This month, I had such a great opportunity to participate in the St. Louis University Product Safety Management Certificate Course. This course curriculum is offered through the Saint Louis University John Cook School of Business and is the brainchild of Don Kornblet, President of ADK Information Studies, LLC and Dr. Ik-Whan-Kwon, Director of Center for Supply Chain Management and Professor at St. Louis University.
The course is offered to product safety managers and others in this field to further develop their skills and knowledge in product safety, supply chain management and risk management. Per their usual program, I was invited to create an exercise that challenged students to find solutions to a real life challenge that CPSC is currently facing. In addition, I had the honor of being the keynote speaker at their graduation ceremony.
In 2004, as part of a compliance action, the CPSC created an innovative compliance program that came to be known as the Retailer Reporting Program (RRP). RRP allowed participating companies to voluntarily report consumer incident information based on risk-based criteria developed by CPSC staff. The program provided automatic confidential treatment of all incident information provided to the agency. Additionally, there was an understanding that if a company provided all the agreed-upon information, then CPSC would not seek penalties for any failure to report under section 15(b). In 2014, CPSC staff became concerned about the volume and value of data being received and the then acting Chairman, rather abruptly, imposed a moratorium on adding new participants. There has been no formal decision on a path forward for the Retailer Reporting Program and as of today the program remains in limbo. The uncertain status of RRP is one of the reasons I thought it would make such an interesting project for the course participants.
The exercise I offered was called, “Opportunities for Obtaining Better Safety Data from Private Sector Sources.” The goal was to brainstorm solutions for the agency’s Retailer Reporting Program self-imposed dilemma. Perhaps the ideas the students brainstormed could benefit sustaining RRP in a way that is valuable to both industry participants as well as CPSC.
I was so impressed with the student’s insights into this problem and the creativity of potential solutions that they generated in the relatively short time provided. Students identified possibilities related to IT, data management, identification, coding, trigger systems, and notably a desire to create a collaborative path forward with the agency. Clearly, it was identified that engagement and cooperation was the path towards a real solution.
The topic of RRP was of high interest to this class and our short time together did not provide an ample opportunity to touch upon all of the creative ideas that were generated. As a result of the exercise, I can say my belief that there is a real opportunity for the agency to develop a “next generation” Retailer Reporting Program, if we are willing to work with industry partners, has been strengthened. In a global market place, especially considering our limited resources, the CPSC needs to look beyond the Washington bubble. We must realize that it is the dynamic and vibrant marketplace that will provide solutions to some of the product safety matters we face today.