What is undue influence training?
Undue influence training is training to make sure that manufacturers and their employees do not exert undue influence on testing laboratories to alter test methods or test results that serve as the basis for certifying a product’s compliance under federal law.
Manufacturers and importers are required to make sure “that every appropriate staff member receive training on avoiding undue influence and sign a statement attesting to participation in such training.” Manufacturers and importers must also inform their employees that allegations of undue influence may be reported confidentially to the CPSC and must tell their employees how to make such confidential reports.
A digital signature or other electronic attestation (such as a check box), indicating that an employee took the training as part of software or online training, would meet the requirement to “sign a statement attesting to participation in such training.”
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CFR › Title 16 › Chapter II › Subchapter B › Part 1107 › Subpart C › Section 1107.24
16 CFR 1107.24 – Undue Influence.
§ 1107.24 Undue influence.
(a) Each manufacturer must establish procedures to safeguard against the exercise of undue influence by a manufacturer on a third party conformity assessment body.
(b) The procedures required in paragraph (a) of this section, at a minimum, must include:
(1) Safeguards to prevent attempts by the manufacturer to exercise undue influence on a third party conformity assessment body, including a written policy statement from company officials that the exercise of undue influence is not acceptable, and directing that every appropriate staff member receive training on avoiding undue influence, and sign a statement attesting to participation in such training;
(2) A requirement that upon substantive changes to the requirements in this section regarding avoiding undue influence, the appropriate staff must be retrained regarding those changed requirements.
(3) A requirement to notify the CPSC immediately of any attempt by the manufacturer to hide or exert undue influence over test results; and
(4) A requirement to inform employees that allegations of undue influence may be reported confidentially to the CPSC and a description of the manner in which such a report can be made.