For as many rulings as have been handed down by the Consumer Product Safety Commission (CPSC) over the last seven months since the Consumer Product Safety Improvement Act (CPSIA of 2008) was enacted, there are as many still to come. From the content of mandatory product recall announcements to the specifics surrounding registration cards and tracking labels, the extent of the unknowns that linger, as effective dates draw nearer, is as daunting as ever.
The CPSC still has a huge task ahead. At a point when, theoretically, about half the rulings should be already worked out, it seems unlikely that the remaining deadlines can be met. I would not be surprised if we see more “grace periods” or official stays similar to the one we saw in January for certain certification and third-party testing requirements.
One such case where a stay is possible is with regard to permanent labels for children’s products (CPSIA Section 103). The CPSC is currently seeking advice as to whether or not to work toward a universal, international labeling and tracking system. While a global system may be a good move, manufacturers of children’s products sold in the US are required by the CPSIA to begin using permanent labels on products and packageing by August 14th of this year. Although talks are already underway, with a meeting being held this week (see below), given that public comments are not even due until April 27, 2009, my guess is that the effective date for tracking labels will need to be pushed out.
In the meantime, manufacturers struggle with whether to take steps toward planning the redesign of their production lines and business processes to accommodate the new labeling laws and internal tracking that will be needed – a nontrivial task to say the least – or to wait until they know exactly what the requirements will be.
Either way, there is something manufacturers and others can do besides sit and wait for the CPSC to resolve the ambiguities of the CPSIA. That is, participate in public meetings and comment requests. Now is the best time to influence the final rulings on these laws. Once they become official regulations, it is incredibly difficult to get them reversed.
Opportunities to make your voice heard for this week are listed below. You can find more information regarding location, times and links to official announcements on the Consumer Product Safety Information Calendar . By clicking on the event title you will see additional details as well as a link to copy the event to your own calendar.
Monday, March 16 – Thursday March 19
CPSC Mtg re: ASTM F15
Tuesday, March 17
CPSC Mtg re: Lead Testing and Tracking Labels for Jewelry
Wednesday, March 18 – Thursday, March 19
CPSC Mtg re: Barrier Fabrics
Wednesday, March 18
Product Labeling Mtg w/ CPSC re: a Proposed Global Traceability
Thursday, March 19
CPSC Mtg re: Certification Requirements, Specialty Products