This past week I had the honor and pleasure of addressing the graduating class of the product safety management course at the Cook School of Business at St. Louis University. The program is one of only a few executive education programs focused exclusively on training corporate product safety compliance managers. The graduates were engaged and knowledgeable, but also realistic in understanding the challenges they face in managing the increasingly complex job of successfully integrating safety into a global supply chain in a way that assures compliance with our regulations.
As an exercise, we undertook a mock hearing paralleling the priorities hearing the Commission held several weeks ago. The “student witnesses” testified before me (representing the Commission) about issues to which they believe the agency should be giving increased attention. Their “testimony” was informed by the studies they have been doing over the past several months.
Interestingly to me, what I heard paralleled in many ways the messages we heard from the Commission’s July priorities hearing. While the students had suggestions for specific products that they believe present risks and warrant additional attention, several themes also came through loud and clear. For example, we spent much time talking about the alignment of international standards and the preemption of state standards. In their work back at their companies, they have seen the problems caused by diverse standards all addressing particular risks but in different ways. Additionally, we discussed the sometimes overwhelming challenges that smaller- to medium-sized companies face in trying to understand and comply with rules that they see as unnecessarily confusing. The message was that while safety is a core value, contending with hard-to-understand rules that seem to have requirements that do not necessarily advance safety—while still consuming scarce resources—is hard to justify.
In the end, I found the experience heartening. It is great to see the marketplace—and the education sector—responding to new safety challenges with training to help companies further develop the management processes to assure safety in their companies and products and compliance with the law. Although it may be frustrating to hear more about the difficulties created by poorly crafted, poorly understood rules coming out of the CPSC, one sees dimly the hope of a reinvigorated community of the regulated and the regulators, working together to craft sensible rules that improve safety effectively and reasonably.