As Congress discusses the CPSC’s budget, some are warning that we must maintain or increase our budget in order to avoid a repeat of 2007, the so-called “year of the recall.” To make this point, agency officials recently have pointed out that as our staffing fell, recalls rose – the implication being that this increase in recalls indicated a lapse in safety. I challenge this assertion.
Until the passage of the CPSIA, the recall was the agency’s primary enforcement activity and it continues to be one of the most important tools in our arsenal. In 2007, when we saw lead paint violations from two of America’s iconic brands, the agency undertook an immediate and aggressive enforcement campaign to assure that the lead paint law was being strictly complied with. This enforcement emphasis showed troubling lapses in quality assurance programs of some global manufacturers and, of course, led to the lead paint recalls of 2007. However, preventing violative products from coming into the country is always better than recalling them after import and the CPSIA gave the agency additional tools to stop violative products from entering the country. It is incorrect to say that the 2007 recalls indicated the agency was not doing its job or that a decrease in resources caused an increase in recalls.
Recall statistics can be used to demonstrate just about anything. For example, during 2007 and 2008, the agency was criticized in many quarters, including by a number of Members of Congress, for doing too many recalls. Yet, Representative Jan Schakowsky wrote in a 2002 edition of Mothering Magazine (which recently stopped its print operation because of CPSIA) that she was “relieved” to see the “CPSC announcing recalls of infant products.” A representative of the organization “Kids in Danger” was very critical of a past chairman of this agency for, among other reasons, a dip in recalls in 2004, asserting this decline indicated that the agency was not doing its job. While this same organization criticized the agency in 2008 for too many recalls, it just published a press release stating the 2010 increase in recalls of children’s products indicated that our “actions…have had a measurable and definitively positive impact on children’s product safety.” In other words recalls are either bad or good depending on what point you are trying to make.
As readers of this blog know, I strongly support recalls when done right, and do not believe that every recall the agency does has merit. However, it’s time we all got off the kick of using recall statistics to push a particular point of view. They show we are doing an essential part of our job. Let’s leave it at that.