Video Clip - Regulations for Textile and Clothing Products, March 2009

Transcript



Note: Views expressed in this presentation are those of the staff and do not necessarily represent the views of the Commission.

Hello my name is Mary Toro. I am with the U.S. Consumer Product Safety Commission. I am the division director for the division of regulatory enforcement in the office of compliance and field investigations. I am sorry that I am not physically with you today but the demands of the new laws that we are beginning to enforce require me to stay close to the office. The mission and obligation of the CPSC is to protect the public from unreasonable death and injury or harm from consumer products. The framework to protect the public is given to us by the U.S. Congress. Their intent is consistent with our mission, to protect the public. We have to work within this new law and find a way to safeguard the public and continue to conduct business. We need to do this in a fair, reasonable and practicable manner. We recognize that you are in business. Our goal is not to negatively impact your business. Our goal is to ensure that consumers, especially children, are safe when they use the products that you manufacture. My job is also to help you understand the requirements of our mandatory standards, to help you to avoid recall when a product doesn't comply with the regulation. I hope that this presentation will give you an understanding of the mandatory requirements that we currently have in place for the regulations of one class of consumer products that we regulate, textiles and apparel goods.

Today I will give you a short overview of the Consumer Product Safety Commission, the impact of imports on product safety, the mandatory standards that we have in place for clothing flammability, children's sleepwear and also a little bit on the Consumer Product Safety Improvement Act. I will also talk briefly about voluntary standards, especially drawstrings on children's clothing and industries responsibilities. The CPSC is an independent Federal regulatory agency created to protect the public from unreasonable risks of injury associated with consumer products. The commissioners are appointed by the President for multi year terms with confirmation by the senate. Currently we have in place one acting chairman and one commissioner.

What is a consumer product? CPSC has jurisdiction over thousands of consumer products. We exclude products covered by other federal agencies such as automobiles that are covered by the National Highway and Traffic Safety Administration. Food, drugs, medical devices covered by the food and drug administration. Firearms, airplanes, boats and pesticides. All other products generally are under our authority, this would include toys, clothing, playground equipment, exercise equipment, just about any type of consumer product is under our preview. The CPSC staff has four concerns that it readily addresses, products that fail a mandatory standard, products that fail a voluntary standard when that failure leads to a defect in the product that may cause a substantial injury such as the strangulation of a child from a drawstring on a hooded garment. And we also deal with products that create an unreasonable risk of serious injury or death. An example of this would be our work with the tip over or rollover from riding lawnmowers and the installation of rollover protection. Often when we find a product that has a problem with its manufacturing we will require that that product be moved toward a voluntary standard or mandatory standard.

There are several actions that CPSC can take when we find a volatile product on the market or a product that presents a defect or a hazard. We can work with industry to develop voluntary standards or issue mandatory safety standards. We can ban products where no standard is feasible. We can work with industry on a voluntary recall or can require the mandatory recall of dangerous or volatile products. We can cease products that violate mandatory standards at the port working with customs. We can seek civil and criminal penalties for violations of section 15 and 37 reporting requirements. Section 15 of the Consumer Product Safety Act requires manufacturers to report to us when they believe that their product may present a hazard or a defect. And section 37 requires manufacturers to report to us when they have claims against them for injuries from a specific product. We also have a requirement or we can take action and educate consumers in the industry regarding the safe use of products or to teach industry about new mandatory rules.

CPSC has five statutes under its authority. The Consumer Products Safety Act, the Flammable Fabrics Act, the Federal Hazardous Substances Act, the Poison Prevention Packaging Act and the Refrigerator Safety Act. Today I'm gonna talk to you about the Flammable Fabrics Act but those statutes all have prohibited acts under the laws. It is prohibited to manufacture, distribute or import any product that does not comply with the mandatory standard or ban under any act the commission enforces. It's a prohibited act to fail to report information as required by section 15B of the CPSA. Under our new laws, under the CPSIA, a failure to certify a product is also a violation or prohibited act and in the near future it will be a violation to fail to include tracking labels when it's appropriate.

