The CPSC is accepting comments, indeed, soliciting them, on component testing until January 30th. >Here are the questions they would like the public to answer:
* 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 conditions and/or 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. Address receipt, storage and quality control of incoming materials, management and control of work-in-process, non-conforming material control, control of rework, inventory rotation, and overall identification and control of materials.
* 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.
http://www.cpsc.gov/about/cpsia/ComponentPartsComments.pdf- PDF file from the CPSC with further information.
Contact information:
EMAIL THE CPSIA - Sec102ComponentPartsTesting@cpsc.gov - with your views on testing. They have issued a Request for Comments and are accepting emails until 1/30.
You don't have to answer every question- you can pick one to write about or three or whatever.
You dont' have to comment from the standpoint of small business- you can write as a parent, as a consumer, as a citizen.
So if you do write (or already have) and would like to share your responses to help others figure out how to word what they want to say, I know I'd appreciate it, and I bet others would, too.
