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Practice Areas

Imports are Key Part of CPSC Draft Strategic Plan

Tuesday, February 09, 2016
Sandler, Travis & Rosenberg Trade Report

The Consumer Product Safety Commission is inviting comments through March 9 on all aspects of its draft strategic plan for 2016-2020. This draft plan sets out how the CPSC will pursue its four strategic goals of cultivating the most effective consumer product safety workforce, preventing hazardous products from reaching consumers, responding quickly to address hazardous consumer products in the marketplace and with consumers, and communicating useful information quickly and effectively to better inform decisions. CPSC programs will align with these goals and staff will implement strategies to achieve them.

Prevention. With respect to preventing consumer product-related injuries, the draft plan sets forth the following initiatives.

- increase capability to identify and stop imported hazardous consumer products; e.g., by accelerating the ongoing effort to modernize the CPSC’s risk assessment methodology computer system, implementing the full-production RAM compliant with the Single Window initiative, and decreasing the time required to process imported products subject to inspection

- increase importers’, manufacturers’ and retailers’ use of consumer product safety best practices, including finalizing the Trusted Trader program

- advance data analysis and research capability to identify existing and potential emerging consumer product hazards, particularly those linked to rapid advances in technology such as the use of nanoparticles

- address changes in traditional manufacturing methods, such as additive manufacturing using 3-D printers, and e-commerce distribution options

- develop voluntary standards and mandatory regulations to address hazards for products resulting from new technologies

- identify, research and inform the public about chemical or chronic hazards in consumer products

Response. To allow the CPSC to quickly address hazardous consumer products in the marketplace and with consumers, the draft plan specifies the following goals.

- determine the feasibility of implementing an e-filing process for importers, manufacturers and retailers to submit incident data and section 15(b) reports

- improve the effectiveness of corrective actions; e.g., by implementing electronic submission of progress reports from recalling firms and informing foreign product safety regulators about interventions undertaken in the U.S. and encouraging them to take appropriate steps

- explore the feasibility of an expedited approach to corrective action plans for lower-level consumer product hazards

- increase the speed with which the CPSC identifies hazardous products by improving the data collection, internal sampling analysis and testing process to quickly identify patterns and trends that reflect emerging hazards

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