Some might find it a surprising way to celebrate the start of the Independence Day weekend by announcing a new job. Nevertheless, I wanted readers to know that after leaving the CPSC 18 months ago, I have decided to come out of “retirement” and have become affiliated with Olsson, Frank, Weeda, Terman & Matz, a Washington law firm with a regulatory, public policy and litigation practice. Since the firm includes not only exceptional lawyers and policy advisors, but also scientists, doctors and other technical professionals, it brings a special kind of creativity to problem solving that is unmatched in Washington. It is this creativity and “spunk” that convinced me OFW was the right place for me.
Since leaving CPSC, I have spent my time writing, speaking and working on interesting projects of my choosing dealing with regulatory policy and safety issues. While I intend to continue these interests, my affiliation with OFW will bring another dimension to these activities.
I also intend to continue writing this blog. Its purpose is to educate and to provide commentary—sometimes complementary and often critical—about what is happening at the agency from my unique perspective. I try not to pull punches and my affiliation with OFW will not change that.
Tell CPSC What You Think
Published June 30, 2017 Burden Reduction , Comment Request , Consumer Product Safety , Nancy Nord , Recalls , regulation , safety Leave a CommentTags: CPSC, Nancy Nord, OFW, Recalls, regulation, safety
One of the very positive hallmarks of the new leadership at the CPSC is a desire to hear from all interested stakeholders on how to more effectively push forward the agency’s safety mission. The agency has offered several opportunities for input and for those of us who share that goal, these opportunities should not be ignored.
First, the agency will be conducting a workshop on ways to improve the recall process, including the effectiveness of recalls. Recall effectiveness is a perennial topic of conversation at the agency so it is gratifying that the agency is again looking at this topic, but hopefully from a new perspective. Both as a Commissioner and now, in private law practice, I often hear complaints about the opaqueness of the process. Participation in the workshop offers an opportunity to give real suggestions on how to make the recall process work better. The workshop will be held on July 26, 2017 at the agency headquarters in Bethesda. Those interested in participating must sign up with the agency no later than July 3. Here is more information about the workshop.
Second, the agency is requesting comments on ways to reduce the regulatory burden imposed by agency rules in ways that do not diminish safety. This effort is especially welcome since many of the regulations issued by the agency over the past eight years did not consider ways to accomplish safety goals in less burdensome ways. When Congress told the agency to try to find ways to reduce the burden of testing, the agency went through a fantasy effort to comply and, not surprisingly, came up with very little. Indeed, about the best it could do was exempt from testing toys made entirely from untreated wood from the trunks of trees (but not the branches—who knows what could be in branches!). (See here.)
Reducing unnecessary regulatory burden is important since this engenders respect and support for the agency. Rules that are outdated, overly complex, or impose requirements without regard to real and measurable safety results should be identified and either changed or repealed. The agency’s effort to collect information on burdens imposed by its regulations is a welcome first step in this process.