Compliance is Not Enough for Safe Promotional Products
While most product safety initiatives in the promotional industry are focused on compliance—CPSIA, FDA, Prop 65 and similar regulations—ICPHSO has always taken a deeper approach to consumer product safety. Several experts spoke of the importance of avoiding product related injuries by building in safety from the beginning—by designing out safety defects at the product development stage and by considering the foreseeable abuse and misuse of a product as well as its intended use. Another important topic focused on the importance of recall preparedness—having a well-practiced plan in place for the inevitable situations where unsafe products are discovered after a product goes to market. Time is always of the essence in such cases, including the obligation to report to CPSC. One of the most impressive presentations of the week was by Jennifer Thompson of Costco who explained the sophistication, speed and effectiveness with which Costco implements recalls and notifies customers who have purchased recalled products.
So while we should be proud as an industry of the product safety strides we are making—through PPAI's Product Responsibility Action Group (PRAG), through QCA, and through individual company initiatives—the ICPHSO presentations illustrate how product safety has to become part of the culture of all industry participants if we're truly to protect our industry. For example, how many promotional products are imported without a formal risk assessment or without evaluation for product safety hazards? In some cases these tests can seem unaffordable but the risk of not testing can be even more expensive. A few years ago our product development team was considering a spa kit for our line—one that contained a variety of aloe-type skin creams and lotions. The kit would have sold for less than $10. In performing our risk assessment we asked a well-known cosmetics lab to verify that the lotions were of the quality that the Asian factory contended and that they did not contain any harmful ingredients or toxins. The lab quoted $28,000 for the tests. This may be a normal cost for a major cosmetics company but for most of our industry it isn't a reasonable value proposition, particularly when the supplier has no idea if the product will even sell. Accordingly, we did not add the spa kit to our line. Now this week, in an unrelated case, the FDA has issued a dire warning about dangerous levels of poisonous mercury found in a variety of imported skin creams and antiseptic soaps or lotions found in at least seven states. Just imagine how this could have impacted our industry if these poisonous lotions had been purchased through a promotional products distributor and given away in a spa kit by a major corporation.