JPMA Testifies On CPSC Priorities
Wednesday, June 15, 2016
Posted by: Kathleen Chaplick
Interested persons, including JPMA staff, presented comments to the Consumer Products Safety Commission (CPSC) concerning the CPSC agenda and priorities for FY 2017 and FY 2018.
Statement of Mark S. Fellin, MPS, Director of Regulatory & Legislative Affairs, JPMA, Before The U.S. Consumer Product Safety Commission on Agenda and Priorities FY 2017 and/or 2018
Thank you Chairman Kaye and Commissioners for the opportunity to provide testimony on your priorities for Fiscal Years (FY) 2017 and/or 2018. The Juvenile Products Manufacturers Association (JPMA) has a long and proud history of ensuring that juvenile products are built with safety in mind. JPMA members, who comprise parents, grandparents and caregivers, design products that help parents care for and protect their children. As an industry, we personally understand the importance of ensuring that our children are safe in all environments and that parents and caregivers are educated about the importance of juvenile product safety and best practices when choosing and using products for their babies and children.
On behalf of the JPMA members, I have the honor of submitting and presenting the juvenile product industry’s perspective of the ongoing working relationship between our industry and the CPSC and to provide our suggestions for priorities in the upcoming fiscal years. Since 2012, I have acted in the role of Director of Regulatory and Legislative of Affairs for JPMA. JPMA has a tremendous appreciation for the work CPSC has done since the implementation of the Consumer Product Safety Improvement Act (CPSIA) and related amendments thereto. Our association has a long history of working with state and federal governments to advance JPMA’s core mission to be an information source and to provide leadership for all stakeholders related to the production and safe use of infant products.
CPSC’s engagement with all external stakeholders, including manufacturers, retailers, consumer advocates and safety experts, is key to the agency’s ability to fulfill its safety mission. Regulated industries should be viewed as partners in safety as they have vital information on product specifications, consumer behavior, global supply chains business practices and the real-life impact of regulations on businesses. Consistent stakeholder engagement will aid the CPSC in making better informed decisions and rulemaking, help guide the retroactive review of inefficient and burdensome regulations and, perhaps most important, address emerging safety risk and hazards. We believe this engagement should be ongoing and formalized. Therefore, we are supportive of the development of Federal Advisory Committees to address ongoing issues that have a significant contribution to CPSC’s mission: import surveillance, recall effectiveness and information collection/management.
My testimony, on behalf of JPMA, will focus on four areas: (1) Maintaining flexibility and openness as it relates to Section 104 of the CPSIA, more commonly referred to as the “104 rules” and CPSC staff involvement throughout the ASTM process; (2), initiate rulemaking on JPMA’s crib bumper petition to adopt the ASTM standard; (3), properly allocating resources to measure and evaluate recall effectiveness; and (4) continuing to look at ways to reduce third party testing burdens placed on manufacturers and ensure resources are available to industry.
Read full testimony here.