How Often Should Products Be Tested To Give Clients Confidence?

While most compliance efforts are heavily focused on children’s products due to the existence of many specific standards and the higher risk of selling to a young audience, suppliers would be remiss if they overlooked and didn’t impose applicable or analogous compliance requirements for products geared toward an adult or general audience.

It is just as important to ensure adult or general use products are safe and meet all necessary standards. Toward that end, suppliers should have documented policies to ensure adult or general use products are screened at certain purchasing intervals, and basic tests for small parts and sharp edges should be used to evaluate safety even in non-children’s products.

Given the absence of a formal test frequency requirement by the CPSC for a variety of adult-intended products, many suppliers may feel it’s acceptable to forgo testing altogether for adult products. Or, perhaps take a more lax approach and test once over the sell life of the product. This is a mistake, and given the variability and vagaries of the supply chain it is a formula that could cause harm to consumers, the supplier’s reputation or worse.

For example, say there is a supplier that sources a new piece of drinkware. The supplier does its due diligence for testing when introducing the mug as part of a new catalog. At the initial test, the mug meets the applicable FDA and California Proposition 65 standards. The supplier believes it has done its due diligence and files the passing lab report away without thinking of it in daily compliance operations. The mug becomes a popular seller and is ordered by clients on a quarterly basis. The supplier assumes the factory’s materials have remained the same for each batch year after year until two years after introduction into the State of California. The supplier then is found to have elevated chemical content in the mug and faces a possible recall, lawsuit and fines. It’s a potentially heavy price to pay when a due diligence test frequency step could have been implemented in the supply chain.

To make matters more challenging with adult-intended items, promotional products clients are becoming more compliance savvy. Many of my clients employ compliance professionals or engineers who demand transparency in the supply chain. There is compliance oversight when placing an order, and if the compliance professional isn’t comfortable with the item, the sale is halted. Many clients demand to see proof of testing at certain intervals for all products, not just children’s products. If a distributor requests a lab report from a supplier to ultimately provide to a client to secure a sale, and the supplier’s report is dated several years ago, the client will likely become concerned and question their purchasing source. If you were the client, would you feel comfortable doing business with a company that hasn’t safety-screened its product in five years? Distributors rely on suppliers and need to feel confident that testing is performed on a consistent basis.

Q: What are the recommendations on testing frequency?

UL-Specialized Technology Resources and PPAI recommend that a product regulated by the CPSIA be tested annually. If the production volume is less than 10,000, then testing should be performed at the production of every 10,000 items. Additionally, whenever there is a material change to the item, testing should be performed.

Find more questions like this one about product responsibility—including standards, toy testing requirements and how to read a test report—in the FAQ at Click on Inside PPAI and on Corporate Responsibility.

Tabatha Bauer is director of logistics & compliance for Staples Promotional Products, the largest distributor in the promotional products industry. She is responsible for a North American expanded team that oversees product safety, social responsibility, C-TPAT compliance, haz mat transportation and export trade compliance for both the U.S. and Canada. Bauer has been in the promotional products industry since 2000 and has worked both on the supplier and distributor sides of the business. She is a member of the ICPA (International Compliance Professional Association), PRAG (Product Responsibility Action Group) and ICPHSO (International Consumer Product Health & Safety Organization).