Three Possible Reasons for 3rd Party Testing

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December 19,2011 by Bill Jacoby

Three different situations that would call for third-party testing under final ruling 16 CFR 1107.

There are three basics instances that would require manufacturers/importers of children’s products to conduct independent third-party testing of their product.

  • “Initial” Third-Party Tests:  Under the Consumer Product Safety Improvement Act of 2008 (CPSIA) there is a requirement that prior to new children’s products being placed into the marketplace they would be tested by an independent third-party for compliance of all safety regulations that would apply to it.  This is generally referred to as “initial” third-party testing.
  • Third-Party Tests for “Material Changes”:  After initial introduction of the product into the marketplace there could occur some changes to the product that might not be noticeable to a consumer but significant enough to affect a product’s ability to comply with all of the applicable safety regulations that it was originally certified under. Under the CPSIA these are called “material changes”.  Some changes might be enough to be noticed by the consumer – a product that was originally made from metal is now made from plastic.  Other changes might be more subtle – the red paint that a product is painted with was sourced from Supplier A is now sourced from Supplier B.  Both cases are classified as “material changes” and under the CPSIA require independent third party testing to show the product still complies with all of the applicable safety regulations.
  • Periodic Third-Party Tests:  The law recognizes that there are children’s products that might not undergo a material change for years.  However it was not the intention of the law to allow those products to continue to enter the marketplace based on a single series of third-party tests done years before.  To ensure compliance the CPSIA requires that children’s products be third-party tested from time-to-time.  This ongoing testing is called “periodic testing”.  The interval between this “periodic testing” can be defined by three methods a manufacturer/importer of record can choose; “periodic test plan”, “production test plan” or “ISO/IEC 17025:2005(E)”.

The gravity of testing and certification of children’s products can be underscored by a recent remark to more than 30 representatives of the toy industry at a recent Capitol Hill meeting with the Consumer Product Safety Commission (CPSC).  Commissioner Nancy Nord acknowledged to the group that the January 1, 2012 enforcement date for CPSIA regulations will bring a change to the industry.  All Stays of Enforcement will have expired and the CPSC will be more diligent in its review of toys at ports of entry and failure to comply with third party testing regulations will result in the holding up of the shipment and fines of up to $100,000.

2012 is weeks away …. is your company ready? Need help in deciphering the law as it pertains to you? Jacoby Solutions can review your Testing and Labeling process to make sure it contains all the elements as outlined under 1107 including record keeping. We also can provide services for Sourcing/Project Management testing for any new products you have in development or act as a liaison between you and your factory. Contact us today and see how we can save you money!

Record Keeping and Labeling Requirements for Children’s Products

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December 9, 2011 by Bill Jacoby

CPSIA Testing, Labeling and Certification – Part 5

In 2012 companies will quickly have to deal with the final ruling issued by the CPSC under 16 CFR 1107 as mandated by the CPSIA Section 102.  In this new ruling the CPSC has outlined standards for manufacturers/importers to show compliance with existing safety rules, bans and standards for the products they produce.  The rule can be broken out into five (5) major areas; the types and frequency of testing, what constitutes a material change in a product, the requirements and procedures and training for an undue influence program,  general recordkeeping requirements and label requirements for products complying with consumer safely rules under the CPSA.

In the fifth and final part of this article we will look at the requirements for manufacturers/importers under the recordkeeping part of the rule.

Recordkeeping

A manufacturer/importer of a children’s product must maintain the following records;

  • a copy of the Children’s Product Certificate (General Certificate of Conformity) for each product.  The description on the certificate must clearly distinguish and define the product so that it is identifiable from others that the manufacturer/importer may have
  • records of each third party certification tests.  The manufacturer/importer must have separate certification tests records for each manufacturing site even for the same product.  The manufacturer/importer cannot assume that units of the same product manufactured in more than one location are identical in all material respects.  Differences in power quality, climate, personnel, and factory equipment could materially affect the manufacture of the product.
  • records of one of the following for periodic tests of a children’s products
    • periodic test plan and periodic test results (every year)
    • production testing plan, production test results and periodic test results (every two years)
    • testing results of tests conducted by a ISO/IEC 17025:2005(E) accredited laboratory and periodic test results (every three years)
    • material change records describing all;
      • product design changes
      • manufacturing process changes
      • sourcing of component part changes
      • certification tests and their values
    • undue influence training records including;
      • training materials
      • training records of all employees trained
      • attestations of these employees for training

