Transcript PPAI Product Safety Summit 2012

Product Safety and Regulatory Compliance
for the Promotional Products Industry
We Get the Basics. How Do We Put it into Practice?
An Interactive Workshop on
Implementing Best Practices to
Protect our Businesses and our Industry
Product Safety 201
January 15, 2013
Objectives
• Interactive discussion on how colleagues of varied sizes are implementing
product safety, regulatory compliance and responsible sourcing practices in their
companies – and how they are working to change the culture.
• Discuss the key challenges our industry faces in trying to comply with CPSIA and
to suggest some best practices that can help.
• Identify best product responsibility practices you can adopt in to protect your
business, your clients and the Industry.
• Identify resources that can help, such as PPAI and it’s lab partner UL-STR
Meet our All Star Industry Panel
Rick Brenner, MAS
Prime
Moderator
David Geiger
Geiger
Anne Lardner-Stone
PPAI
Leeton Lee, Esq.
ETS Express
Larry Whitney
Polyconcept NA
Caryn Stoll
Freestyle Marketing
Wayne Greenberg, MAS
JB of Florida/Geiger
And Special Thanks to PPAI’s Expert Lab Partner
Sue DeRagon
UL-STR
Today’s Format
Interactive and participatory discussion
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We welcome questions as we go along, rather than at the end
Please participate in the discussion. Share your experiences.
No negative experiences by vendor name please.
If you a question don’t be afraid to ask
This is your workshop. Take advantage of panels knowledge and experience.
We may “park” a question if it will be covered later
Be brief and to the point so we can cover a lot
• We can revisit topics if we have time at the end
• Please don’t be offended if I interrupt to move the discussion forward
Questions are intended to raise awareness of issues
• Not intended to endorse a particular company’s policies
• Choose the policies that make sense for your company
Where it All Began…….
The Summer of Recalls - 2007
The Result….
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Heightened awareness of risks of imported products
Far reaching new state and federal legislation
• Complicated and often ambiguous regulations
• Four years of “guidance” from CPSC - trying to explain what
CPSIA means and how it affects our industry.
• Major industry initiatives by PPAI, by suppliers and distributors
to develop and implement compliance programs, educate
colleagues and customers, and to change the culture regarding
product safety, compliance and responsible sourcing.
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Product Responsibility
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Product safety
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Regulatory compliance
Social accountability
Environmental stewardship
Supply chain security
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Establishing a Product Responsibility Program
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Do you have a formal product
responsibility process in your company?
What does it include?
How did you get started?
What are some challenges you’ve had and
how have you overcome them?
Distributor Sales Calls
• What should a distributor learn in a client meeting?
– Intended audience?
– Testing standards – compliance requirements?
• Does it risk the order?
– How do you mitigate that?
• Does this information impact product or vendor
selection?
• What about Internet orders?
Suppliers and Distributors
Would you risk a $10,000 order to raise product
safety questions?
Suppliers: Educating the Team
Is this product OK for children?
(or any similar compliance question)
Who can reliably answer that question?
CSR?, Sales rep?, Compliance person?
Who can technically answer that question?
Suppliers: Product Strategy
• What is your blanks/children’s product
policy? How do you communicate that
to distributors?
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Do you have a process to protect against
applying a juvenile imprint to a product
without third party testing?
Suppliers: Test Reports
• How do you determine what products to test
and what tests to perform?
• How do you communicate this to your staff
and to distributors?
• What process do you use to keep up-to-date
with third party tests?
• How often do you update third-party tests?
• Do you perform interim testing?
Distributors: Test Reports
• Do you have a process for obtaining test
reports from suppliers?
• How do you educate your staff on how to read
the reports?
General Use Products
• Is compliance enough for promotional
products?
• What are the risks?
Distributor’s Decorating Apparel
CPSC considers distributors who purchase blank goods
and send them out for decoration as manufacturers.
Recently the CPSC general counsel issued guidance
requiring “an appropriate level of due care” to verify
that the inks are compliant.
How is your company dealing with this responsibility?
How do handle the requirement for a second tracking
label?
Challenges for Distributors Who Contract for Decoration of Children’s Products
“An Appropriate Level of Due Care”
Trusted Advisor
Is product safety/responsible sourcing an
opportunity to create a stronger relationship with
your customer?
Is this a value add or has it become the minimum
requirement for access?
Recall Preparedness
Is your company prepared for a recall?
What are the issues?
How did you create the plan?
Social Accountability
There is a great deal of publicity about working
conditions in factories overseas.
Do you have specific business requirements
dealing with social accountability?
Is it realistic for us to be able to impact factory
conditions?
PPAI Resources
Do you take advantage of PPAI Product
Responsibilty resources?
Webinars/Best Practices/Turbo Test
Are there other ways PPAI could help you?
Supplier or Distributor
10 Things We All Must Do
1. Know the laws/regulations (or have a good resource)
2. Know your product (supplier, primarily)
3. Know your supplier
4. Know your client
5. Know your intended audience
6. Know the risks – regulatory, safety, PR
7. Educate the team
8. Stay current (Buckyballs, John Deere, 600-100/90, F963-11)
9. Instill a product safety culture in your company
10.Protect the industry
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Thank You!