CPSC Delays Vote on Component Testing, “15 Month” Rule Until April 28

The Consumer Product Safety Commission has delayed its vote on the draft proposed "15 Month" rule on testing and labeling and the related draft proposed rule on component testing from April 21 until April 28, 2010.

Draft Proposed “15 Month” Rule

The draft proposed “15 Month Rule” would establish requirements for: (i) reasonable testing programs for non-children’s products; (ii) compliance testing to support certification of children’s products; (iii) continuing testing of children's products on a periodic basis and whenever a material change occurs; (iv) verification testing of third-party test results; and (v) certification labeling.

As the proposed rule would codify Consumer Product Safety Act (CPSA) section 14(a) and (d), as amended by section 102(b) of the Consumer Product Safety Improvement Act of 2008 (CPSIA), it would cover many of the most important aspects of the CPSIA.

The draft contains certain requirements that may surprise the trade, including CPSC’s interpretation that verification would be testing conducted by an alternate third-party lab to ensure that the original third-party test results were correct; that each manufacturing site would be required to have separate periodic test plans; the extensive recordkeeping requirements; etc.

(See ITT’s Online Archives or 04/09/10 news, (Ref: 10040905), for BP summary of the draft proposed “15 Month” rule.)

Component Testing Draft Proposed Rule

The draft proposed rule on component testing would establish the conditions under which domestic manufacturers and importers issuing either a general conformity certificate for non-children’s products or a certification for children’s products could rely on tests of components of the product, including materials used to produce it, as all or part of the basis for a valid certificate that the product complies with each applicable standard, rule, ban, etc. enforced by CPSC.

The draft would also set out the conditions under which such tests of component parts could be conducted by persons other than the manufacturer (or importer), such as the manufacturer or supplier of the component parts.

(See ITT’s Online Archives or 04/14/10 news, (Ref: 10041415), for BP summary of the draft proposed rule on component testing.)

Live Webcast of Meeting Available

A live webcast of the meeting can be viewed at www.cpsc.gov/webcast/index.html. No registration is necessary to view the live webcast.

CPSC calendar (updated 04/19/10) available at http://www.cpsc.gov/calendar.html