Manufacturers/importers must maintain the records specified for five years.  These records must be made available to the CPSC upon request either in hard copy or electronic format, such as through an internet web site.  These records can be maintained in languages other than English if they can be;

  • Provided immediately by the manufacturer/importer to the CPSC
  • Translated accurately into English by the manufacturer/importer within 48 hours of the request by the CPSC (or longer if negotiated with the CPSC staff

Product Labeling

This portion of the ruling outlines the program by which a manufacturer/importer of record may label a consumer product as complying with the certification requirements of section 14 of the CPSA.  The labeling program is not mandatory and can be used at the discretion of the manufacturer/importer who must determine for themselves the cost versus benefit of the program.  The label specifications are designed to avoid giving consumers the false impression that the product is neither a CPSC tested, endorsed or approved product.  It also prohibits manufacturers/importers from implying through the manipulation of the font type, size or other means that the CPSC has tested, endorsed or approved the product.

The label to be printed must be printed in a bold typeface using an Arial font of no less than 12 points, be visible and legible and state:  “Meets CPSC Safety Requirements”  Depending on the product’s characteristics, such as size, surface finish or the presence of a smooth or flat surface, the CPSC has allowed with the Product Labeling rule to give manufacturers/imports flexibility in implementing this rule.  The final rule does not allow for a symbol or a mark to show compliance as it might be misunderstood as a CPSC certification mark or endorsement of the product.  The labeling can appear on the packaging, within the informational literature found with the product, on the product itself or all three.

2012 is weeks away …. is your company ready? Need help in deciphering the law as it pertains to you? Jacoby Solutions can review your recordkeeping  and labeling process to make sure it contains all the elements as outlined under 1107 including record keeping. We also can provide services for Sourcing/Project Management testing for any new products you have in development or act as a liaison between you and your factory. Contact us today and see how we can save you money!

Bill Jacoby is the founder principal at Jacoby Solutions and developed the CORE Audit™ (Compliance Operations Readiness Engagement Audit), the company’s proprietary approach to business operations readiness A one-stop shop for manufacturing and distribution companies in need of a solutions partner who can help them evolve their business while keeping an eye on compliance, Jacoby Solutions saves companies time, money and resources while helping them become CPSIA ready.

Undue Influence – Establishing Your Company’s Policy

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December 8, 2011 by Bill Jacoby

CPSIA Testing, Labeling and Certification – Part 4

In 2012 companies will quickly have to deal with the final ruling issued by the CPSC under 16 CFR 1107 as mandated by the CPSIA Section 102.  In this new ruling the CPSC has outlined standards for manufacturers/importers to show compliance with existing safety rules, bans and standards for the products they produce.  The rule can be broken out into five (5) major areas; the types and frequency of testing, what constitutes a material change in a product, the requirements and procedures and training for an undue influence program,  general recordkeeping requirements and label requirements for products complying with consumer safely rules under the CPSA.

In the fourth part of this article we will look at the requirements for manufacturers/importers under the Undue Influence part of the rule.

Undue Influence

Each domestic manufacturer or the importer of a children’s product must establish procedures to safeguard against the exercise of undue influence on a CPSC accredited laboratory that could undermine the integrity of laboratory test data.  While the importer is not directly responsible for the training of employees of foreign manufacturers on this matter, it does not absolve the importer of its duty to exercise due care when relying on test reports provided by the manufacturer from a CPSC accredited laboratory.  The importer who issues a General Certificate of Conformity on a product that is based on test reports from a CPSC accredited laboratory over whom undue influence has been exercised provides a basis for the CPSC to deem the certificate invalid.  The CPSC will hold the final product certifier (manufacturer/importer) responsible for exercising due care that component part or finished product manufacturers or suppliers have not exercised undue influence over CPSC certified laboratories.

At a minimum these procedures must include;

  • Training for every appropriate staff member on the safeguards by the manufacturer/importer designed to prevent undue influence on CPSC accredited laboratories along with a signed training statement from each staff member
  • Written policy statement from company officials that the exercise of undue influence is not acceptable
  • Procedure for retraining based on any substantive changes to § 1107.24
  • Procedure to notify the CPSC immediately of any attempt by the manufacturer/importer to hide or exert undue influence over test results
  • Procedure/mechanism for employees of the manufacturer/importer to report confidentially to the CPSC any allegations of undue influence

2012 is weeks away …. is your company ready? Need help in deciphering the law as it pertains to you? Jacoby Solutions can review your company policies and include an Undue Influence component to make sure it contains all the elements as outlined under 1107 including record keeping. We also can provide services for Sourcing/Project Management testing for any new products you have in development or act as a liaison between you and your factory. Contact us today and see how we can save you money!