I wanted to show to you today this slide that has a number of recalls that CPSC has coordinated with manufacturers and importers. This slide shows recalls of all consumer products under our jurisdiction through 2009. Of course 2009 is only a few months underway so we've only had 181 recalls so far but as you can see each year the numbers are increasing with 2008 being the year of the recall with 563 recalls. This slide shows the number of recalls by country of origin of the product. As you can see the number of products being recalled manufactured in China has risen steadily over the years and while the number of products imported from China into the United States has also risen and is not accounted for in this slide, the number of products is of concern which is what brings me here to talk about mandatory standards and regulations. Many of the recalls represented here are for children's products containing leaded surface coatings. Most of the children's apparel that is recalled is due to strangulation by drawstrings and the failure of flammability standards. I don't have a breakdown of the actual items that are recalled in this graph but the majority of apparel items, I looked at our website and the majority of recalls for children's apparel was for drawstring strangulation hazards.

To address the issue of noncompliant imported goods CPSC increased their involvement with customs and border protection over this last year. And we became involved as a participating agency in the international trade data system automated commercial environment, better known as ACE. This tool gives qualified CPSC staff access to much better information for targeting unsafe consumer products at the port. ACE grows more sophisticated over time and enables us to see goods that have been brought into the country previously and future shipments of those products. CPSC has joint programs targeting unsafe consumer products by class. As I mentioned we can go back after we find a product that has come into the country that looks volatile. We can look at past shipments. We can also look at future shipments. We can conduct joint audits with the customs and border protection and we also work with them with their importer self assessment product safety pilot program. This is the new program that customs is putting together and we're actively involved in that. If it appears that a consumer product can be modified so that it would not need to be refused admission, the CPSC may permit the product to be delivered from custody under bond to give the owner or company an opportunity to recondition their product. If it turns out that the product cannot be modified or the owner and company is not acting satisfactorily CPSC may direct customs to demand redelivery. This happens quite often when a firm will believe that they can recondition a product and then they decide that it's not worth their time or effort to recondition a product and custom will make them redeliver it to them at their cost. If a product enters commerce and it violates a mandatory standard under the authority of the CPSC it can no longer be exported out of the U.S. except for purposes of reconditioning or destruction. This is a new part of the Consumer Product Safety Improvement Act. Previously products used to be able to be shipped back to the country of origin. That is no longer the case. If there is any type of sale involved that volatile product has to be destroyed in the United States.

With my next slide I would like to begin a discussion of mandatory flammability standards for textile products. Today I'd like to cover the standard for flammability of clothing textiles which is 16CFR1610. The sleepwear standards for children's sleepwear, which is 16CFR1516 and 1616 and also quickly touch on the new certification requirements. There is one other flammability standard for wearing apparel that you should know about and that is the flammability standard for vinyl films. That standard covers items such as PVC items that are used in apparel. Things like children's rainwear, umbrella fabric, anything that's got a PVC coating would be subject to that rule, things like disposable diapers, they're all subject to 1611 but it's such a small percentage of the apparel market that I didn't really include that in my slides today. The purpose of the standard of the general wearing apparels standard is to reduce the risk of injury and loss of life and property by providing standard test methods and ridding the flammability of textiles and textile products for clothing use. Keeping dangerously flammable textiles and garments made from those textiles out of commerce. This is a minimal standard and it applies to both adults and children's wearing apparel. In August of 2008 Congress passed the new rules for us under the Consumer Product Safety Improvement Act. One of those rules was the certification requirement that became effective in November of 2008. That rule required that all products were required to meet a current standard needed to have a certification along with that product when it came into the United States. As of February 10th that certification requirement was put on stay until February of 2010. The certification requirement requires that children's clothing be tested by a 3rd party laboratory and then have a certificate issued that that garment or the fabric used to make that garment complies with the wearing apparel standard or any of the other flammability standards that are currently on the books.

