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Testing Protocol to CPSIA Requirements - 16 CFR Part 1107

By Crystal Johnson

How sure are you that your products are safe once they hit the store shelves or wind up in consumers hands? What degree of assurance do you have that your products meet CPSIA requirements after they are manufactured?

Section 14(a) (12) of the CPSIA addresses 3rd party testing performed by a Consumer Product Safety Commission (CPSC) accredited lab prior to entering the marketplace. The samples tested should be completely representative of the product consumers will receive. Following the initial round of testing, the begging question we hear so often is “how often testing should occur to ensure products are still compliant?” This goes back to establishing a reasonable testing program, which includes testing periodically by selecting representative samples to ensure a high degree of assurance that all untested products are also compliant with the safety rules. The Code of Federal Regulations (CFR) has developed a protocol and standard for this, which is titled Testing and Labeling Pertaining to Product Certification and it can be found in 16 CFR Part 1107. To review the entire standard, please click on the following link: http://www.cpsc.gov/businfo/frnotices/fr10/testing.pdf. In addition to periodic testing, testing should be performed if there is any material change or a change in the manufacturing process which affects the design. So, while the minimum for testing is at least once every two years and the CPSC has recommended annual recertification, some manufacturers may need to test sooner if there is a change in the material or process.

Another integral part of establishing a reasonable testing program is to select random samples for testing (that is once the product is on the store shelf). Instituting this as part of your quality assurance program, will allow for a higher degree of assurance that all untested items are compliant with the applicable safety laws. ATS is a domestic testing lab, and we have assisted a number of customers with ensuring products are compliant once entering the marketplace. Feel free to contact our lab for additional information regarding testing to meet regulatory requirements. Our laboratory is accredited by the American Association for Laboratory Accreditation (A2LA), certificate number 1888.01 and 1888.02. Additionally, we are a Consumer Product Safety Commission (CPSC) accredited lab, our laboratory identification number is 1030.

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