Joined: 02 Feb 2007
Location: NM Albuquerque
|Posted: Sat Dec 20, 2008 7:24 pm Post subject: Intro and TOC: RFC Component v. Unit and 3rd Party Testing
|What is an RFC?
An RFC means a "request for comments". Agencies (often government entities) open discussion to the public by requesting comments about the effect of policies they plan to implement. The request for comment (RFC) is usually structured as a series of questions. If you decide to particpate, you can answer all or some of the questions. You may also include comments about questions that should have been asked but were not, and the reasons why these questions apply to the topic.
December 15, 2008, the CPSC issued a Request for Comments (RFC). It is important to respond because the RFC concerns third party and unit vs component testing, two critical areas for us.
1. Comments are due by January 30th.
2. Our internal draft deadline is January 5th.
Because it is important to submit a response to an RFC as soon as possible, our goal is to complete the draft by January 5th. It is important to finish well before January 30 (the due date) because time is needed to distribute the final version across the web since it takes time for it to get around. Anyone is welcome to use our draft as is or modify it to suit their purpose.
Because the eight questions in the RFC are complex, it's easier to discuss each question in it's own thread as best as we can because there is some cross over. This thread is the main document, a sort of "table of contents" to the each question in this forum. Below are links to each thread. Of course, you can start new topics in this folder as long as the topic is related to this RFC.
|The Commission staff invites comments on Section 102 of the CPSIA, Mandatory Third- Party Testing for Certain Children’s Products. The staff requests comments specifically on third-party testing of component parts.
CPSIA section 102(a)(2) imposes testing requirements to support certificates of compliance for “children's products'' as defined in section 235(a) of the CPSIA (to be codified at section 3(a)(2) of the Consumer Product Safety Act). Ninety days after the Commission issues those requirements for a given product or category of products on the rolling schedule specified in section 14(a)(3), the certificate for the product or products in question manufactured after that date must be supported by testing performed by a third-party laboratory whose accreditation has been accepted by the Commission absent the Commission's exercise of its authority to extend such a deadline by an additional sixty days in certain instances. Given the schedule for implementation of the third-party testing requirements, the staff is interested in comments and information regarding
1.How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts of a consumer product versus third-party testing of the finished consumer product.
2.The conditions and or circumstances, if any, that should be considered in allowing third-party testing of component parts.
3.The conditions, if any, under which supplier third-party testing of raw materials or components should be acceptable.
4.Assuming all component parts are compliant, what manufacturing processes and/or environmental conditions might introduce factors that would increase the risk of allowing non-compliant consumer products into the marketplace.
5.Whether and how the use and control of subcontractors would be affected by allowing the third-party testing of component parts.
6.What changes in inventory control methods, if any, should be required if third-party testing of component parts were permitted. Address receipt, storage and quality control of incoming materials, management and control of work-in-process, non-conforming material control, control of rework, inventory rotation, and overall identification and control of materials.
7.How a manufacturer would manage lot-to-lot variation of component parts, in a third-party testing of component parts regime, to ensure finished consumer products are compliant.
8.Whether consideration of third-party testing of component parts should be given for any particular industry groups or particular component parts and materials. Explain what it is about these industries, component parts, and/or materials that make them uniquely suited to this approach
Last edited by Eric H on Sun Dec 21, 2008 10:49 am; edited 3 times in total