Product safety has become much more risky – and not just for manufacturers of consumer products. The Consumer Product Safety Commission (CPSC) has announced its intent to use its increased civil penalty authority ($15 million cap in the 2008 amendments), insisting on penalties over $5 million routinely for companies that report voluntarily, but “too late,” in the view of the staff.
Penalties have been demanded not just from manufacturers, but also from importers and retailers.
Health Canada is aggressively implementing its 2012 law, insisting on reports of “incidents” within two days by every party in the supply chain (including distributors, importers and retailers), and retention of sales records for all products sold in Canada for six years.
Both agencies assert jurisdiction over products that present risks to consumers (like escalators and wiring in office buildings), not just products you can buy at the store or on-line for your personal use.
In August, 2011 the European Commission voted to implement a complaint database like the CPSC’s SaferProducts.gov, and has just recently released a risk assessment process that all manufacturers must use to determine if a product should be recalled.
Lee L. Bishop, formerly product safety and compliance counsel for GE’s appliance, lighting, and industrial products businesses and now counsel to Miles & Stockbridge, will present a primer on these and other regulatory requirements.
Timothy L. Mullin, Jr., principal of Miles, will discuss recent CPSC penalty actions and the CPSC’s new approach toward penalties.
Credits: 2 Prof. Practice, Transitional/Non-Transitonal NY CLE
State: New York
Lee M. Cushman Phone: 203-461-9004 E-mail: