Almost one year ago, Congress directed the CPSC to come up with ways to reduce the costs of third party testing. I mentioned in my previous blog several general themes that occur again and again in the public comments on how to reduce testing burdens. Today, I would like to give you a flavor of some specific comments submitted concerning harmonization of both safety standards and testing requirements, be they international, federal, or state. Differences in requirements frequently lead to redundant testing which leads to additional costs without any noteworthy increase in safety. Unnecessary costs take their toll in the form of lost jobs or shuttered businesses, and the ultimate loser is the consumer, stuck with the bill and fewer choices. In addition, the global economy is affected as increased testing costs impede both innovation and the ability of companies to expand into foreign markets.
Below are some examples from the comments received.
“It is becoming a minefield of compliance issues and companies are having trouble avoiding violating one regulation in an attempt to comply with another. In the process, testing costs are increasing.” –American Apparel and Footwear Association
“Manufacturers of children’s art material products are subject to four tiers of federal regulation: FHSA, LHAMA, ASTM D4236, and CPSIA…This creates many redundant testing requirements for the industry and raises costs for them.” –The Art & Creative Materials Institute, Inc.
“The CPSIA standards are a lot like the EN 71 requirements, which we already do fulfill…But even though [sic], we are asked to test all our products again to CPSIA standards.” –Grimm’s (German toy manufacturer)
“A strong federal standard that preempts state standards is very important for the success of a business. Compliance with a patchwork of state standards is impractical, extremely burdensome, and does not make the product any safer.” -Toy Industry Association
These and other comments show that this is an important, multi-layered and complex issue. But just because it is hard to solve does not mean that we should not spend more time and effort trying. I look forward to receiving staff recommendations on how to address this important issue. The numerous comments we received from such a diverse group of commentors indicates that this is something the agency needs to address.