Notes from the Recent CPSC Safety Academy 2013

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During the recent CPSC Safety Academy held in Seattle, WA this month, there was a presentation given by Carol Cave, the SafetyAcademy2013Assistant Executive Director (AED) of the Office of Import Surveillance and John Blachere, an International Trade Specialist in the Office of Import Surveillance for the CPSC on how the CPSC reviews shipments at ports.

With the expansion of the tariff codes, the CPSC has the ability to target shipments with either high profile product groups, which may have experienced recalls or manufacturers who may have had problem products in the past.  Based on this system, there were over 2 million shipments that were eligible for examination and out of these only 1,400 (0.070%) were detained with an average detention time of 13.4 days.

The products detained included; Toys (55%), Fireworks (14%), Clothing (9%), Holiday Light Sets (3%), Other Electrical Products (5%) and All Others (14%).  Most of these products entered the United States by Sea (86%) with the other categories being; Rail (2%), Truck (6%) and Air (6%).

Of the 1,400 shipments stopped for examination 77% (1,022) were found to have violations with 61% (622) of those requiring seizure.  These shipments were over the period from October 1, 2011 to September 5, 2013.

Of those violations that required seizure, the number one reason was for lead (34%) followed by a mechanical hazard (15%).  While all of this was interesting, most of this information has been issued throughout the year in CPSC press releases.  What was interesting was that during the QA portion of the presentation a question came up with regard to Children’s Product Certificates.  The question was, how did the CPSC observe company’s complying with the requirement of certificates “accompanying each shipment”?

Carol and John both said that certificates were either physically with the products (in the containers themselves), included with the importation documents submitted by brokers or in a unique URL printed on the invoice, PO or other importation document.

They were then asked if they stopped and seized shipments strictly for not having a certificate for which they responded no.  However,  they did say that beginning in the fiscal year 2014 they will be looking to see if the shipment does have a proper certificate.  This means that even if the shipment has passed the examination for chemical or physical hazard, the shipment can still be help up for a documentation (certificate) violation.

CPSC Safety Academy to be held Sept 18th

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CPSC to hold 2nd Annual Safety Academy 

 logo with the words "Product Safety Through Education" The CPSC Safety Academy brings together CPSC staff and stakeholders, including manufacturers, consumer advocates, academic researchers and others to disseminate and share information on product safety topics. These topics include current regulatory requirements, testing and certification of children’s products, the mandatory toy standard, navigating compliance issues, the fast track recall program and others.

 

 

2013 Safety Academy

The U.S. Consumer Product Safety Commission is pleased to announce its 2013 Safety Academy. This year, the one-day academy will be held on the West coast in Seattle, Wash.

 

The academy will be held from 8 a.m. to 4 p.m. on Sept. 18, 2013, at the Henry M. Jackson Federal Building located at the Seattle Metro Service Center, 915 2nd Avenue, Seattle, Wash. 98174.

 

Agenda

 

CPSC Safety Academy Logistics 

 

Registration is closed; the maximum capacity for attendees has been reached.

 

The Safety Academy offers basic topics in the morning sessions designed for those unfamiliar with the CPSC and the agency’s regulations. Afternoon sessions present more complex topics. Regardless of a person’s level of familiarity with the CPSC, the Safety Academy is an opportunity to ask questions about regulations and procedures, and to meet with specialists and field staff.

 

FOR FURTHER INFORMATION CONTACT:  

Marc Schoem

Acting Director, Office of Education, Global Outreach, and Small Business Ombudsman

4330 East West Highway, Bethesda, MD 20814

Phone:        301-504-7620

E-mail:       business@cpsc.gov

California’s Safer Consumer Product Regulations

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On August 28, 2013, California’s safer consumer product regulations (otherwise known as the “green chemistry rules”) Californias-Green-Chemistry-Initiativewere approved by the Office of Administrative Law and were filed with the Secretary of State; they will take effect on October 1, 2013.

California now has the authority to regulate every ingredient in every product sold in California, with limited exceptions.   At 72 pages, the regulations set out a multi-year, information- and paperwork-intensive process that gets more voluminous and complex with each successive phase of implementation.

Step One [September 2013]

  • An initial list of chemicals (“chemicals of concern”) will be released that will be the basis for regulation and is expected to contain around 230 chemicals.  Any company selling products into California will need to review the list of chemicals against their product’s chemical formulation to determine if their products contain any of these chemicals.
  • If products do contain any of these chemicals, companies will need to begin the process of identifying who within their supply chain will be responsible for compliance requests, toxicity testing and notification under the regulations.
  • These regulations apply to “manufacturers, importers, assemblers, and retailers”

Step Two [Spring 2014]

  • A plan will be published that will identify the products in need of immediate regulation and for the particular product/chemical combination and the “alternatives analysis” to determine if “safer chemicals” could be used.
  • Final selection of priority products is expected to occur no later than October 2014

Step Three [Fall 2014]

  • Once priority products have been identified, companies supplying those products can respond by sending a “Priority Product Notification” indicating that they do not sell a product in California that contains the chemical of concern.
  • A company can send a “Priority Product Notification” indicating that they will remove the product for sale in California (“Product Removal Intent Notification”)
  • A company can send a “Priority Product Notification” indicating that they will remove the chemical of concern from the product (“Chemical Removal Intent Notification”)
  • A company can send a “Priority Product Notification” indicating that they will replace the chemical in the product (“Product-Chemical Replacement Intent Notification”)
  • After the company submits their initial notification they must then submit a second notice indicating that the first action has been completed (“Confirmation Notification”)
  • Within the first 60 days of the “Priority Product Notification” the company can submit a “Alternative Analysis Threshold Notification” which indicates that the chemicals of concern contained within the product are less than the threshold amount.  This notification must include;
    • Name and Contact information of the person submitting the notification
    • Name and Contact information for all manufacturers, importers, assemblers and retailers
    • Certification that the chemical is present in the product only as a contaminate and the concentration does not exceed the PQL threshold and the method used to determine the PQL
    • Source of the chemical in the product
    • All brand names and labeling information for products and if a component the names of all known products in which the component is used
    • Laboratory methodologies, location and quality assurance/quality control protocols used to measure the chemical
    • Attestation for the controls that will be in place to assure that threshold will not be exceeded