Protecting Your Client's Brand
In addition to obtaining the information you need to comply with the law, it's an opportunity to demonstrate to your clients your concern for their protection and your knowledge of the law. Make it your standard practice to note on applicable purchase orders in bold letters: "The products in this order are intended for an audience that includes children 12 years of age or younger and must comply with all provisions of CPSIA."
With product safety and regulatory compliance in mind, you should vet each of your suppliers carefully and perhaps through a different lens than you have before. Does the supplier have a compliance department? Is there a senior compliance officer who can explain to you how the compliance process works at each of the suppliers' factories and at their headquarters? Does the supplier have any quality or product safety certifications? Do they have inspection records and third-party audits to back up what they're saying? Is a risk assessment done on their products before each one is added to the line? What third-party tests are conducted and how often? How do you obtain the current test report for each product? Do the test reports include photographs specific to the supplier's products or are they generic reports for similar products made by the same factory? Does the report include all the required tests to comply with U.S. regulations or is the report referring to European standards? All of these are important questions that you or someone in your organization should know the answers to before doing business with any supplier.
Where can you get this education if you're new to product safety? One great resource is the Promotional Products Association International (PPAI). PPAI frequently offers product safety classes and has an extensive library of on-demand product safety webinars. It also publishes numerous best-practices documents that can help jump-start your compliance initiative. PPAI even has an online tool called Turbo Test that walks you through a series of questions to help you determine the compliance requirements for most promotional products. Testing labs such as UL-STR and ANSECO Group are another resource for product safety and compliance training. Most labs provide webinars on a variety of product safety and compliance topics and provide consulting services on a product-by-product basis as well.