The Stericycle ExpertRECALL™ team recently had the pleasure of attending the Juvenile Products Manufacturers Association’s (JPMA) Annual Legislative & Regulatory Summit and Membership Meeting in Washington, D.C.

During the event, we were honored to introduce Consumer Product Safety Commission (CPSC) Chairman Inez Tenenbaum. Her keynote speech not only highlighted the important role companies like ours play in implementing recall programs, but also addressed several issues currently affecting the juvenile products industry, including:

• Industry and retailers’ positive response to the implementation of CPSC’s new mandatory crib standards;
• The challenges of soft bedding, which parents have been told to avoid due to sudden infant death syndrome (SIDS);
• Ongoing work to spread the word on rules required by the Danny Keysar Child Product Safety Notification Act, in which manufacturers must provide consumer product registration forms to facilitate recalls of durable infant and toddler products; and
• The one-year anniversary of SaferProducts.gov, the first publicly available government-sponsored consumer product safety information database website.

Tenenbaum also spent time reviewing CPSC’s safety agenda for the coming  year as the agency continues on its quest to become the global leader in consumer product safety.  High on CPSC’s agenda is a series of projects aimed at advancing consumer protection. These projects address potential safety hazards related to several consumer products including portable gas generators, recreational off-highway vehicles and upholstered furniture.

As a member of JPMA, we find significant value in attending these product safety conferences as it greatly enhances our understanding of what is happening in the industry and allows us to anticipate future trends. Our team was especially pleased to hear CPSC applaud the industry’s response and participation in the agency’s recent safety-related initiatives. As CPSC continues to focus on safety prevention, those within the industry would be well-advised to keep apprised of any new regulations and ensure that all corporate policies and procedures reflect future guidelines.

Did you attend this informative JPMA event? What were the main points that you took away from Tenenbaum’s remarks? Will you be instituting any changes in the way you do business as a result of information gleaned from the conference? Your comments are welcome below.

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.

Beginning June 28, 2011, all cribs sold in the U.S. must meet the new federal requirements set by the U.S. Consumer Product Safety Commission (CPSC). The new regulations were introduced in response to a long list of safety complaints that forced crib manufacturers across the industry to put their recall management to the test over the past decade.

In the past four years alone more than 11 million cribs have been recalled from the marketplace. And the new federal requirements hold companies accountable for the safety of cribs, bassinets and other children’s sleep products.

Since 2000, there have been at least 32 cases of infant suffocation attributed to detaching drop side rails. As a result, new CPSC requirements include making hardware stronger, improving mattress support durability and prohibiting traditional drop slides. Immobilizers and repair kits are no longer allowed as a solution to the drop side crib problem.

These new rules apply not only to new cribs, but also require child care centers to replace old cribs with cribs that meet the new compliance standards. And it is now illegal to sublet, lease, resell or even offer for use any crib that does not meet the CPSC’s new stricter standards.

These new guidelines apply not only to cribs manufactured in the U.S., but also to those that are imported here for sale. To protect themselves against product liability and recall risk, manufacturers must now ensure that safety testing of cribs that will be sold in the U.S. is more rigorous, no matter where the products are being manufactured. With a large portion of cribs sold in the U.S. originating in Chinese manufacturing facilities, the CPSC is taking a greater role in monitoring the safety of all products, cribs and sleep products included, that are coming from the country.

Private firms are already stepping up to the plate to ensure that foreign made products meet the CPSC standards. For example, SGS North America Inc, a division of the world’s largest safety and inspection company, recently announced that their Shanghai lab has become the first Chinese testing facility certified to provide crib safety testing services in compliance with the latest CPSC rules. According to an SGS press release, “the accreditation provides local testing resources for Chinese factories that produce full-size and / or non-full-size cribs destined to be sold in the U.S.”

The new CPSC regulations are a signal that compliance and safety will not be compromised, even in an increasingly global marketplace where goods made in one country are often sold in another. As a spokesperson for SGS pointed out, “having testing services near the point of manufacture is going to be essential in order to avoid delays in getting new models to market.” Working together with federal and private organization,s your company can not only survive these regulatory changes, but also thrive in the U.S. marketplace.

Manufacturers in the U.S. and abroad should be getting ready to meet these new requirements. The best way to avoid a costly recall is to make the extra effort to ensure that your safety and compliance measures are above and beyond those mandated by the regulatory agencies, especially when children’s products are involved.

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.

With so many high profile children’s product recalls, especially crib and toddler bed recalls, over the past year, it should come as no surprise that regulators have now approved new mandatory safety standards for toddler beds. These new standards are just the latest move by increasingly active product safety regulatory bodies to protect consumers, yet another regulation for which manufacturers of children’s products must be prepared.