Bill Jacoby is the founder principal at Jacoby Solutions and developed the CORE Audit™ (Compliance Operations Readiness Engagement Audit), the company’s proprietary approach to business operations readiness A one-stop shop for manufacturing and distribution companies in need of a solutions partner who can help them evolve their business while keeping an eye on compliance, Jacoby Solutions saves companies time, money and resources while helping them become CPSIA ready.

Defining a Material Change after Product Certification

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December 7,2011 by Bill Jacoby

CPSIA Testing, Labeling and Certification – Part 3 Material Change

In 2012 companies will quickly have to deal with the final ruling issued by the CPSC under 16 CFR 1107 as mandated by the CPSIA Section 102.  In this new ruling the CPSC has outlined standards for manufacturers/importers to show compliance with existing safety rules, bans and standards for the products they produce.  The rule can be broken out into five (5) major areas; the types and frequency of testing, what constitutes a material change in a product, the requirements and procedures and training for an undue influence program,  general recordkeeping requirements and label requirements for products complying with consumer safely rules under the CPSA.

In the third part of this article we will look at the requirements for manufacturers/importers under the Material Change part of the rule.

Material Change

After the initial certification of a product, a “material change” in the product is a change that “could affect the product’s ability to comply with applicable rules, standards or regulations.”  This could occur based on a change in product design, manufacturing process or the sourcing of component parts where the manufacturer/importer knows or should know could affect the products ability to comply with all applicable children’s product safety rules.  At this point the manufacturer/importer must submit sufficient samples of the product to a CPSC accredited laboratory to test for compliance.

A manufacturer/importer whose product has undergone a material change cannot issue a new Children’s Product Certificate until  this testing is done.  Changes that cause a children’s product safety rule to no longer apply to a children’s product are not considered material changes.  The extent of testing needed depends on the extent of the material change.

For example, if the children’s product was a cotton sweater with metal buttons that were certified under the lead limits of Section 101 of the CPSIA and were changed to wooden buttons would this be classified as a material change?  Yes and No, changing to wooden buttons would eliminate the need to show continued compliance for lead limits under Section 101 of the CPSIA as natural wood is exempt from lead testing.  However for other children’s product safety rules, such as small parts the change may be a material change.

The three major categories of material change are;

  • product design, which includes all component parts , their composition, and their interaction and functionality when assembled.  The manufacturer/importer should evaluate the product as received or assembled by the consumer when examining product design
  • manufacturing process, is a change in how the children’s product is made which could affect the finished products ability to comply with the applicable safety rules.  For each change in the manufacturing process, the manufacture/importer should carefully evaluate the product to ensure it still meets all applicable safety rules or if the change results in new rules being applied to it.
  • sourcing of component parts, is a change that results when the replacement of one component part of a product with another component part that could affect compliance.  This includes, but is not limited to, changes in composition, part supplier, or the use of a different component part from the same supplier who provided the initial component part.

For a domestic manufacturer, there would be a special knowledge of its production design, components and, production processes not found with importers of record using foreign manufacturers.  For example, a domestic manufacturer would know whether a new solvent contains any of the prohibited chemicals such as lead and phthalates, or a replacement mold is made from the same specifications as the previously compliant mold.  Such changes would not be examples of “material change” and unless the importer of record has a very close working relationship with the foreign manufacturer, would not know.

2012 is weeks away …. is your company ready? Need help in deciphering the law as it pertains to you? Jacoby Solutions can review your testing process to make sure it contains all the elements as outlined under 1107 including record keeping. We also can provide services for Sourcing/Project Management  testing for any new products you have in development or act as a liaison between you and your factory. Contact us today and see how we can save you money!

Bill Jacoby is the founder principal at Jacoby Solutions and developed the CORE Audit™ (Compliance Operations Readiness Engagement Audit), the company’s proprietary approach to business operations readiness A one-stop shop for manufacturing and distribution companies in need of a solutions partner who can help them evolve their business while keeping an eye on compliance, Jacoby Solutions saves companies time, money and resources while helping them become CPSIA ready.