There's also a requirement that apparel be checked for lead content and surface coatings and it is limited that those surface coatings and lead content be under 600 parts per million. For example, buttons, snaps, gamut's, zippers and other products that may be metal that are used on apparel must be tested and the manufacturer must ensure that those products contain less than 600 parts per million lead content. That number drops to 300 parts per million in August of this year, 2009. It is required that although a certification requirement, certification statement is not required manufacturers are required to ensure that the products they put on the market do not contain lead above the 600 parts per million currently. In August that number will drop to 300 parts per million lead for the content of any item used on a piece of wearing apparel for children.

Ok we'll go back to the flammability standard. The standard establishes flammability requirements that all clothing textiles used in apparel must meet before their introduction into commerce. The standard provides a method for testing and establishes three classes of flammability performance of textiles and textile products and restricts the sale and distribution of those products that are dangerously flammable. The fabric is tested at a 45 degree angle and allowed to burn its entire length, 5 inches or 127 millimeters. The results of 5 specimens are averaged and a class designated to the fabric based on its flammability performance and surface characteristics. Apparel products are tested in their original state and after one dry cleaning and one laundering. That process is used to remove any finishes that may be adhered to the surface of the textile fabric. This slide has a chart that shows the different classifications of fabric after they've been tested. Fabrics that are class 1 are fabrics that have no unusual burning characteristics and are acceptable for use in clothing. Class 2 fabrics have intermediate flammability and you must use with caution. Generally they have variable flammability results and can get you in to trouble when you use those types of fabrics in certain clothing situations. Class 3 fabrics are dangerously flammable and cannot be used in wearing apparel. If you have a class 3 fabric on the market it is considered dangerously flammable and will be recalled. Generally class 3 fabrics are those fabrics that are made out of cellulosic fabric, cellulosic fibers that have a raised fiber surface that end. Also those fabrics that are very lightweight such as sheer silks and sheer rayon.

I have some examples of those fabrics that I would like to show to you. This garment is 100 percent cotton chenille. It is a raised fiber surface and it is a class 3 fabric. This garment is 100 percent rayon, brushed rayon, also a raised fiber surface. This garment tested as a class 2 class 3. This garment is a plain surface, sheer silk garment which also fails as a class 3 garment. This slide summarizes the classification of fabrics by their burn rate and by their surface construction. As you can see plain surface fabrics have a different criteria then raised surface fabrics and it is based on their burn rate and the time of the burn. The samples are averaged and the results are reported as either a class 1, class 2, or class 3 fabric. 16CFR1610 lists certain fabrics and constructions for exemption purposes from testing. The fabric still must meet the requirements of the standard but years of experience with testing these fabrics by the staff show that they are always class 1 or class 2 and will comply with the standard without testing. What this provides for people for manufacturers is an allowance to certify their product without providing a test report. What you need to do is certify that your fabrics either meet the weight requirements under the first exemption for fabrics weighing more than 2.6 ounces per square yard regardless of their fiber content or if the fabrics were made of certain fiber types those fabrics would also be exempt from testing for certification purposes. You would still have to have some supporting documentation under the CPSIA to show that your fabrics complied with one of these two exemptions to keep you from having to perform a test for certification purposes but this does allow you some guidance on how to meet those criteria. We have copies of the regulation posted on our website which I do have posted at the end of my presentation.

This slide lists several fabrics that are problematic under the clothing textile standard. Typical non-complying fabrics are sheer 100 percent rayon, often made up into skirts and scarves, sheer 100 percent silk scarves, 100 percent rayon chenille sweaters which was like the white sweater that I showed you earlier, rayon nylon chenille blend and long hair sweaters typically have a much longer fiber length on the surface than the one that I showed you, polyester cotton and 100 percent cotton fleece garments such as sweatshirts, generally polyester that is less than 20 percent in a polyester cotton blend do not pass the clothing textile standard and then 100 percent cotton terry cloth robes generally pose a problem. They come in a lot of times as a class 2 fabric with variable test results and oftentimes can present class 3 fabric.

