So far, 2014 has been an interesting year. In January and February, the talk among those who follow CPSC matters closely was about the agency’s efforts to fundamentally change the voluntary recall process under the guise of merely “tweaking” the process. In March, the conversation is all about the agency’s efforts to dilute the protections that §6(b) of the Consumer Product Safety Act provides to assure that information coming out of the agency is accurate and fair. I wonder what April will bring.
The proposed changes to the §6(b) information disclosure rule which are now out for public comment alter the current rule and practice in very fundamental ways. Any company that is regulated by the CPSC should look at the proposal closely to understand how the CPSC proposes to change the rules of the road. As a starting point in this analysis, I recommend that you read an article recently published by the Washington Legal Foundation and written by former CPSC general counsel Cheryl Falvey. This article gives an overview of the changes the commission proposes and why they are important. Then you should read the proposal for yourself and start writing comments to the CPSC.