The latest safety standards will require all toddler beds to include separate warning labels for entrapment and strangulation hazards. In addition, the beds themselves must have a guardrail at least five inches above the bed’s mattress, and the spindle and slat strength must pass the same tests required for cribs.

Even though the new safety standards will not take effect until six months after they are published in the Federal Register, manufacturers should waste no time in ensuring full compliance. As countless past recalls have taught us, resisting change and attempting to delay consumer protection initiatives can backfire, whether in the form of a recall, litigation, or serious brand damage.

With the spotlight continuing to shine on consumer safety and regulatory enforcement, manufacturers must adapt. Just because regulators are now requiring certain physical standards does not mean manufacturers should stop there. Going beyond compliance and creating the industry gold standard for safety can not only protect a company from regulators and litigation, but can also prove a valuable marketing tool for convincing safety conscious parents to buy your product instead of a competitor’s.

As always, the best way to effectively manage a recall is to avoid it in the first place. Unfortunately, just complying with the most basic regulatory standards is not always sufficient to avoid a recall. Going beyond basic compliance can yield tremendous benefits, both in protecting and boosting your bottom line.

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.

Consumer Product Safety Commission Chairman Inez Tenenbaum offered welcome news to the makers of baby cribs, toys, strollers and other children’s products recently when she asserted that her federal regulatory body will take special care to make its decisions based on science, not politics, and that she looks forward to a continued partnership with the industries she regulates. Not only will this approach affect whether companies need to make modifications to the products they have manufactured for years, but it most assuredly will impact the recall process and could make the difference between whether a manufacturer must manage a recall.

Tenenbaum, who has been at the helm of the CPSC since July, 2009, made her remarks in the keynote address of the Juvenile Products Manufacturers Association Summit Meeting in Washington, D.C., in mid-March.

“I come before all of you this afternoon in the spirit of partnership—a partnership aimed at restoring the confidence of parents in the products they buy and rely on for their babies and toddlers,” Tenenbaum told the JPMA Summit, which I attended with dozens of other sponsors and industry representatives. “We at the CPSC are committed to ensuring that we base our regulatory actions, including product recalls, on the science and facts related to the issues that come before us.”

JPMA Executive Director Michael Dwyer noted after Tenenbaum’s speech that manufacturers must on their own address widespread safety concerns, regulatory issues, and “the demands of today’s supermoms who want it all.” But the fact that Tenenbaum – serving in a presidential administration reputed to be cracking down unreasonably on industries and companies for regulatory infractions – is offering to partner with an industry under such great scrutiny represents an opportunity that the JPMA and its members cannot afford to miss.

As members of the JPMA well know, product safety continues to be the number one consumer issue their industry faces. Parents turn to federal regulators for protection when they feel manufacturers aren’t looking out for their well-being, or might be putting profits ahead of safety. By taking advantage of Tenenbaum’s olive branch and working openly with the CPSC to safeguard consumers and their families, the children’s products industry can greatly improve its stature over the next few years.

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.

Millions of children’s products containing unsafe levels of cadmium have been recalled over the past nine months, and now the U.S. Consumer Product Safety Commission (CPSC) has announced that it plans to allow companies to enforce their own voluntary cadmium standards. But the story probably won’t end there. While the CPSC does not currently have strict cadmium limits in place for consumer products, it is never too early to adjust your recall planning to accommodate possible new regulations that may impact your recall management in the future.

Cadmium came under scrutiny by federal regulators when testing revealed very high levels of the chemical in millions of children’s toy and jewelry products found at chain stores and popular restaurants, including Wal-Mart, McDonalds and Claire’s.

CPSC Chairman Inez Tenenbaum, who once called cadmium “the new lead,” said recently that manufacturers should take a “migration approach” in creating voluntary limits on cadmium content. That means manufacturers should take into account the effect their products might have on a child if they were ingested over 24 hours. The CPSC is also calling for more rigorous cadmium testing measures.

If your products contain cadmium, you need to understand what all this will mean for your business. As the industry puts new standards in place, your company should establish internal procedures to monitor cadmium levels in the products you manufacture.

If the CPSC asks for your input, you need to be prepared with your recommendations and history of cadmium in your products. While disclosing such information may result in a recall, you need to be completely candid with regulators now rather than face even tougher scrutiny from lawmakers and consumers down the line.

Just as important, you need to know ahead of time how the new regulations will impact your current and future inventory. You want to be prepared well in advance to make necessary manufacturing adjustments and announce any recalls so that consumers and regulators see your company as responsive and responsible. While managing a recall is certainly not a process you want to be involved in on a regular basis, making an announcement before new standards are in place could actually generate consumer loyalty from parents concerned about children’s safety.