 

 

Production Testing Plans – What you need to know

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December 6, 2011 by Bill Jacoby

CPSIA Testing, Labeling and Certification – Part 2

In 2012 companies will quickly have to deal with the final ruling issued by the CPSC under 16 CFR 1107 as mandated by the CPSIA Section 102.  In this new ruling the CPSC has outlined standards for manufacturers/importers to show compliance with existing safety rules, bans and standards for the products they produce.  The rule can be broken out into five (5) major areas; the types and frequency of testing, what constitutes a material change in a product, the requirements and procedures and training for an undue influence program,  general recordkeeping requirements and label requirements for products complying with consumer safely rules under the CPSA.

In the second part of this article we will look at the requirements for manufacturers/importers under the Production Testing Plan and ISO/IEC 17025:2005(E) part of the rule.

Production Testing Plan

As discussed earlier, after the initial certification of the product by the domestic manufacturer or importer of record the product must undergo periodic testing to show continued compliance with the same safety rules, bans and standards it was originally certified under.  As outlined in Part 1 of this article, one option is to test the product under the Periodic Testing Plan.  Another option, which we will discuss now is called the Production Testing Plan.  A Production Testing Plan would be conducted at the manufacturing site whether it be domestic or foreign and would outline the production management techniques and tests that would be performed to show the continued compliance of the products produced.  A Production Testing Plan may include these following elements;

  • recurring testing at the factory and/or the laboratory
  • the use of process management techniques
    • control charts
    • statistical process control programs
    • failure modes and effects analyses (FMEA)
  • measurement techniques (nondestructive)

Whatever Production Test Plan is designed by the manufacturer it must be effective in showing continued compliance with the safety standards that the product was originally certified under.  Production Test Plans cannot consist solely of mathematical methods but must include some testing.  The CPSC has allowed that testing DOES NOT need to be the same test methods used for certification of the product.  If these test methods are different from the certification testing the manufacturer must document the production testing methods used to show how these methods ensure continuing compliance for safety certification of the product.  For example, if under the original certification a component of the product was tested under the small parts regulation, then the manufacturer may demonstrate continue compliance by measuring how affectivity that component is attached to the product.

A Production Testing Plan must contain the following items;

  • a description of the production testing plan to include;
    • a description of the process management techniques used
    • the tests to be conducted
    • the measurements to be taken
    • the intervals at which the tests or measurements will be made
    • the number of samples tested
    • the basis for determining that the combination of process management techniques and tests continued compliance of the product if the tests used are not the same as the ones used for certification of the product
    • a copy of the production plan at each manufacturers site and a specific plan for each children’s product manufactured there
    • a production testing interval that would ensure that any sample selected for production testing would comply with all applicable children’s product safety rules

 

If the production testing plan fails to provide that “high degree of assurance” of compliance for the products tested, the CPSC may require the manufacturer to show compliance using the Periodic Testing Plan as discussed in Part 1 of this article.

 

An importer can arrange for a foreign manufacturer to develop and conduct a production testing plan for a product.  The same production testing plan from another party may be used by multiple importers as a means of increasing the importers’ maximum periodic testing interval to two years.  The importer, as the product certifier, must use due care to ensure that the implementation of a production testing plan by the manufacturer ensures with a “high degree of assurance” that continuing production complies with the applicable product safety rules.

 

ISO/IEC 17205:2005(E)

A modification of the Production Testing Plan, would require manufacturers to conduct any testing done under the plan using an ISO/IEC 17205:2005(E) laboratory.  These tests which would be done by a CPSC accredited laboratory must be conducted at least every three years.  The manufacturer must ensure that the same test methods used for certification of the product are used to show continued compliance of the applicable children’s product safety rules.  Using the information obtained from this testing, the manufacturer will determine the appropriate testing interval and the number of samples needed for periodic testing to ensure continued compliance.

If this continue testing fails to provide the “high degree of assurance”, the CPSC may require the manufacturer to show compliance using the Periodic Testing Plan.

The advantages of these two test plans would be to extend the length of time between certification testing form annually to every two or three years, depending on the testing plan selected.  If the certifier of the product is an importer of record using a foreign manufacturer, the importer must closely work with the foreign manufacturer to ensure that either testing plan be well documented and shows that continued production of their product complies with all applicable product safety rules.

