Establishing a Proper Compliance Program

Is my safety program where it needs to be?

This is a common question that a company must ask itself in regards to their safety program. Unfortunately there is not a guideline out there that is going to give you step-by-step guidance as to how to put one together. Every program built is unique to the company and the types of products they are manufacturing and/or importing. 

What a company can do to insure they are on the right track is ask themselves the right questions.  

The following 9 Questions can help you gauge if your "Compliance Program" is where it needs to be.

• Do you have a formal Statement of Management Policy?
• Does your team have knowledge of specific requirements that pertain to your product and the countries they will be sold in?
• Have internal manuals, documents, and procedures necessary for compliance been created and kept?
• What are your record keeping procedures?
• Do you have complete ownership of compliance for your vendors and/or manufactures?
•  Have you or your team had regulatory training and been certified?
• Have you formalized internal Audits and SOPs?
• How many times a year do you perform internal mock recalls, product defect situations, and contamination procedure exercises?
• Do you have a cross department safety council?

It is imperative that vendors and manufactures of consumer goods consistently evaluate the state of their program and make necessary adjustments as needed.

Have a question? Feel free to send it to QualityAssurace@CPTSol.com

CPTS Team

Lead, Phthalates, and Inaccessible Parts

Knowing what needs to be tested and more importantly what doesn't, is a common theme we see with inexperienced manufactures, importers and retailers. 

Did you know that parts that are not easy accessible through normal use, do not need to be tested for Lead or Phthalates? 

According to the CPSC, ''lead and phthalate limits shall not apply to any component part of a children’s product that is not accessible to a child through normal and reasonably foreseeable use and abuse."

One of the most common places where testing costs can be reduced is by understanding the differences between these accessible parts and inaccessible parts.

So how do we determine if a part is inaccessible? According to the CPSC a component part is not accessible if it is:

• Not physically exposed by reason of a sealed covering or casing 
• Does not become physically exposed through reasonably foreseeable use
• Abuse of the product including swallowing, mouthing, breaking, or other children’s activities, and the aging of the product, does not case the part to become accessible 
• Parts do not become explodes after the CPSIA Physical/Mechanical test.

Please note that paint, coatings, fabric, or electroplating may not be considered to be a barrier that would render a part to be inaccessible.

We often see a business submit a product or a component to a laboratory for testing without stating certain areas of inaccessibility. The lab will then either A) assume the parts are accessible or B) flat out charge the extra testing cost if the business did not ask for the exemption. 

In short, take the time to determine parts that are inaccessible in your product and more importantly make sure to review with the lab any reasons why inaccessible parts were wrongfully tested.

As always,  please feel free to send your comments/questions to QualityAssurance@cptsol.com

CPTS

How Safety Testing Works: Part 1

Where exactly does the safety process begin? With all of the regulatory changes that have happened over the last 5 years, the safety process should start at the Design phase. The key to a great Quality Assurance program is to be diligent in the beginning stages of the process. Remember, be proactive not reactive. 

Start with a basic understanding of what raw materials your product will contain. If a soft plastic piece is part of the design, make a note that Phthalates are commonly found in plastics that bend with ease.    

Make note of who your target customers are and make sure that all regulations that pertain to that target is well documented. For instance, a child's sound toy might have a specific decimal limit that must be met in order to pass testing.

Another factor to take into consideration is if your product is being sold at a specific retailer. There is a good chance that the retailer you are planning to sell through has it's own brand specific testing practices that go beyond the typical federal regulations that your products would be tested to.

The easiest way to complete the safety design process and document it correctly would be to have a Design Evaluation performed on your product. A Design Evaluation is typically needed for companies who do not have a team of safety engineers, or have access to the latest and newest testing standards. These Design Evaluations can map out every requirement needed and any potential hazards or failures prior to the start of production.

Design Evaluations are the new norm in the Quality Assurance world. When performed correctly, a company can hedge their risks, reduce testing costs, and take a proactive approach to safety testing.

As always, please feel free to ask any questions in the comment section below.

CPTS