The CPSC will ask consumer groups and trade associations to help develop cadmium standards. With the industry’s input, these standards should be fair and reasonable. By participating in this open discussion about cadmium content standards, you will be the first to know how the proposed standards will impact your business and what changes you will need to make to comply with those standards with a minimum amount of disruption to your business.

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

Have you ever considered just how many regulatory agencies have the power set standards and control what consumer products stay on store shelves? Did you know that Environment Protection Agency (EPA) is one of them?

While at first glance it may not seem that the EPA would have a role in the regulation of consumer products, the agency is currently considering getting involved in regulating cadmium in toy jewelry and other products. Concerned that the Consumer Product Safety Commission (CPSC) has been slow to regulate cadmium — recently called the “new lead” by the CPSC chairman — the EPA recently announced that it will set limits for how much cadmium will be allowed in toy jewelry unless the CPSC acts soon.

The EPA is currently working side-by-side with the CPSC to determine safe limits for cadmium. But the EPA is apparently frustrated with how long it is taking to put new regulations in place. A few months ago, retailers including Claire’s Boutique Inc. and Dress Barn Inc. recalled a number of jewelry items after the CPSC discovered that they contained cadmium. A few months earlier, McDonald’s Corp. offered customers a $3 refund to return glasses promoting the new Shrek movie when it was discovered that they had been decorated with paint that contained cadmium.

Since April, the CPSC has been saying that it plans to take action on cadmium “as quickly as possible.” But to date, nothing has happened. But the EPA’s most recent statement is now putting the consumer agency in the hot seat, and that could result in a significant number of new recalls. We often don’t remember that the EPA has been involved in the recall process in the past for pesticides and even motor vehicles that failed to meet emissions standards.

This is an important cautionary note for producers, importers and processors who don’t follow every regulatory agency closely. Sometimes, these agencies will take action beyond what you would usually expect. Failing to pay attention could result in a recall for a safety violation you never knew existed.

Understanding how each regulatory agency can influence your business practices is crucial in taking the necessary steps to always be prepared for the next potential crisis. In order to get ready for the changes coming, make sure you allocate the proper resources to updating and testing your recall readiness plans.

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.

The recent recall of more than two million baby cribs by Evenflo Co., Delta Enterprise and five other children’s furniture manufacturers has parents once again wondering if their children are at risk every time they put them down for a nap or a night’s sleep. These recent additions to the crib recall list bring the five year crib recall total to more than 9 million units. No wonder the media are buzzing. As we hear more and more about crib recalls, there is a real concern that consumers are starting to ignore repeated recall announcements, making recall communication and recall compliance even more challenging.

One of the biggest challenges manufacturers and retailers face when recalling a product is recall notification. Communicating with retailers and consignees is hard enough. But getting your message through the clutter and communicating with consumers is the critical step in achieving an effective recall. Some of the most difficult recalls to manage are those in which the products are already in consumers’ homes. So how do you make sure your message is heard and that affected consumers will respond?

Manufacturers should contact consumers at the personal level whenever possible. For example, any consumer who is on record as purchasing one of the recalled cribs should be contacted directly.

It is also helpful to offer an enticing rebate or reward as part of the recall remedy. Consider compensating consumers not only for the crib itself, but also for the inconvenience of responding to the recall.

As Storkcraft learned at the end of last year, managing a product recall requires a vigilant team that is always ready to respond to the inevitable flood of calls, e-mails, and website visits from parents concerned for the safety of their children. It is important to ease consumers concerns and fears quickly so that you can maintain trust and regain business once the crisis has passed.

But when it comes to drop-side cribs, manufacturers may not need to worry much longer about communicating with consumers or managing the crisis. The Consumer Product Safety Commission (CPSC) plans to issue new crib safety regulations by the end of the year. Meanwhile, state regulators aren’t waiting. The New York State Legislature has already passed a bill banning drop-side cribs and sent it on to the Governor.

Manufacturers need to understand that the CPSC could ban drop-side cribs at any time. Are you prepared to announce an immediate recall and remove from commerce all drop-side cribs that remain in your manufacturing and distribution facilities across the country? Recall plans aren’t just for an occasional recall.  Having in place a recall plan that outlines your recall logistics and procedures can help you effectively remove any product from commerce at any time.

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.

More than 18 months after the Consumer Product Safety Improvement Act of 2008 (CPSIA) became law the Consumer Product Safety Commission (CPSC) is still working to implement the new rules mandated by the Act. While it may sometimes seem as though the mainstream media have long since forgotten about the CPSIA, its impact on manufacturers and retailers is still coming into focus. And manufacturers would be wise to keep in mind that the Act is a real concern. If you aren’t careful, you may find yourself in hot water for not complying with the new regulations.