Now I'm going to start talking about children's sleepwear. The purpose of the sleepwear standard was to protect children from the risk of injury from fire when children were unsupervised. The standard requires that children's sleepwear must be flame resistant and not continue to burn when removed from a flame source. Children's sleepwear means any product of wearing apparel, sizes larger than 9 months, intended to be worn primarily for sleeping or activities related to sleeping except diapers and underwear, infant garments and tight fitting garments. So the sleepwear standard lists certain types of garments that are not included in the definition of sleepwear. In 1996 the commission issued amendments to the sleepwear standard because people were petitioning us. They wanted children's infant garments to be exempt from the sleepwear standard because they said infants were never left unattended. When they were left unattended they were usually sleeping in a crib so they generally did not get presented with the same risk of injury that older children did. They were less mobile. So CPSC staff decided to change the sleepwear standard and exclude children garments size 9 months and under from having to meet the sleepwear standards. They do have to meet the general wearing apparel standard which is 16CFR1610 but they no longer needed to meet the more stringent requirements of the sleepwear standard.

We also at that time issued requirements for garments that were called tight fitting garments. These were sleepwear garments that were manufactured to be close fitting to the body similar to what we in the U.S. call ski pajamas or similar to maybe long underwear but they're not long underwear. They are tight fitting sleepwear garments. There is a very strict definition for what those tight fitting requirements are and a manufacturer must manufacture to those requirements in order to have those garments exempt from the testing requirements of the sleepwear standard. Those garments also like the children's infant garments are exempt from the testing requirements of 16CFR1615 and 1616 however they do have to meet the standard for clothing textiles.

As I mentioned in my definition of sleepwear, sleepwear also is defined as any product of wearing apparel such as a nightgown, pajamas or similar related items intended to be worn primarily for sleeping or activities related to sleeping. That definition includes bathrobes or children's robes because the staff believes the robes are items that are worn prior to sleeping or early in the morning when children get up. And we had incidence where children are exposed to flame sources from space heaters and fireplaces and things like that where their garments would ignite and so the requirements for, the sleepwear standard also is applicable to robes. It's also applicable to this class of garments called leisurewear or loungewear. The loungewear for children is considered to be sleepwear. CPSC office of compliance issued a guidance letter in 1996 that was reissued in July of 2008 regarding our enforcement posture on the sleepwear standard as it relates to items marketed as loungewear for children. And I have a piece of loungewear that I'd like to show you so that you understand what I'm talking about. This is an item of loungewear. It generally has a pull tie waist. It's made out of, generally out of flannel sometimes out of a plain weave cotton, 100 percent cotton. This item happens to comply with the sleepwear standard. It's made out of a sleepwear fabric. But oftentimes we will find garments marketed as leisurewear that do not comply. They are made with cotton flannel that is untreated and will burn quite readily when tested to the sleepwear standard. The sleepwear standard requires that both the fabric, the prototype of garments meaning seams and trim and also finished garments be tested to meet the requirements of the standard. I want to repeat that. The sleepwear standard requires that manufacturers test fabric, seams and trim on any prototype and the finished garment in order to manufacture that garment and put it on the market. This is a very stringent requirement and the testing of the fabric and the seams and trim is required to be done prior to mass marketing of that garment.

