the importer of record facility, or to their ultimate consignee's facility. That product is going to remain intact to be held away from other items offered for sale. However, if your product is detained, it is going to remain at the CBP bonded facility. This is typically the centralized examination station where your product was examined until CPSC completes its evaluation or testing. So now with that part, and I know that I've spoken with a lot of importers, probably some of you on the phone. And one thing I'd say about that is that once we collect that sample and we pass it off to the Office of Compliance and Regulatory Enforcement, the investigators are typically back into the field looking at other cargo while you as the importer of record are working directly with that compliance officer to bring that product into compliance if that is possible. However, once all of that is done, these are what you have to look forward to. Typically as the importer of record, you are going to know the outcome of that sample before I do, because you have been working closely with that compliance officer to find out exactly what can be done with the product. So should the product not meet the requirements, the importer of record is issued a notice of violation directly. The notice will detail one of three actions, either to correct the future production or importations. My understanding is that we're not seeing very many of these anymore. I'm not sure why, I just noticed that we don't. Recondition, if it's determined that your product can be brought into compliance and other factors are satisfied, you may be allowed to recondition that product. And then when all else fails, we would move for seizure, or if you are in the Seattle Tacoma area, likely exclusion. So here are some statistics from last fiscal year. As you can see, of the entry lines scored in our risk, risk assessment methodology system, we had nearly 5 million lines last fiscal year. Of those nearly 5 million lines, we examined under 10,000. So that's a, that's an examination rate of less than 1%. Of those, we've collected quite a few samples. And of those samples, we had a violation rate of approximately 86%. And then from those violations, you can see the outcome percentage. Now the average evaluation period is important, because as I said, we will collect that sample, and that product has to remain intact while we complete our evaluation and our testing. Right now that period is running well last fiscal year and actually about right now we are running at approximately 51 days. That means from the date of that notice of sampling and detention or complaint or conditional release to the date you get that notice of violation in that final disposition is approximately 51 days. Now here are the violations for last year. Now this was interesting to me when I received the data because I have been with this agency for seven years, the lead violation has always been led. This is the first time I've ever seen anything overtake. But this is where we are. And again, some entries will have more than one violation type. Again, if we go back to our example of the pullback car that came with paint pots paintbrush in the car, should that car have been found to contain lead and did not have a tracking label or a certification that is three violations for one product. So now I've hit you with all the bad. One thing I did was I pulled all of our investigators nationwide and I asked them, give me some best practices and recommendations that I can pass on during this presentation so that we can help. These importers who feel befuddled by our length and live in mass of regulations, we can at least give them something, a starting point or something. So this is what we came up with. I received about 121 responses total on every single one. Number one was to ensure that the submitted packing list has sufficient details. I cannot tell you how many times I've received a pack or an invoice that just as plastic toys. This will delay the exam 100% of the time, because if I request a CPC, and I get it for one item, but now I get out there and find that plastic toys are actually three items. Now I have to come back to you and I may even have to detain this product while we try and work out the rest. So make sure that your submitted packing list invoice or whatever has sufficient detail to know exactly what is in the container in the shipment. Another is to include your markings, labels or FBA numbers for fulfilled by Amazon shipments. If your box does not list what the product is, but you have cartons one, two, three, etc. Let me know what's in cartons one through whatever that will help us out immensely. Provide a copy of your certificate of certificate of compliance with your entry documents or upload it separately in DIS with the CPS tack. This is important for two reasons. One, I've actually seen this certificate of compliance placed in each shipping carton, although that is super helpful. I would call that overkill. We don't need to do all of that. I can get to your broker when you're giving them the invoice. Hey, also here's my CPC.  I can see that you've likely had this product tested. I can see that I have not identified any known hazards. Tracking label looks great. I can let this product go with confidence. Okay, this one is important because it also lists the CPS tag. Although brokers can upload documents into DIS, we can only see them within CPSC if they have the CPS tag that also includes entry documents. And then if you include a point of contact with the importer record, it saves me from having to ask. As I said that notice of violation goes directly to the importer record. So if you're out that point of contact, it's going to delay the final disposition. This really doesn't like me clicking today. Here we go. All right. E-filing initiative. So what is that? I'm sure you guys have heard me talk about it. If you're in the Seattle area, you heard me mention it at our last trade meeting. E-filing initiative is going to enable importers of records and brokers by extension to electronically file certain data elements from their certificates of compliance. That's your children's product certificate or your general certificate of conformity via the CBP partner government agency message set. So that's within eighths. The plan was approved December 2020.  