Expert Recall

As the industry leader in recall logistics and regulatory compliance for consumer and juvenile product recalls, ExpertRECALL is pleased to share with its readers exclusive interviews with thought leaders on issues of critical importance to the recall space. In light of recent consumer, juvenile and infant product recalls, we interviewed Mike Dwyer to discuss what juvenile products manufacturers are doing to protect consumer safety and prepare for changes in CPSC regulations.

Mr. Dwyer is the Executive Director of the Juvenile Products Manufacturers Association (JPMA) where he manages the day-to-day operations of the organization. In that role, Mr. Dwyer acts as staff liaison with the Board of Directors and all committees and task groups. Additionally, he acts as the liaison with retailers and is responsible for maintaining relationships with third party organizations such as the Consumer Product Safety Commission (CPSC), American Society for Testing and Materials (ASTM) and National Highway Traffic Safety Administration (NHTSA). As the Executive Director, Mr. Dwyer also provides oversight of all government affairs and regulatory activities to JPMA members and represents the Association before government and international bodies.

As a husband and father of three, Mr. Dwyer spoke with us about both the parental concern for product safety and the concerns of the juvenile product industry.

ExpertRECALL: The CPSC is working to provide clarification of the Consumer Product Safety Improvement Act for manufacturers and retailers. What are JPMA members most concerned about?

Mike Dwyer: First off, I’d like to be clear that JPMA members have supported the Consumer Product Safety Improvement Act from the very beginning. However, the unintended consequences of the legislation have been a burden to many and catastrophic to others. Manufacturers are currently and have been working diligently to get a complete understanding of the new law and the impact on their business. First and foremost, manufacturers want to ensure that consumers, retailers and other stakeholders have an understanding of the new law and how it affects them in the buying decisions they make.

Secondly, CPSIA and regulatory compliance are driving up the cost of doing business for juvenile product manufacturers and forcing some manufacturers to rethink their product lines. Some smaller manufacturers are closing their doors because they cannot afford many of the overly burdensome compliance provisions and unintended consequences of the legislation. Regulatory issues will materially raise retail price points in a down economy. In fact, in 2008 alone, millions of dollars were invested by companies for additional testing and new technologies in order for them to be in compliance with CPSIA, when they were already in abidance with current mandatory regulations and voluntary standards.

ExpertRECALL: There have been several juvenile product recalls in the past few months. What do you want consumers to know about the recent flurry of recalls in the industry?

Mike Dwyer: When a recall is announced, it’s important for parents NOT to panic. Get the facts on why the recall occurred, how it affects them, and what to do about it. Additionally, when products are tested, they are assembled and used in accordance with the manufacturers stated intent as embodied in the assembly and use instructions. If the instructions are not followed, risks associated with use of any product may be exacerbated. Not all recalls occur because of a violation of a regulation or product standard. In addition, recalls do not account for certain factors typically not measurable in a lab, such as wear and tear over time.

Finally, many of the recent crib recalls have been as a result of use of inappropriately assembled or secondhand cribs purchased from yard sales or thrift shops. This is a major concern because secondhand cribs often do not include the proper hardware or may include substitute hardware, and may not include the assembly instructions. Also, lost in all of the media coverage of this most recent crib recall, is the fact that of the 4,700 or so incidents involving sleep environments and children each year, as much as 80% involve parents and care givers putting their children in an unsafe sleep environment (on the floor on pillows, co-sleeping, etc.). Properly assembled, functional cribs remain the SAFEST place for a baby to sleep. Opinion leaders and others should take care to stress that point even if a particular crib model is recalled.

ExpertRECALL: With consumer safety top of mind among elected officials and the American public, what are JPMA members doing to resolve these recalls and protect consumers?

Mike Dwyer: Product safety is the top priority among manufacturers in this industry. If it wasn’t, frankly, they shouldn’t be in the juvenile products business. JPMA is dedicated to the development through ASTM of effective safety standards and promoting infant safety and well-being, wherever there are defined risks. Juvenile product manufacturers have worked for many years with their competitors, the CPSC and a variety of consumer advocates by engaging in the development of voluntary standards for juvenile products through ASTM.

The sole purpose of the activities of these groups is to address emerging hazards and improve product safety. These groups work together to develop effective consensus standards. One example of these efforts is an 84% and 89% reduction in fatalities due to the establishment and effectiveness of ASTM Standards for baby walkers and cribs, respectively, according to CPSC testimony at a 2007 Senate hearing. JPMA and our dedicated members have been a driving force behind the development of effective consensus standards and a supporter of the ASTM process for juvenile products since the outset. Without being required, JPMA developed and implemented a Certification Program so manufacturers would have a clear path to assuring compliance with product standards and consumers would have a tool to distinguish products that have samples independently tested to verify compliance to standards.

Stericycle ExpertRECALL™ is the industry leader in recall logistics and regulatory compliance for consumer product, pharmaceutical, medical device, juvenile product, and food and beverage recalls. ExpertRECALL’s professionals are experts in recall management who can help you streamline the entire product recall process.