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CPSC Seeks Input on Component Testing

Published December 16, 2008

BETHESDA, MD (BRAIN)—The Consumer Product Safety Commission is seeking comments on mandatory third-party testing for component parts in children’s products as part of the new consumer product safety law.

The Consumer Product Safety Information Act requires children’s products—those designed or intended primarily for children 12 or younger—be tested by a third-party facility 90 days after the Commission issues requirements for a certain product.

For instance, for the law's new lead paint requirements, third-party testing goes into effect on Dec. 22, 90 days after the Commission's completed the rulemaking process for that category.

The CPSC is looking for comments and information on several topics pertaining testing of component parts including:

—How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts of a consumer product versus third-party testing of the finished consumer product.

—The circumstances, if any, that should be considered in allowing third-party testing of component parts.

—The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.

—Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace.

—Whether and how the use and control of subcontractors would be affected by allowing the third-party testing of component parts.

—What changes in inventory control methods, if any, should be required if third-party testing of component parts were permitted.

—How a manufacturer would manage lot-to-lot variation of component parts, in a third-party testing of component parts regime, to ensure finished consumer products are compliant.

—Whether consideration of third-party testing of component parts should be given
for any particular industry groups or particular component parts and materials. Explain what it is about these industries, component parts, and/or materials that make them uniquely suited to this approach.

Comments must be received by the Office of the Secretary by January 30, 2009. Comments may be filed to, by fax to (301) 504-0127 or by mail or delivery to the Office of the Secretary, Consumer Product Safety Commission, Room 502, 4330 East-West Highway, Bethesda, Maryland, 20814. Comments should be captioned “Section 102 Mandatory Third-Party Testing of Component Parts.”

Interested persons will have additional opportunities to comment following publication of any notices of rulemaking proceedings in the Federal Register.

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