CPSIA HR4040 PDF

In December , this stay of enforcement was further extended until February 10, In both cases, the CPSC cited a need to implement further rulemaking and to give manufacturers more time to comply. These new regulations go into effect 15 months after publication in the Federal Register. Specifically, if employees of a manufacturer, private labeler, distributor, or retailer of consumer products, may not have their employer retaliate against them for reporting potential violations of consumer product safety laws.

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In December , this stay of enforcement was further extended until February 10, In both cases, the CPSC cited a need to implement further rulemaking and to give manufacturers more time to comply. These new regulations go into effect 15 months after publication in the Federal Register. Specifically, if employees of a manufacturer, private labeler, distributor, or retailer of consumer products, may not have their employer retaliate against them for reporting potential violations of consumer product safety laws.

Increases criminal penalties for various prohibited acts to include forfeiture of assets and imprisonment for up to five years, and eliminates the requirement that the CPSC first notify a company of noncompliance before seeking criminal penalties. Requires CPSC approval of the remedy offered in a product recall, rather than giving the recalling party its choice of repair, replace, or refund.

Congress passed this legislation in the wake of several high profile recalls in and of toys manufactured in China. Though many of these later turned out to be problems with design rather than manufacture, [11] public pressure was increased as the result of at least one case of lead poisoning [12] and subsequent issues with tainted pet food [13] and other products shipped from China.

The first deadline came up in September, and several major deadlines came up in February Manufacturers point out that many of the products to be impacted are already making their way through the supply chain.

As a result, much inventory that was legal prior to the signing of the law and was manufactured shortly thereafter will probably be on shelves as the deadlines approach. The Natural Resources Defense Council and Public Citizen apparently agree that these products are already in distribution, but believe that manufacturers should still be held liable. There is also confusion of what products need a GCC and which do not.

They have not been tested because the items generally do not contain hazardous materials; CPSC has been slow to define some of the accreditation or testing criteria; some of the low volume, low value items are not economical to test; and lot tracking methods would not allow some of the items to be tracked.

Companies with large varieties of products will have difficulty selecting several samples of every item. Those can be combined in limitless ways and in various sizes. Testing all of the final products generally provides no more information than would testing the individual inputs or "components" , but is vastly more expensive. When tested separately, the button would fail, but when mixed together with the other inputs, the final total lead content may fall below the standard.

Thus, unit testing would result in certifying the safety of a product which has unsafe components that could be swallowed by a child. Electronics products contain lead as a component of solder ; whereas the European Restriction of Hazardous Substances Directive standards have long attempted to phase out lead solder, the tin solder is known to suffer from a defect known as tin whiskers.

This means that entire classes of products may become unavailable as manufacturers withdraw from the markets, banned as they are unable to pass tests, or defective as they substitute inferior components. The law requires some rulings from the CPSC on a predetermined schedule, and allows for other rulings as necessary.

Manufacturers must wait until a final ruling is made before they can perform the required testing or gather the required documentation. For example, the law required the issuance of a GCC for products manufactured "on and after November 12, ", but the GCC ruling was not published in the Federal Register until November 18, Larger manufacturers are faced with problems stemming from their leverage, from aspects of Sarbanes-Oxley legislation, from their visibility, and from the logistics of managing the testing of large varieties of products.

Large manufacturers tend to be very leveraged, and use their eligible inventory as their borrowing base. Because the inventory is going to become unsalable on February 10, , there will be an abrupt change in their borrowing base. This raises the question of whether corporate officers can legitimately claim inventory in their current borrowing base.

Because many of these loan agreements and all publicly traded companies require audited financial statements at the end of the year, inventories will be tested.

This will result in a negative change in valuation and a sharp reduction or termination of available credit. For public companies, it raises the issue of whether those officers are making false representations, introducing the specter of criminal liability under Sarbanes-Oxley.

One small bookstore owner interviewee criticized the CPSC and referenced the book Fahrenheit , where the destruction of books at government behest was a plot point. Olson also claims that there has never been any known case of a child receiving lead poisoning from a book. In his closing paragraph, Olson writes " The law has a provision for exceptions to be made by the CPSC, but it has not done so for these products as of March

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