My last two blogs have discussed shortcomings in the soon-to-be-voted-on testing and certification rule. A third aspect of this testing and certification rule that concerns me is how it has mired another rule in an arbitrary process: our voluntary component testing rule.
The component testing rule clarifies that testing done by a component part manufacturer can be relied upon by the manufacturer of the final product. The rule would allow component part manufacturers (like the company that makes the plastic for the teddy bear’s nose) to test and certify those component parts themselves. The final manufacturers of consumer products (here, the teddy bears) could then pass through the compliance maze more quickly by relying entirely on components that were already tested and certified. The goal of the component testing rule is to mitigate the burden of testing by spreading those costs across the supply chain. It recognizes that, from a safety standpoint, the whole really is just the sum of its parts. And, it effectively pushes safety up the supply chain.
The component testing rule could have been issued months ago. Indeed, all year long I have been asking the majority why they were holding back this rule and have yet to receive a satisfactory answer. Apparently, their thinking is that if this is tied to the testing and certification rule, it will make the whole indigestible package more palatable. They are wrong in thinking this. And they are wrong, by holding the component parts rule hostage, to regulate with such disregard for how their actions impact those who have to live with them.