There seems to be a lot of confusion over what is actually required and we find that many manufacturers test only the finished garment and when that happens and they find a failure in the regulation oftentimes many garments are already in the market that they then have to recall and take out of the market. The standard purposefully required manufactures to test and use only compliant fabric in the manufacturing of children's sleepwear. So I want to drive home that point that it's very important that the fabric that you use in the manufacture of children's sleepwear be compliant with the sleepwear standard prior to the manufacturing of those garments and finished goods. In addition to the tight fitting requirements having to meet the specific sizing requirements in the regulation, in 2000 a mandatory labeling requirement was also developed for tight fitting garments. The label is required to be permanently attached to the neck and read, where snug fitting, not flame resistant. There is also a requirement that a hang tag that gives point of purchase safety information that is yellow in color or a smaller version of the hang tag be used on the prepackaged garment. I have a picture of the yellow hang tag in this slide. There are specific words that must be printed on the label and it must be a specific size. There is a requirement that no additional information other than the required statement be on the label. This picture is a typical item that is of the tight fitting size requirements. It's a two piece, 100 percent cotton children's short sleeve garment, interlock knit, very nice and soft.

This picture is a slide of a person, one of our compliance officers measuring a garment. This is something that we do quite routinely. We pick up garments from the retail or from customs or from manufacturers or importers points of distribution and we check them to make sure that they meet the tight fitting sizing requirements. This is a person testing the waist measurement and also the waist and the wrist measurement and then the last slide is once again the chest measurement and the upper arm measurement. Generally it's a very straight forward measurement and the regulation gives guidance on how to make those measurements.

Ok while I realize that that was just a very short brief summary of the sleepwear standard and what's required under that standard there's a lot of additional information on the consumer product safety commissions website and I recommend that you go there. WWW dot CPSC dot gov and look up the information that we have on children's sleepwear and complying with that standard.

I next wanted to move to requirements for lead in children's products. We have and have had on the books a requirement for lead containing paint used in both paint and in children's goods, children's toys and other articles intended for use by children. That limit was at 600 parts per million and it was based on the total weight of the dried paint film. Currently congress has upgraded our requirements and in the summer of 2009 that level will drop from 600 parts per million to .009 percent or 90 parts per million. That requirement is very stringent and it covers all items that are manufactured for children so any product that uses a screen print or any type of surface coating would be subject to the lead paint rule. Now we know that some decorative buttons that are used on children's garments are sometimes hand painted and those hand paint sometimes contain lead. It's very important that manufacturers test their products and determine the lead content of those surface coatings. Another item that is used often in children's garments that does contain lead are thermal prints and thermal transfers so manufacturers need to be aware that those products cannot contain currently lead above 600 parts per million and in the summer that will drop down to .009 percent. The consumer product safety improvement act requires that children's garments that contain a surface coating obtain third party testing and then supply a certificate that that product does not contain lead paint or lead surface coating.

In addition section 101 of the CPSIA will also require the lead content on all children's products for children age 12 years of age and younger to drop to different levels throughout the year. In February 2009 the level was 600 parts per million. That drops to 300 parts per million in August of this year and then it drops again if technologically feasible and practicable to 100 parts per million in August of 2011. CPSC posted an enforcement policy on the lead content significance and the policy is significance to the textile industry. The textile and apparel industry provided CPSC with a lot of data to show that typically the dyes that are used in the textile industry are not lead containing. However we could not give a total exclusion for all textiles because we know that there are some surface coatings that do contain lead and there are PVC and other types of textile constructions that do contain lead. The CPSC staff has begun to identify classes of products that consistently have lead content below the prescribed limits. This staff is not aware of a single documented case where a product in the following categories contain total lead content above 300 parts per million. The class of textiles identified are dyed or un-dyed fabrics, not including leather, vinyl or PVC, non-metallic threads and trim used in children's apparel and other children's fabric products such as baby blankets. This class does not include such products if they have undergone further treatment that may impair or impart lead onto the surface or into the fabric if they are ornamented with metal, rhinestones or other objects or if they have plastic or metal fasteners which may possibly contain lead. Those items are things such as snaps, gamut, zippers and fasteners or buttons, plastic buttons.