So now we're moving forward with that. So this is going to enhance the risk assessment methodology system that I mentioned previously. It's going to enhance the targeting and our enforcement ability simply because we were only asking for certificate data once a product had been identified for exam. With that, we can't use that certificate data in risk assessment for targeting. So the idea is that incorporating this information will allow us to better target. And this can lower your examination rate, especially for those importers who constantly get constant, constant compliant exams. If we can see that, and we can see that you're doing your due diligence with your certificates of compliance, we likely won't be looking at you very often. And then one more important note, we're currently in the development stage of the beta pilot. We're looking for this to start in the fall of 2023. So we are soliciting participants in a workshop that's going to be hosted on October 13, 2022. And we will discuss the purpose and mechanics of e-filing certificate data and other associated topics that goes along with it. The workshop's going to be held in hybrid format. So if anyone is in the Bethesda, Maryland area, you can attend in person in the commissioners main hearing room located on the fourth floor, Bethesda Towers, or you can join virtually. Registration is still open for those who wish to participate. And so for more information or to participate, you can reach out to our e-filing program specialist, Arthur Lacey at the e-filing pilot at cpsc.gov. You can visit the e-filing website, cpsc.gov slash e-filing. Or you can take a look at our public calendar. There is a link to the federal register notice as well as a link to participate on the CPSC public calendar. And that's all I have. My contact information is here as well as the contact information for my boss's boss and my boss's boss's boss. So if you have any questions that I can't seem to help you with, go ahead and feel free to climb up the ladder. But absolutely, if you have any questions regarding importations of art materials or any other material that is regulated by CPSC, please feel free to reach out to me via email. Thank you, Jamie. Thank you, Stefan, for a very informative presentation. We have about 10 minutes left for questions. I'm going to start back from the beginning and work forward. And hopefully the people that asked these questions are still online to hear them. So the first question is a question over the concept of a band, quote unquote, band hazardous substance. The question is, if the children's product contains a hazardous substance, shouldn't this product be banned? I think there's just a little bit of confusion on what we mean by band hazardous substance and how that works here. So maybe Stefan, if you have an opportunity to weigh in there, that would be helpful. Sure. So the FHSA defines, or rather one of the definitions under the FHSA for band hazardous substance is any article intended for use by children, which is or contains a hazardous substance. So under normal circumstances, let's say a paint kit for a child, if the paint contains some kind of chronic hazard, it's a hazardous substance and therefore now that paint set intended for children is a band hazardous substance. I did mention that there are exceptions, specifically under 16 CFR section 1500.85A4. There is an exemption from classification as a band hazardous substance for educational materials, which does include art materials that are intended for educational purposes. So those would not be considered band hazardous substances. Great. Thank you so much, Stefan, moving right along. If slime and dough are not considered art or art materials, are they then considered toys or maybe just rephrasing a little bit, you know, what a product that is primarily of play value and not an art material be considered a toy? Maybe it's another way to phrase that. So that's a little tricky to answer. Classification of children's toys does take multiple different factors. Typically things like slime kits may or may not be considered a toy, depending on the other stuff that it's packaged with. I believe that if it's just strictly a slime kit, it may not be considered a toy, but those are evaluated on a case by case basis. There are multiple factors like, you know, how it's advertised, the intent, the other components of the product that it comes with. Those all need to be considered when classifying as a toy or a regular product. Excellent. Thank you very much. Okay, moving along. This person says they have a question about the modeling clay for young children, such as two year two year old children. Can this type of modeling clay be considered an art material? And what if the modeling clay is for children six years older or older? Are there any differences between these two different types of modeling clay for these two different audiences? So at its core, there's not really a difference what the age determination is going to be. If it's going to be for 12 years of age and younger, that's going to be a children's product. And certainly modeling clay could be intended for children as young as two. It really just kind of depends on, you know, whether it's obviously safe and doesn't contain any kind of hazardous substance. Just because it's meant for a young child does not automatically mean it can't be art material. So it modeling clay for two plus, for example, could certainly be considered art material and would be required to meet the requirements of llama. Great. Thank you so much. And I want to just clarify too, as well, if you look at the small parts regulation, 1501.3 G modeling clay and similar products are exempt from small parts testing. So, you know, in other scenarios, a product for children, two years old and