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Product Safety: The Focus is on Children

By Jay Treadway

September 24th, 2009

Being part of a larger organization has it’s advatanges. Since 2006 Treadway Graphics has been associated with Geiger, a company that is headquartered in Maine. Geiger has hundreds of sales reps around the country and publishes the Farmers’ Almanac.  

Wayne Greenberg is a Geiger rep in Florida and he has become an expert in the product safety issues that are concerning a lot of people in our industry. Last week Wayne updated all of us with the following:

I have been watching the issue of product safety, the directives of the Consumer Products Safety Information Act (CPSIA), and the actions of the Consumer Product Safety Commission (CPSC). What a challenging minefield? I want to share what I have observed, what many of our suppliers are doing, and what problems this creates for us.

The critical issue revolves around our products and their relationship to children. Basically, special safety regs kick in when promotional products and kids are put in the same sentence. These requirements include testing, special labeling and higher standards regarding how the products are made (e.g. lead content).

The rules come into play when:

1. A product is likely to be used by a child 12 and under, or

2. A product is specifically designed for use by a child 12 and under, and/or

3. A product is decorated with a logo that makes it intended for a child.

Taken individually, these elements are confusing enough. Taken together, they encompass perhaps 2/3 of the products in our industry. And the CPSC has moved the target several times over the past 6 months, with each move making it more difficult for us to interpret.

You might think that a supplier could avoid expensive testing and legal liability by labeling their products as “not primarily designed for Children 12 and under” or “not for use by a child 12 and under.” Even though some companies might do this, they still need to consider the following 4 “pillars” in determining if a given product falls under the child safety regs:

1. A statement by a manufacturer about the intended use of such product, including a label on such product if such statement is reasonable.

2. Whether the product is represented in its packaging, display, promotion, or advertising as appropriate for use by children 12 years of age or younger.

3. Whether the product is commonly recognized by consumers as being intended for use by a child 12 years of age or younger.

Commentary: This brings a little common sense to a determination. A product like a coffee mug or inexpensive watch that might be used by people of all ages does not necessarily become a regulated child’s product.

4. The Age Determination Guidelines issued by the CPSC staff in September 2002 and any successor to such guidelines.

Commentary: The CPSC can and does “age grade” a product. If using the guidelines an expert determines a product “grades out” to be for 6 to 10 year olds, it is a child’s product.

A product liability issue pulls in every one in the supply chain, including our customers. It is up to us to know who the product recipient will be and who beyond that will ultimately use the product.

Thanks to Wayne and others in the Geiger organization we are doing a lot to make sure the products we sell do not cause issues for our customers. As you can see by the product safety page on the Geiger website we are determined to make sure the products we sell our customers are safe.  

I feel a little better knowing there are people in my company dedicated to making sure the products we sell are safe for children. Most of my customers deal directly with kids; and many of those kids are under 12. I want my customers to know that we are working diligently behind the scenes to insure they receive only safe products for their kids.

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