Other common problems found on children's clothing, some zipper pulls and decorative snaps may contain high levels of leads. Decorative snaps that have paint on the covers they may contain lead, drawstrings of course, drawstrings on children's garments present a strangulation hazard which currently is addressed by ASTM voluntary standard which is the ASTM1816-97 the standard specification for drawstrings on children's upper outwear. CPSC has many, many recalls on children's garments with drawstrings. In addition to the requirements on lead there also will be a requirement for tracking labels on children's products and their packages. The CPSC staff is considering writing a regulation for tracking labels but we have not imparted on that path yet. We're still working on some of the other rules that we have to get on the books. But the tracking labels require manufacturers of children's products to the extent practicable to place distinguishing marks on a product and its package that will enable the purchaser to ascertain the source, date, and cohort including the batch, run number or other identifying characteristics of the production of products by reference to those marks. Requires children's products, all children's products and Congress defined what a children's product is and they say that it's any product designed and intended primarily for children 12 years of age or younger and the effective date of that is August 14, 2009.

CPSC's staff is currently looking at different methodologies of imparting and attracting number 2 products. We are aware that it is difficult on many small items to impart a tracking number. One of the new authorities that we have with the Consumer Product Safety Improvement Act is an authority under the CPSA that I thought might be of interest to you. This authority is called the CPSA section 15J. It allows the commission to specify by rule for any consumer product or class of consumer products characteristics who existence or absence shall be deemed as substantial product hazard if the commission determines that such characteristics are readily observable and addressed by voluntary standards and B if such standards have been effective in reducing the risk of injury from consumer product and that there is substantial compliance with such standards. Not later than 60 days after promulgation of a rule under paragraph 1, any person that is adversely affected by that rule can petition the commission under the procedures that we have set forth that the rule might adversely affect them. What this means is that for products such as drawstrings where we have a lot of strangulations because of the drawstring in the hood on children's garments that we could make that voluntary standard that's currently on the books into a mandatory standard just by the fact that we have determined that children's products that have a drawstring present a substantial risk of injury to those children. And this is an authority that we did not have previously. It would not require us to go through the current two step rule making that we need to do to write a rule.

I included some facts about drawstrings on children's clothing because it seems that manufacturers still don't understand that CPSC has taken a position that children's clothing that has an upper hood with a drawstring is considered a considerable strangulation risk to children. Knots, toggles and other decorative or functional attachments on the ends of long, loose drawstrings can catch and snag on other objects. Two hazards associated with such drawstrings are primarily on the hood and neck area drawstrings of upper outerwear. There is a potential for vehicular dragging, a hazard associated primarily with waist and bottom drawstrings of upper outerwear. The consumer safety specification is intended to reduce the risk of drawstrings on children's upper outerwear accessing and getting snagged in various entrapment areas. The staff as I said has done several recalls, 100's of 1,000's of garments taken off the market because manufacturers continue to make garments for children with drawstrings in the upper area, head area and neck area of the children's garment. The role of voluntary standards when reporting defects to the consumer products safety commission, a product that does not comply with all applicable voluntary safety standards may be considered a substantial product hazard for that reason alone. Not all voluntary standards address safety risks or safety hazards but many do and the CPSC always looks at how the voluntary standards are addressed when the manufacturer manufactures a product. CPSC staff regularly seeks corrective action in cases involving products that fail to comply with voluntary standards and a product that complies with all applicable standards is not immune from recall.

As I said many voluntary standards do not address all the safety risks associated with a product. Under section 15 of the CPSA the manufacturer is required to report to us when they believe that a product contains a defect that may present a substantial risk of injury or a defect. Section 15B of the Consumer Product Safety Act requires manufacturers, distributors and retailers to report to CPSC immediately if they obtain information raising safety concerns about a product they make or sell. We believe that manufacturers and importers should report to us if they have information which reasonably supports the conclusion that the product contains a defect that could cause a substantial product hazard. They don't have to know for sure. They can just have information that reasonably supports that the product contains a hazard. And the reporting requirement applies more broadly then the commission's authority to order corrective actions. In the United States the importer retailer has the responsibility of reporting to the CPSC staff information they've obtained that reasonably supports that a product contains a defect which could create a substantial product hazard. I wanted to report to you the penalties that are associated with violations of the prohibited act or violations of the standards under our authority. Any person who knowingly commits a violation is subject to a civil penalty of $100,000 for each violation. This is new with the Consumer Product Safety Act of 2008. Previously each violation was worth a penalty of $8,000 with a maximum cap of 1.825 million. Our cap has been raised to 15 million and criminal penalties including imprisonment are also possible for willful violations. We have pretty hefty penalties now which we didn't have before.

