One of the biggest challenges the CPSIA presented the CPSC is the requirement, in §104 of the law, to issue four final rules each year regulating durable infant and toddler products. Young children are our most precious “consumers” and it is critical that the products they use for sleeping, feeding, and playing are safe. Having said that, not all these products necessarily present risks or present risks of the same magnitude.
Congress told us to mandate standards for these durable nursery products based on voluntary consensus standards unless we determined that more stringent requirements are needed. As we have worked to push rules out on the timetable mandated by Congress, I am concerned that the quality of the rules we are issuing is being overshadowed by the need to meet this schedule. Sometimes we propose or mandate requirements that have not had a full vetting by the experts outside the agency. If this happens we need to go back and repair the damage, a process that is resource intensive and inefficient for the agency and for stakeholders.
I discuss my concern in a statement I filed on an NPR on hand-held infant carriers. I am interested in any ideas from others who share my concern about how to make the process work better than it currently does. You can read my statement here.