From Reactive to Proactive: Redefining Safety Standards in the Promotional Industry (A Four-Part Series)

For the promotional products industry, the CPSC is one of the only governmental organizations dedicated to the issue of compliance. But be that as it may, Margulis isn’t the only one who believes the CPSC isn’t proceeding with due caution on issues of lead and product safety. According to a September 28, 2007 press release issued by the U.S. Senate Committee on Commerce, Science and Transportation, a legislative hearing on the Consumer Product Safety Commission Reform Act of 2007 had been scheduled for early October of this year. Should the bill be passed, the CPSC would be in store for numerous positive changes including budget and staffing increases; an upgrade of the CPSC’s research, development and testing facility; and stricter penalties for violators of the Consumer Product Safety Act. The Act also will ban lead in children’s products altogether and require more stringent labeling to aid in product recalls.

What (Else) to Watch For …

Though the issue of lead has been the media “darling” of recent months, and particularly affects the promotional products industry, toxicity is not the only danger that should impel action. The CPSC’s standards on issues, such as small parts and sharp edges are just as important, yet similarly, the rules are only slightly more spelled out. Here are a few of its explanations and points of caution for manufacturers and distributors of children’s products:

• Small parts: According to a small-parts regulatory summary sheet, which was created by the CPSC’s Office of Compliance in 2001 and summarizes the requirements published in the Code of Federal Regulations, “A small part is any object that fits completely into a specially designed test cylinder 2.25 inches long by 1.25 inches wide.” This is the approximate size of the fully expanded throat of a child under three years old, it continued. The information goes on to detail when and where labeling is appropriate as well as which, if any, additional warnings are required and where to go for supplemental information.