What CPSC suggests you monitor from a manufacturing standpoint, we suggest that manufacturers monitor the returns from their distribution chain, parts that are ordered from their customers, consumer complaints claims, lawsuits and feedback. We also recommend that you look at life testing of a product and if you find that it doesn't meet the longevity that you believe it should have met that you should also be aware of maybe that's something you should report to us. You should also have quality assurance programs and product improvements written into your plans for manufacturing. We believe you should keep track of material changes that take place during the manufacturing process and you should also keep track of retailer reports and retailer feedback. These items are all very important. And CPSC also keeps track of injuries and incidences in our CPSC injury clearinghouse. That information is available to manufacturers. Because CPSC does have reporting requirements we do recommend as a foreign manufacturer that you can report to us. We recommend that you evaluate product failures and determine what could have occurred in a worst case situation. Maybe the report that you get is a minor scratch or something like that but if something would have failed a little bit differently a person could have lost a finger or an arm or something like that. Those are the types of things that you need to address, you need to look at, you need to try to predict the future if you can. Don't assume that an incident without injury means there's no problem. Don't wait to finish exhaustive investigations before CPSC that you might have a problem. And don't assume that a problem will go away by itself because they generally don't. CPSC likes to work with firms with their corrective actions, corrective action is a generic term. It can involve repair of the product, replacement of the product and also can involve repurchase and it can involve all of the things up above. It just depends on how bad the problem is with your product.

If the commission makes substantial product hazard determination for a product that does not have a regulation associated with its manufacturing, it may order the manufacturer distributer or retailer to notify the public of the problem and to take corrective action. The commission may order a manufacturer distributor or retailer to repair or replace the product at no charge to the consumer or refund the purchase price less an allowance for use. The next picture is a picture of our website. I wanted you to look at the homepage and be familiar with it. We have a lot of information on our website. It's a really good tool for keeping abreast of what's going on with the commission, new rules, new regulations, product recalls, items that are of concern to us, new and useful information, we have it all on our website and I suggest that you visit it. As I mentioned, the website is www dot CPSC dot gov. The way you avoid a product recall is to know and comply with the federal standards. You also should know and comply with voluntary standards when they're applicable to the product that you manufacturer. You should have controls in place to control your supply chain and you need to test. You need to know when to test your product and you need to test it. And you need to do production testing as often as you can. You need to monitor the products use. You need to evaluate complaints, injuries and customer feedback. You also need to respond to retailer and importer notifications that they have a problem with your product and you need to report safety issues. One of the requirements that we have with our customs authority is to refuse admission of a consumer product if it fails to comply with an applicable consumer product safety rule. This is a CPSA standard or ban. If the product is not accompanied by the required certificate or tracking label or is accompanied by a false certificate, we can deny entry. If it has been determined to be an eminent hazard in a section 12 proceeding we can refuse admission. And if the product has a defect that constitutes a substantial product hazard we can also have customs refuse admission. If the product was imported by a person not in compliance with inspection and record keeping requirements we can also refuse admission. These are new rules that we did not have in place before and it's given us much stronger authority at the port.

That is the end of my presentation for today. I want to thank you for your attention. I know it was difficult not having a person standing up in front of you and actually being present with you. But I do appreciate the time and the ability to come and talk with you. If you have further information please contact me. I noticed that my email address is not on this webpage, is not on this slide but my email address is mtoro@cpsc.gov or you can contact me through the contact section on the CPSC website. Thank you very much for your attention and have a nice day. Goodbye 

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