 

2012 is weeks away …. is your company ready? Need help in deciphering the law as it pertains to you? Jacoby Solutions can review or create your Production Testing Plan to make sure it contains all the elements as outlined under 1107 including record keeping. We also can provide services for Sourcing/Project Management  testing for any new products you have in development or act as a liaison between you and your factory. Contact us today and see how we can save you money!

Bill Jacoby is the founder principal at Jacoby Solutions and developed the CORE Audit™ (Compliance Operations Readiness Engagement Audit), the company’s proprietary approach to business operations readiness A one-stop shop for manufacturing and distribution companies in need of a solutions partner who can help them evolve their business while keeping an eye on compliance, Jacoby Solutions saves companies time, money and resources while helping them become CPSIA ready.

Requirements for Manufacturers/Importers under the Periodic Testing Plan part of the CPSIA section 102 rule. Are YOU Ready?

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December 6, 2011 by Bill Jacoby,

CPSIA Testing, Labeling and Certification

In 2012 companies will quickly have to deal with the final ruling issued by the CPSC under 16 CFR 1107 as mandated by the CPSIA Section 102.  In this new ruling the CPSC has outlined standards for manufacturers/importers to show compliance with existing safety rules, bans and standards for the products they produce.  The rule can be broken out into five (5) major areas; the types and frequency of testing, what constitutes a material change in a product, the requirements and procedures and training for an undue influence program,  general recordkeeping requirements and label requirements for products complying with consumer safely rules under the CPSA.

In the first part of this article we will look at the requirements for manufacturers/importers under the Periodic Testing Plan part of the rule.

Periodic Testing Plan

Under a Periodic Testing Plan the certifier (domestic manufacturer or importer) would be required to develop a testing plan that would ensure a children’s product manufactured continues “with a high degree of assurance” to meet the safety standards that the product was originally certified under.    The certifier of a children’s product must also determine the frequency of periodic testing (no less than once per year) and the number of samples to be tested.    There are provisions within this rule that would allow the manufacturer to extend the testing frequency to either two (2) years or three (3) years and will be discussed in a later article.

The CPSC has stated in its comments on this rule that it does not want CPSC accredited laboratory’s determining the number of samples that should be submitted for testing.  The CPSC expects the domestic manufacturer/importer to specify to the laboratory the number of samples needed for testing in order to show compliance for the product.  With the wide variety of children’s products, manufacturers, and manufacturing processes that would be subject to this rule, the CPSC felt it would be impractical to give guidance on specific sampling methods that could be applied to all products.  It is therefore important for the domestic manufacturer/importer to use their knowledge of the product and how it is manufactured in order to determine a method for determining the number of samples needed for testing.  Whatever method is chosen it must clearly document that a sufficient number of samples were selected in order to achieve “a high degree of assurance” for compliance.

In general a Periodic Testing Plan must include:

  • the tests to be conducted
  • the intervals at which the tests will be conducted
  • the number of samples to be tested

 

If the Periodic testing plan is conducted by the manufacturer (foreign or domestic), then each manufacturing site must have a periodic testing plan specific to each children’s product manufactured at that site.  If the importers of record are conducting the periodic testing plans then these plans must be retained by the importers of record.

 

The testing interval for a periodic testing plan may vary depending on the specific children’s product rule and the nature of the product but may not exceed one year.  Factors with which a manufacturer/importer may use to determine the testing interval are;

  • Extreme variance in test results (from sample to sample)
  • Results that are close to the allowable regulatory limit
  • Known factors in the manufacturing process that could affect compliance for a rule (example would be a casting die that has a useful wear life and is nearing the end of that wear life)
  • Consumer complaints or warranty claims
  • New or newly sourced component parts that are introduced into the assembly/manufacturing process
  • After the manufacture of a fixed number of products
  • The potential for serious injury or death resulting from a noncompliant product
  • A dramatic increase in the number of products produced annually
  • How often similar children’s products are tested by other manufacturers

The CPSC has also stated that domestic manufacturers/importers my use the testing certification from suppliers of component parts in order to show final product compliance as long as it meets the requirements under 16 CFR 1109 which outlines the conditions for relying on component part testing for certification.

Finally, the domestic manufacturer or importer is responsible for issuing a Children’s Product Certificate for the children’s product they manufacture or import.  For the importer using a foreign manufacturer issuing a Children’s Product Certificate involves one of two choices; one, if the importer has documentation of the manufacturing process (changes in suppliers, changes in component parts, etc.) and the testing data (laboratory report) then it can  issue a Children’s Product Certificate for that product or two if the importer has no knowledge of the manufacturing process then it should treat each shipment as a discrete lot and subject it to certification testing.  At this point the CPSC feels that the importer does not know whether material changes have been made to the product since its last shipment.  In regard to that shipment, the CPSC has put forth that it is not considered continuing production of the product and is therefore not subject to the periodic testing requirements.

