Is the Library Hazardous to Your Health?
09-30-2009
By Dave Schmeltzer
By now we all understand that the CPSIA outlines new regulations and standards for lead paint, coatings, and ink used in toys and other products intended for use by children. Or do we? Where does the line get drawn? Are DVDs and storage media devices subject to the same standards as toys and other products intended to be used by children? What about library books?
Unsuspecting companies and industries may be at risk for an unfortunate surprise when CPSC regulators come knocking at the door.
It is critical that each industry that could foreseeably target children as consumers take a good, hard look at the new guidelines. You might fall under these regulations and not know it, and be subject to the fines and penalties that apply.
Here’s my advice: work with your industry associations regarding concerns about the CPSIA. They have already been requesting clarification on behalf of their members and are expecting answers in the coming weeks. Several associations are even lobbying Congress to ensure they get the clarification they need.
The Media & Entertainment Services Alliance, the American Apparel and Footwear Association, and the American Library Association are just three of the groups seeking clarification from the CPSC about the extent to which the federal law applies to their industry. And understandably so – everyone is trying to get prepared for the new requirements in order to protect consumers from harmful products and their business from increased penalties associated with noncompliance.
Each issue should be considered by asking two questions. First, is the product covered? And second, what is the exposure risk?
The good news is the CPSC is listening. They have received and are reviewing the vast number of proposals for clarification of the rules. Likewise the Commission is receiving a number of “frequently asked questions” that they are looking to answer. We can anticipate a rule to be proposed in mid-November that should help clarify some of the issues, including the economic impact of the regulations and unintended consequences of the Act.
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.
[...] is always refreshing to hear fruitful discussion that focuses on the preparation and solutions to CPSIA issues. We commend the panelists in this session and couldn’t agree more with their [...]