regulatory conversation

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REGULATORY ENFORCEMENT : A CONVERSATION PANEL DISCUSSION ICPHSO ORLANDO, FL FEBRUARY 27, 2014 VIEWS EXPRESSED IN THIS PRESENTATION ARE THOSE OF THE STAFF AND DO NOT NECESSARILY REPRESENT THE VIEWS OF THE COMMISSION.

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How to locate CPSC data on regulatory non-compliance notices, which are also called "letters of advice" (LOAs). The referenced Excel table will be updated frequently with the names of the firm, the foreign manufacturer, and other information. Businesses may integrate this information into their compliance workflows to assist them in sourcing safe & compliant consumer products.

TRANSCRIPT

Page 1: Regulatory Conversation

REGULATORY ENFORCEMENT:

A CONVERSATION

PANEL DISCUSSIONICPHSO

ORLANDO, FLFEBRUARY 27, 2014

VIEWS EXPRESSED IN THIS PRESENTATION ARE THOSE OF THE STAFF AND DO NOT NECESSARILY REPRESENT THE VIEWS OF THE COMMISSION.

Page 2: Regulatory Conversation

FINDING CPSC LETTERS OF ADVICE

• Identify applicable regulatory requirements for your product• Based on:• Product/product class• Intended age audience & consumer use patterns• Product’s material composition

15 USC §2063; 16 CFR §1107.20

Page 3: Regulatory Conversation

FINDING CPSC LETTERS OF ADVICE

• Identify one (or more) CPSC-accepted laboratories to conduct testing for identified regulatory requirements.

• Certify in a Children’s Product Certificate (CPC) based on passing test results.

• Provide CPC to retailers and distributors and, upon request, to CPSC or Customs (CBP).

15 USC §2063; 16 CFR §1107.20; 16 CFR 1110

Page 4: Regulatory Conversation

CPSC LETTERS OF ADVICE

1,775 Violations

From Oct. 2012 through January 17, 2014

Page 5: Regulatory Conversation

CPSC LETTERS OF ADVICE

• Voluntary; 16 CFR Part 1109

• If a finished product manufacturer purchases a component from a supplier who voluntarily tests its product (e.g., a paint supplier), that manufacturer must “exercise due care” to rely upon the component part certificate or component part test results in drafting its own Children’s Product Certificate.

• The concept of due care is flexible, and it will vary depending upon the circumstances and the industry in question.

Page 6: Regulatory Conversation

CPSC LETTERS OF ADVICE

LOA Table: Action Requested by Office of Compliance:

Consumer Level Recall Retail Level Recall Distributor Level Recall Stop Sale and Correct Future Production Correct Future Production

Page 7: Regulatory Conversation

CPSC LETTERS OF ADVICE

Import: Actions Requested by CPSC at Ports of Entry

Seizure & Destruction (Destruction by CBP; Requested by CPSC)

Conditionally Release & Recondition (CPSC Office of Import Surveillance and Office of Compliance & Field

Operations; Release under Bond) Conditionally Release For Destruction

(CPSC Office of Import Surveillance and Office of Compliance & Field Operations; Release under Bond)

Export Unconditional Release

Page 8: Regulatory Conversation

Desktop Reference Guidewww.cpsc.gov/desktopguide

CPSIA Resourceswww.cpsc.gov/GettingStarted

Twitter@CPSCSmallBiz

Slideshare Downloadable Presentationswww.SlideShare.net/USCPSC

RESOURCES

Email list signup www.cpsc.gov/email

Page 9: Regulatory Conversation

:

Mary ToroDirector, Div. of Regulatory

EnforcementOffice of Compliance

[email protected]

:

Neal S. Cohen Small Business Ombudsman

[email protected]

THANK YOU

Questions?