CPSC periodic testing rules go into effect this month
March 13, 2013,
Until now, manufacturers were required to do initial testing of their product at a CPSC -accepted lab and to conduct material change testing if they changed manufacturers, designs or used new materials.
But beginning this month, manufacturers of juvenile products will have to test their products a minimum of once a year - even if there have been no changes in the product's manufacturing process.
CPSC Small Business Ombudsman Neal Cohen said the new rule generally means testing at a minimum of once a year for all continuing production. However, Cohen said, conditions exist where testing could be required more often than once a year - say, a product with more complex mechanics or one containing numerous small parts.
In addition, companies must also have a written periodic testing plan that explains how they test, how frequently they test, and how they select representative samples, and Cohen recommends that companies also include a rationale for their choices. Records should be kept for five years.
Some companies may potentially be able to test less frequently - up to once every two years - if they have a production testing plan that is closer to a quality assurance or quality control plan.
"If you're a manufacturer and every two hours you already have procedures in place to pull something off the lines and to check to see if it's within your specs...what we're saying is, ‘That's great. Document what you do, how frequently you do it, why you choose to do it that way, and what actions you take if something doesn't pass. Write it down,'" said Cohen.
Cohen also added that manufacturers should make sure their plans meet the requirements set out in CPSC 's regulation, 16 CF R 1107.
The CPSC does not provide a model periodic testing plan because, Cohen says, "manufacturers know their products best and how best to ensure the continued compliance of their products with federal safety laws."
For more details on periodic testing, visit cpsc.gov/testing.
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