 

2012 is weeks away …. is your company ready? Need help in deciphering the law as it pertains to you? Jacoby Solutions can review or create your Periodic Testing Plan to make sure it contains all the elements as outlined under 1107 including record keeping. We also can provide services for Sourcing/Project Management  testing for any new products you have in development or act as a liaison between you and your factory. Contact us today and see how we can save you money!

Bill Jacoby is the founder principal at Jacoby Solutions and developed the CORE Audit™ (Compliance Operations Readiness Engagement Audit), the company’s proprietary approach to business operations readiness A one-stop shop for manufacturing and distribution companies in need of a solutions partner who can help them evolve their business while keeping an eye on compliance, Jacoby Solutions saves companies time, money and resources while helping them become CPSIA ready.

Juvenile products must include product recall cards

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Consumer-action.org

Tuesday, October 25, 2011

As of June 2010, many durable infant and toddler products—including cribs, play yards, strollers, and high chairs—were required to contain a product registration card and a method to register online that allow purchasers of these products to easily register them with their manufacturer. (The information is only allowed to be used for notification of a recall or other safety concern—not marketing.) Companies are required to notify all of those purchasers who have completed the registration of a recall or other product safety issue.

However, a recent national survey commissioned by the Consumer Federation of America (CFA)—undertaken by Opinion Research Corp. (ORC)—found that over three-fifths of parents with children under 12 (61%) were not aware of this new protection. And an even larger proportion of all adults (68%) did not know about it.

CFA and Kids In Danger (KID) have compiled a list with links to most manufacturers’ registration sites.

In addition, CFA, KID and Consumers Union have produced a brochure that is available online and available in hard copy upon request.  You can contact CFA by email at cfa@consumerfed.org to order copies of the brochure.

The materials also can be accessed online through www.consumerfed.org and www.KidsInDanger.org.

Eighteen types of durable infant and toddler products are required to have the product registration cards. These products include full-size cribs and non-full-size cribs; toddler beds; high chairs, booster seats, and portable hook-on chairs, bath seats; gates and other enclosures for confining a child; play yards; stationary activity centers; infant carriers; strollers; walkers; swings; bassinets and cradles; children’s folding chairs; changing tables; infant bouncers; infant bath tubs; bed rails; and infant slings.

 

Tags/Keywords

product safety, recalls, warranties

Is Your Business Registered with SaferProducts.gov?

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Posted By: Bill Jacoby on October 11,2011

When problems become complaints:
In every potentially damaging customer service interaction, there is a pivotal point. And this point is not just the initial problem or incident reporting; it is the manufacturer’s or distributors reaction to the fraught interaction your customer experiences.Your employee’s response to the customers inquiry or complaint now needs to take into consideration the pace at which the angry customer now escalates the problem into a formal complaint on the safer products.gov website.

Take a look on the saferproducts.gov website and you will see several reports filed by consumers that were a result of not getting a satisfactory or timely response from the manufacturer. Some of them were not happy with the response given and others never even received a reply or call that was promised.Some of the reports submitted have the box checked No when asked if they plan to contact the manufacturer.

If you care about your brand equity and consumer confidence, you must register your business with Safer Products.gov so that you can be alerted when an incident is filed. Some of the key benefits of registration are:

  • Maximizes your time to review and respond to Reports before the 10-business day Report publication date.
  • Notification of Reports involving your products sent to you quickly and securely through e-mail.
  • Convenient and secure online account to provide comments on Reports and to communicate with CPSC.
  • Accounts can be set up with multiple users, with different permission settings for each user, to provide maximum flexibility.

Registration also provides you with a way to make a claim that a report contains materially inaccurate information . This information can be false and misleading and is so substantial as to affect a reasonable consumer’s decision making about your product. So if you care about your brand, take a look at your company’s incident reporting and escalation process and definitely  register your business so you can take a proactive approach when possible. You should always post a comment in response to a report. This is not  brand protection and compliance, just good business.

Bill Jacoby is the principal at Jacoby Solutions which has developed a CPSIA Operational Readiness Audit to help companies identify risk and improve their company’s business operations.