Searchable Consumer Product Safety Incident Database (SaferProducts.gov)

The CPSC just released a report to congress on their plans to create a "Searchable Consumer
Product Safety Incident Database (SaferProducts.gov)".

The spirit of the CPSIA act is "self certification". To date, there has been little evidence of a committed and rigorous enforcement capability. It is now clear that part of the enforcement strategy is consumer whistle blowing and reporting, followed up by CPSC investigation and action.

I think that this announcement is a call to action for companies who have not committed themselves to be profitable and successful under the new business paradign created by the CPSIA act.

Ignore it at your peril!

CPSIA: A Marketing Opportunity?????????

We all realize that the CPSIA act was passed to protect children under 12 from specific health hazards like lead and phthalates. And the cost of compliance is a new and often expensive and additional "cost of goods sold".

Is it only a costly inconvenience for most companies who have always been ethical and concerned about the safety of their products?

Remember back to the days when ISO compliance was critical to a manufacturers ability to sell into larger companies. That was a vary large and expensive commitment as well. In the end, it helped differentiate your organization from your competitors and was a story worth telling!

The CPSIA act is now a reality and an opportunity to differentiate your company, your products and your commitment - see Univenture’s Polypropylene Products Meet CPSIA Material Requirements

Firewalled Testing Laboratories Permitted by CPSIA

I came across an interesting article on the internet this week "Third-party safety tests not required for Mattel". The article suggests that Mattel is getting special treatment somehow. But the CPSIA act supports the concept of fire walled testing as a valid and fully compliant option. The inhouse laboratory capabilities must certified and are as rigorous as any 3rd party lab. This recognition by the CPSC reflects that some companies have the engineering and science competency to test their products. Regardless the penalties and market place impacts are applied to the company not the lab.

CPSIA Webinar - CPSIA Compliance: "A Virtual Manufacturer"

Please attend our first CPSIA webinar. The webinar is at 1 PM EST. Register here.

This session is going to help SMEs understand how to manage the expectations placed by the CPSIA and turn your CPSIA related activities into a competitive advantage while fully complying with the Act.

Webinar Title: CPSIA Compliance: "A Virtual Manufacturer"
Date: Today, the 18th of Aug
Time: 1 PM EST
Registration link: http://bit.ly/p4Y5N

Phthalate Testing - Accountability and Responsibility

The CPSC released a series of commentaries on phthalate testing on August 7, 2009. The releases focussed on testing and are very relevent. What I found most interesting was the closing paragraph in the Statement of Policy: Testing of Component Parts with respect to Section 108 of the CPSIA, August 7, 2009

"D. Who Is Responsible for Deciding Whether to Test for Phthalates?
Manufacturers either know or should know what materials and components go into the products
they make, and if the product or its components contain one of the plasticizers specified in
section 108 of the CPSIA, the manufacturer or importer certifying the product must test the
component or product to ensure that it complies with the CPSIA. Failure to comply with section
108 of the CPSIA is a prohibited act under section 19 of the Consumer Product Safety Act
(CPSA) and can result in civil and criminal penalties. Likewise, failure to have a product subject
to section 108 of the CPSIA tested by an accredited third-party laboratory and have the
appropriate certification for that product is also a prohibited act under section 19 (CPSA)."

It's clear where the buck stops - it's here!

It's not just about GCC's ...............

The visible implications of the CPSIA act are many and often expensive for many organizations: GCC's, labels, use of independent lab testing etc.

But much of the act is based on science, engineering and shop floor manufacturing. For example see
"Interpretative Rule on Inaccessible Component Parts" and "Testing of Component Parts".
To operate profitably and compliantly under CPSIA, organization with need understand the science and engineering implications of their processes. This means upgrading the skills of their staff or engaging consulting expertise as required.

CPSIA 2010 Plan and Budget

For anyone thinking that the CPSC's focus on Children's Product Safety and the impact of the CPSIA Act will eventually go away like a bad poison ivy rash, take a quick look at the CPSC's 2010 budget and plan!

1. Budget grows to $107,000,000 including an increase of 43 FTE's.
2. In 2009, 17 rules were put in force and "60" CPSIA related activities are in progress.
3. 2010:

3rd Party Testing

• Random samply standards will be implemented
• ongoing reviews of 3rd party testing to ensure that CPSC's standards are enforced and more importantly, the 3rd Party Testers do not begin applying their standards and interpretations.

Phthalates

• Interpretative rules on products covered by the phthalates provisions of the CPSIA

and More ........

Conclusion: The impact of the CPSIA is not going away!