Not Knowing the Intended Use of a Product Puts Suppliers and Distributors at Risk

2) Another option is for suppliers to indicate in their catalogs, website, and in industry product databases, the specific products in their line that have been manufactured and tested as meeting CPSIA children's product standards. According to Brenner, "this option is a little more risky than option 1 because it requires more vigilance by everyone. If a distributor sends in a juvenile imprint order for one of the products that isn't marked as compliant and the supplier produces and ships it, then liability for everyone is still an issue. This option could work if distributors and suppliers have good communication and orders are clearly marked as 'intended for children.' eDistributors who receive orders over the Internet should require customers to answer a question about the intended use of the product—whether or not it is intended for young children—and the response should be included on the corresponding order to their supplier."

"The one thing that none of us in the industry can afford to do is to ignore this issue or assume it is someone else's problem," Brenner said. "This is a case where it really does take a village—everyone working together—supplier, distributor and end-buyer—so we make sure we all get it right. Who is the product intended for? Are children involved? If so, select only products which have been manufactured and tested as compliant with CPSIA standards. On that issue, there is no other option."

Brenner writes frequently on product safety and other industry issues. The complete text of this blog and others can be viewed at www.rickbrenner.com. Brenner was co-chair of the PPAI's first Product Safety Summit held this past August in Denver. He is a member of PRAG—PPAI's Product Responsibility Action Group and a founding board member and Compliance Committee Chair of the Quality Certification Alliance.