As we mentioned earlier this year, one of the CPSC’s top priorities for 2010 is to ensure a safe sleep environment for babies and toddlers. Now the Federal Register has published proposed new rules and safety standards for toddler beds – a recent development that has the potential to greatly impact the infant and children’s product industry.

The proposed rules follow Section 104(b) of the CPSIA, which requires the CPSC to determine consumer product safety standards for all durable infant and toddler products. According to the Act, the standards must be the same as, or more stringent than, voluntary industry standards based on the CPSC’s determination of what requirements are required necessary to further reduce the risk of injury. Specifically, the proposed safety standard for toddler beds would address entrapment hazards as well as component failures of the bed support system and guardrails.

These proposed rules serve as a reminder that the CPSIA continues to be interpreted and implemented and will increasingly impact you as a manufacturer. So how do you make sure that you stay in compliance with both voluntary and regulatory standards?

First, make sure you are engaged in industry groups and associations that can help you understand and adhere to the standards being established for your products. These trade groups are attuned to proposed legislation and regulatory standards, and can help you interpret their impact on your company. Some industry associations, such as the Juvenile Products Manufacturers Association, will even certify your products, providing you with a seal to use on your products and sales materials. When you comply with these voluntary standards, you assure consumers of your commitment to safety.

Second, closely monitor the Federal Register and news from the CPSC for new developments. As the CPSC continues to sift through the new law, you can expect to hear more about proposed rules, new standards and increased penalties for noncompliance. For example, at the same time the CPSC proposed rules for toddler beds, the agency issued a notice of proposed rulemaking for safety standards for bassinets and cradles.

Finally, when you hear about proposed rules that impact your business, take part in the public discussion about how those rules would work and what impact they would have on your business. According to the CPSC docket on toddler beds, comments on the proposed safety standards for toddler beds are due July 12, 2010, and can be submitted online. Manufacturers are also invited to submit comments on the proposed rulemaking for bassinet and cradle safety standards. Get involved and make your voice heard.

But most importantly, be prepared.

New rules that may result from the CPSIA could put your company at greater risk for a recall – or worse. Be sure you understand the new standards before you face a recall. And when you manage that recall, be certain your team can execute the recall process effectively. Or risk facing the sharpened teeth of the CPSC.

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.

First there were crib recalls. Then it was stroller recalls and concern about baby slings used to transport and carry infants.  Now the latest infant product recall to hit the news involves 1.2 million Graco high chairs – the product parents and caregivers use to keep their children safe while they eat.

In the last several months, significant safety concerns have been raised more and more often in more and more areas of everyday life, especially the lives of our children.  This high chair recall is yet another example of the ever increasing vigilance and commitment of the Consumer Product Safety Commission. In this environment it is critical for manufacturers to have a recall plan in place so they are prepared to effectively manage a recall when the alarm sounds.

As I discussed with CNNMoney.com, the most important thing Graco needs to do now is make absolutely sure their remedy is effective. That also means making sure consumers are informed of the recall, that they understand whether the product they own is affected, and that they are provided with an appropriate solution. As a manufacturer, always be sure that your messaging is clear and consumers understand what they need to do to protect themselves and their children.

And when you promise a repair kit, make sure it works, and make sure you can deliver. The quicker and more effectively you can ease consumer fears, the sooner your customers will feel safe, and the more likely they are to trust your products in the future. 

You may think you are in the high chair business. But when an incident like this occurs, you are really in the consumer safety business. And you must always manage with that in mind.

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.

The Consumer Product Safety Commission announced on December 24, 2009, that the agency voted unanimously on registration requirements for durable infant or toddler products. While we’ve previously mentioned the new rule on this blog, as recall experts we want to ensure it receives the attention it deserves. This new rule creates one more path to follow to achieve regulatory compliance, while also affecting the entire recall planning and communication process.

So what does the rule entail? This rule will affect 18 categories of infant and toddler products including cribs, chairs, play yards and activity centers. According to the CPSC, the final rule requires manufacturers comply with the following:

1. Provide a postage-paid consumer registration form with each product;
2. Keep records of consumers who register their products with the manufacturer; and
3. Permanently place the manufacturer’s name and contact information, model name and number, and the date of manufacture on each product.

The final rule will also specify the text and format for the registration form as well as establish requirements for online product registration.

We agree with the CPSC’s assessment that this will help companies better communicate with consumers about recalled products – but it’s no panacea. Many of the big ticket nursery items this rule affects, like cribs and strollers, are often passed down from one generation to the next without assembly instructions or the appropriate product warnings. This leaves registration cards outdated, or possibly missing.

Just because your company adheres to this rule – which it must in order to be compliant – doesn’t mean you’re ready for a recall. Recall risk is still real. This new rule is only one of many that you must adhere to before, during and after a recall event to ensure you quickly and effectively protect your customers and close out a recall.

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.