Oops! I just checked my calendar – it’s April 1.
Many in the agency have been touting the much anticipated component parts testing rule as a real boon for small businesses. I share this hope. Therefore, I am more and more perplexed: if it will be so useful, why is the component parts testing rule (proposed 10 months ago) being held hostage to the more complicated, more complex “15 month” testing and certification rule??? That’s what is happening. While the component parts rule may help businesses cope with their testing requirements, our very cursory assessment of the testing and certification rule shows it will impose several hundred millions dollars of costs on product manufacturers. Unfortunately neither the costs nor the benefits of this rule have been properly quantified so the agency will be regulating blindly. Never mind that there is no reason for sitting on the component parts rule and that our words pointing to it as a boon for small business ring hollow by our actions.
We haven’t been able to put out succinct, helpful rules (see our muddled definition of “children’s products”). When we have the opportunity to do it with component testing, we delay.
Sadly, the real April fool’s joke is on both businesses and consumers.