CPSIA Exemptions: Excerpts with Brent Stone
On Monday, I spoke with Brent Stone, executive director - operations for the Quality Certification Alliance, about the Consumer Product Safety Commission's (CPSC) recently announced exemption program. Brent gave me a lot of good information that could be useful to suppliers and distributors, but due to time constraints I wasn't able to include all of it in the original article. Below, I've included a few snippets from the transcript of our interview, discussing ink compliance, the golden sample, and the risks to your client's reputation.
Kyle Richardson: I think one of the biggest concerns with this registry is that people may not realize the difference between being exempted from testing and being exempted from compliance.
Brent Stone: Right. It's highly unlikely that the CPSC will ever put out anything that relieves people from the responsibility of making sure a product is safe and compliant. And I don't know how you do that in our industry without testing.
KR: So some kind of testing has to occur.
BS: Right. I don't know how someone can ensure compliance without using testing as part of the compliance program.
Now, there are two separate governing bodies in play here. I would lump state and federal into one governing group, and then the second group is the court of public opinion. Imagine a small-batch manufacturer who saw this as a reason not to test and delivered an untested product into commerce, and that had a Fortune 500 brand's name on it. If somehow a bad product still got out there, and that brand's name was on it... what is your defense, "well, we followed the law"? How would that work out for the client?
Not only do you have to think about compliance with whatever the federal regulation is, but you also have an obligation to protect the brand. And when you protect the brand, you need to protect it from perception as well as reality. You're not going to be able to argue that ... you were compliant when your buyer's name is ruined. Many people focus on testing, but testing in and of itself is not a complete compliance program.