a product for children, six year old or more, there could be some differences on physical and mechanical testing. So for modeling clay, that's exempt here. So there wouldn't be that consideration. And the same thing is true for finger print, finger paints, watercolors, and other paint sets, as well as writing materials such as crayons, chalk pencils, and pens. I think that's important to just cover that there's some exemptions from small parts testing for products for children under three years that ordinarily might have small parts testing for the art material space. Another question from the same person for craft stickers with maybe a thin layer of glue or other adhesive is llama applicable in that kind of situation. Can this type of craft sticker get exempted from llama since people have very limited time to touch the glue or adhesive? Are there any guidelines from CPSC regarding generally what types of stickers would be covered or could be covered by the llama requirements? So there is no specific exemption for stickers under the requirements under llama, but our business guidance page on art materials does address this specific question. It's under the question, how does CPSC staff enforce these requirements with regards to stickers. Basically, what the answer is, is that stickers that where it's self adhesive, you don't need to do anything to the actual adhesive would not, no, CPSC staff would generally refrain from enforcement. There's like the question pointed out there's going to be very little risk or potential for exposure and therefore little risk or potential to cause chronic health effects. That being said, things like double sided stickers or stickers where you need to lick or wet the adhesive in order to actually activate it. Obviously those have a much greater probability of exposure. So those types of stickers would probably need to have some kind of talks review. Great. Thank you so much, Stefan. Moving along to Jamie, we have some import questions now. That's a really quick question. Someone when you mentioned the acronym issue, someone asked, what does DIS mean? Sure. DIS is the document imaging system within CBP's ACE system. So I answered your acronym question with more acronyms, but it is a CBP US custom system for transferring documents. Great. Thanks for covering that. One question here as well. You mentioned the idea of reconditioning and conditional release for art materials. What could be a potential situation that might arise? And it's okay if you don't have it, but this person's curious whether there, what kinds of situations would that trigger where there might be a conditional release situation. So art materials, I, again, working at import surveillance, my position is to surveil imports. So I don't make those final determinations, but I do see the final dispositions when they come down. I have been seeing what looks like stronger enforcement on art materials. I have not had any situation where an actual material was reconditioned because the violation was based within the llama requirements. Those have been seized. Okay, that's, that's very helpful. Thanks for covering that. Do you have any other examples of how kind of llama requirements are screened and maybe just other examples of the types of art materials you're seeing? Or maybe some of the problems you're seeing just in a general way without being too specific. You know, what are you seeing? You know, the word on the ground. Sure. So we see a lot of, I'm trying to think of if I've seen any creative art materials lately, and I have it. Typically we see a lot of kits for children. We see a lot of markers, color pencils, paints, finger paints, etc. One that I did see recently was a set of bath crayons. And the problem was that the conformance statement and the tracking label were on an adhesive label. Now that is kind of, no pun intended, kind of a sticky situation for us because technically the regulations do state that the tracking information needs to be indelible. However, if this is a water product, something on a paper adhesive label likely would not last for the lifetime of the product. And so, you know, we've, I've been seeing quite a few of those lately, actually, water art materials. And with that you have a whole host of other issues as far as the labels and making sure that, again, your tracking information is indeligible because that's usually where you're going to get tripped up. And then also making sure that although you purchase a product that already has the conformity statement on it to distribute, make sure you actually receive and review the toxicology report because I recently had a situation where they had the conformance statement. They had a toxicology report. However, they have specific labeling that was required that was not on the product. So make sure you get the make sure you actually request the toxicology review if you are not actively getting it yourself. Make sure you read it and make sure that your product actually conforms with what it says that it needs to conform with. I, that was actually the first time I've seen that like I said I've been with this agency for approximately seven years. I had never seen an actual art material that had the conformance statement that actually had the toxicology review. Typically, that's usually where we mess up, but in this situation, they just didn't have the required labeling. That's very helpful, Jamie. Thank you for sharing those viewpoints and thank you again to Stefan as well. That was the last question that we had today. I just want to reiterate that we are here for you part of, you know, why we do these is not just about going over this content for a specific set of issues. It's to let you know that we are here and we are available for questions anytime anyone has a question. You can reach us at sbo at cpsc.gov. Give us a call. Jamie already said she's available for questions if you're in the Seattle area. So we really encourage you to do that. Please reach out. That's what we're here for. Thank you again. And we'll see you next time. Bye-bye.