The Golden Sample: Why Testing Alone Isn't Enough
On a side note, even if we deliver safe products we must remember product safety is only one part of the equation. While product recalls are drawing much attention these days, historically, more big companies have been tripped up by social accountability issues rather than product safety problems. This has become such a concern that most Fortune 1000 companies now have some sort of Corporate Social Responsibility (CSR) program. There are even published lists of the alleged worst offenders, which I imagine does wonders for the stakeholder stock price.
Testing or factory audits are certainly best-practice steps to measure the effectiveness of your compliance program. But in and of themselves, testing and factory audits are not a compliance program. The CPSC has given some direction on what should be done in the presentation "Reasonable Testing Program & Third-Party Testing."
The goal of a testing program is to create a reasonable certainty that all manufactured products comply with rules, standards and bans. The components of this program include:
- Product Specifications
- Certification Testing
- Production Testing
- Remedial Action Plan
Testing must be proactive. Testing must be current. Testing must be specific to the project you are manufacturing if you have changed that product by putting a logo on it. I'm not aware of any ink suppliers that offer current test reports on their inks. So in the absence of their component testing, you are obligated to test these inks yourself. Product testing must be a component of your product safety and compliance program rather than an end-of-the-game "Hail Mary" to see if product safety exists.
To help you determine if your supplier partners are following the CPSC protocol, ask these questions:
- What is your testing program?
- What is your social accountability program?
- How do you develop the product specifications that you give to your factories?
- What are your checks and balances to ensure production matches the tested sample, and where does this take place?
- What happens when a product fails testing?
- What steps do you take to correct the manufacturing process?
- Heaven forbid it should ever be needed, but what is your product recall process in case something slips through?
If your supplier can send documentation within an hour or two, it has a proactive compliance program. If it takes a day or two, the policies are most likely being quickly written so the info can be sent to you. If the supplier says, "Huh?," we wish you luck and hope you have a big product liability policy because we'll be hearing or reading about your customer in the headlines soon. Let's hope your relationship with that customer and your business survives this inevitability.