CSPC Draft Staff Briefing Outlines 11 Ideas to Reduce Testing Costs

The CPSC has released a Staff Briefing that will be discussed and voted on by the Commission on October 3, 2012 that outlines 11 areas the will help reduce the cost of testing and compliance for children’s product manufacturers and importers of record.  The aim at finding burden reducers during fiscal 2013, which begins October 1 and are;

  • Education of companies on testing rules
  • Expand the determination of what should be tested by;
    • Creating a list of tests in international standards that companies could use to show conformity with corresponding CPSC product safety rules
    • Using the same process used now to determine if certain materials need not be tested for lead to be applied to the eight heavy metals now tested for under ASTM F963
    • Expand the current list of materials exempt from testing for phthalates
    • Allow Fourier transform infrared spectroscopy (FTIR) to show phthalate compliance
    • Allow for production volume exemption (under 10,000 units produced) for periodic testing which would require testing compliance every 3 years instead of very year
    • Expand the bodies responsible for accrediting third-party laboratories beyond ILAC-MRA signatories to increase number of testing labs
    • Allow “de minimis” testing exemptions for lead in paint and phthalates
    • Increasing the materials exempt from lead determination to include those deemed safe for addition to food by the FDA
    • Allow companies that do short production runs and recertify their product with each run, not have to create a periodic testing plan for doing so
    • Create classes of products that are deemed “low risk” of noncompliance and allow companies that produce those products to expand the intervals of compliance testing.
    • Reducing administrative costs of compliance through information technology
    • Seek authority from Congress to certify certain manufacturing processes as satisfying testing requirements due to ongoing reassessments involved.


The full staff briefing (all 117 pages) can be found here