Compliance is Not Enough for Safe Promotional Products
4) Investigate whether the product, its components or its packaging is subject to any state or Federal regulation. In addition to CPSC regulation, many promotional products are also regulated by the FDA, including hand sanitizer, first aid kits, sunglasses and food contact materials such as drinkware. If the product is regulated be sure you have current (within a year) third party tests showing that the product complies with all of the regulatory requirements of current law.
5) Consider identifying products in your line that contain toxins. BPA, lead, phthalates and cadmium have all come under scrutiny by Congress, by CPSC, and by FDA but are still allowed by law for most products. Some of your customers or your customer's customer may have policies against purchasing products containing these substances. An alternate idea is to identify the products in your line that are lead free, phthalate free, cadmium free and BPA free and note this in your catalog, advertisements and on your web site.
6) Determine if any special labeling is required to warn against any hazards, to note any stress limits and to identify the appropriate age for the product.
This is certainly not a comprehensive list but it's a good start and would go a long way to raising the bar for product safety in the promotional products industry. In the months ahead, PRAG will be working towards proposing a similar suite of "best practices" for product safety that all industry participants can rally around. The more that all of us do to promote product safety—compliant products and safe products—the more we do to protect our clients and our livelihood.
(To learn more about ICPHSO and its programs, visit www.ICPHSO.org.)