THE ROBINSON REPORT #32: Working Together to Be Safer

The CPSC’s mission is to protect consumers from unreasonably dangerous products. From ATVs and hoverboards to chairs, clothes, and cribs, products from all over the world are likely covered by a regulation promulgated by the CPSC or a voluntary standard CPSC participated in developing. Our relationship with industry stakeholders such as consumer advocates, manufacturers, retailers, importers and distributors is key to us doing our job well. Outside parties have several ways in which to engage with us that will be mutually beneficial.

Upcoming Workshop and Hearing

Next week the CPSC will be hosting two events in which we want hear from our external stakeholders.

On Tuesday, July 25, 2017, we are hosting a free Recall Effectiveness Workshop at 10:00 a.m. EST to try to find potential ways to improve the effectiveness of consumer product recalls. One of the primary ways in which we protect consumers is through recalls, and the success rates are often very disappointing. I am very much looking forward to hearing ideas on improving our recalls from our outside stakeholders at this upcoming workshop.

On Wednesday, July 26, 2017, the CPSC will host our Annual Agenda and Priorities Hearing at 10:00 a.m. EST. The purpose of this hearing to receive views from any and all interested parties about what the Commission’s agenda and priorities should be for 2018 and 2019.  This is a great opportunity to submit written comments and testify as to what you think we should be focusing on.  We would love to hear from you!

Public Comments

The public is always invited to provide feedback on proposed rules at As of today, the following proposed rules are available for public comment. Follow the hyperlinks to submit your input.

Finally, help us identify ways the Commission could potentially reduce burdens and costs of its existing rules, regulations, or practices without harming consumers. We welcome any suggestions, but request information and data to support them. Tell us your ideas on how the Commission could be more effective. Written comments are due September 30, 2017.

Check Out Our SBO!

The CSPC has had a Small Business Ombudsman (SBO) since 2014. The SBO provides information, guidance, and technical assistance to small businesses that are clear, easy to understand, and consistent with agency policy. Among other things, the SBO does webinars covering a variety of products, safety concerns, and regulatory requirements. The webinars may be found on the CPSC’s YouTube channel. See the SBO’s upcoming trainings and events schedule for more information. The SBO also travels to meet with stakeholders directly. (See our Public Calendar.) And follow the SBO on Twitter and/or subscribe to email updates to keep abreast of small business issues as they occur.

Our Regulatory Robot Tool

I have posted before about the Regulatory Robot. It is a tool to guide small businesses through our requirements to identify and review important product safety requirements before manufacturing or importing a consumer product. The Robot starts as a questionnaire that should be completed for each product. After completing the questionnaire, the Robot generates a downloadable PDF for your company’s files and future reference. While the Robot is not a substitute for legal advice, it provides a great starting point for small businesses and individual inventors to use to enhance consumer safety during the design stage of a product. The other Commissioners and I recently voted to dedicate additional resources for enhancing the capabilities of the Regulatory Robot as part of our midyear adjustments to our 2017 Operating Plan.

We hope that the Robot’s ease of use—at no cost except the 15 minutes needed to complete the questionnaire—will encourage individuals and small businesses to consider and consult CPSC’s and other applicable regulations early and often. By making consumer safety a top priority, a business can both be profitable and embody the values of corporate social responsibility.

Suggested Best Practices

Please consider ways to incorporate safety into your company culture by contemplating safety at a product’s design stage, building safety into your supply chain, becoming knowledgeable about the regulatory environment, establishing a recall strategy in advance, developing a habit for documentation, and prioritizing customer safety. (See our best practices.) Consumer safety is not an aspect of operating a business that should be solely relegated to the general counsel or the compliance officer. Rather, for manufacturers, innovators, and e-Commerce platforms, consumer safety should permeate your entire organization, from engineers to public relations to finance officers to sales. Adopting these best practices communicates to both your customers and members of your organization that safety is a priority and something that is taken seriously as a corporate social responsibility and ethical business practice.

Innovation, NOT Inhibition!

Cognizance of consumer safety and the underlying regulations and standards enables business owners to plan for and incorporate such measures into their business model. Designing, manufacturing, and selling products that consumers can enjoy without the risk of serious injury or death is good for everyone!

I am looking forward to hearing from and possibly even seeing many of you soon!

Join us in keeping consumers safe!

Posted in Best Practices, CPSC Small Business Ombudsman, Hearing, Public Comment, Regulatory Robot, Small Business Ombudsman, Strategic Plan, Workshop.