Hong Kong Society for Quality (HKSQ) was one of supporting organizations and about ten HKSQ members participated the seminar. We took a group photo before the seminar.
In the beginning, Prof. KC Ho (Dean, School of Science & Technology, OUHK) gave an opening remark and presented a souvenir to guest speaker.
Group photo was taken with OUHK professors.
Section 1: Overview of CPSC
Mr. John Golden (Attaché, US CPSC) introduced the U.S. Consumer Product Safety Commission (CPSC) Overview firstly. CPSC is an independent federal agency which has established since 1973. CPSC is responsible for consumer product safety function of the federal government. Then Mr. John Golden briefed their mission that "Protecting the public against unreasonable risks of injury from consumer products through education, safety standards activities, regulation, and enforcement."
The organization of CPSC was introduced and Mr. John Golden was belongs to Education, Global Outreach, and Small Business Ombudsman. Then he mentioned US estimated annual losses asociated with Consumer Porducts upto USD 1 Trillion in Societal Costs (where 34,500 Deaths and 36 Million Injuries cases).
The definition of Consumer Product is "... Any article, or component part thereof, produced or distributed (i) for sale to a consumer for use in or around a permanent or temporary household or residence, a school, in recreation, or otherwise, or (ii) for the personal use, consumption or enjoyment of a consumer in or around a permanent or temporary household or residence, a school, in recreation, or otherwise...".
(Section 3(a)(5) of the Consumer Product Safety Act, 15 USC 2052(a)(5))
Some Consumer Products were excluded from CPSC and showed in the following diagram.
Then John described different ways CPSC to prevent injuries and deaths through "Regulations", "Voluntary Standards", "Identifies, Monitors, Analyzes Trends", "Conducts Risk Assessments", "Conducts Research", "Education on manufacturing for safety", "Educates on Safety Use", "Surveillance: Retail, Internet, Ports" and "Investigations, Recall, Compliance". The follow diagram showed the CPSC Voluntary Standards Monitoring.
For Import Surveillance, John introduced Importer Self-Assessment Program in which CPSC staff were working with Customs & Border Protection (CBP) to implement a program that allowed companies to apply for a "low-risk" status. However, the data of CPSC Recalls by Product Origin demonstrated the high port of Recalls come from China. The CPSA provided for three remedies in the case of the recall of a product such as Repair, Replacement and Refund of Purchases Price.
During discussed Best Manufacturing Practices, I was interested in Testing and summarized below.
- Even when testing and certification is not mandated by CPSC, importers and suppliers should make sure that products meet all requirements.
- To avoid problems, samples should be tested randomly, early and often.
- The cost of testing is a tiny fraction of the costs associated with recalls and violations.
Section 2: CPSC requirements for adult and children's clothing
Mr. John Golden introduced Flammable Fabrics Act (FFA) through different regulations included Clothing Textiles (16 CFR Part 1610), Vinyl Plastic Film (16 CFR Part 1611), Children's Sleep wear (16 CFR Part 1615/1616), Carpets and Rugs (16 CFR Part 1630/1631), Mattresses and Mattress Pads (16 CFR Part 16132), and Mattress Sets (16 CFR Part 1633). The testing summary was shown in the diagram below.
Drawstrings are considered a substantial product hazard. It applied to drawstrings on upper out wear, jackets and sweatshirts. In order to avoid entry problems with the US government (Customs and CPSC), foreign manufacturers should comply with both CPSC Regulation (mandatory) and Private Sector Standards (consensus voluntary standards).
Mr. John Golden pointed out four types of product safety concerns included Product fails to comply with a mandatory safety standard or ban under the Acts, Product fails to comply with voluntary standards relied upon by the Commission, Product contain a defect which could create a "substantial product hazard", and Product creates an "unreasonable risk" of serious injury or death. The overview of US Toy Regulations were discussed:
- Age grading of toys
- Requirements for Toys under the Federal Hazardous Substances Act (FHSA)
- Mandatory Toy Standards ASTM F963-11 (updated and effective on June 12, 2012) and ASTM F963-07
- Additional requirements under the Consumer Product Safety Improvement Act (CPSIA)
The following diagram showed different limits on Lead, Phthalates, etc in Children's toys and clothes.
There are four types of third party testing which are accepted by the CPSC to conduct testing on consumer products using approved test methods in accordance with established federal safety standards:
- Initial third party testing (also called certification testing);
- Component part testing;
- Material change testing; and
- Periodic testing for continued production
John said all non-exempt materials must be third party tested by a CPSC-accepted laboratory (on a test-by-test basis). (www.cpsc.gov/labsearch)
Section 4: Imports of Consumer Product Under CPSC Jurisdiction
John shared many import data from 2003 to 2012. China import is dominant.
Reference:OUHK - http://www.ouhk.edu.hk/WCM/?FUELAP_TEMPLATENAME=tcSingPage&lang=eng
HKSQ - http://www.hksq.org/
CPSC - http://www.cpsc.gov/cpsia
For New Certification, Testing, and Other Requirements - http://www.cpsc.gov/en/Business--Manufacturing/International/English/