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Compliance Program Seminar - Panel 3 - Role of Trade Associations in Program Compliance

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Compliance Program Seminar - Panel 3 - Role of Trade Associations in Program Compliance

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Compliance Program Seminar - Panel 3 - Role of Trade Associations in Program Compliance

  1. 1. Consumer Product Safety Commission Compliance Plan Seminar Autumn Moore Director, Regulatory Affairs & Compliance November 1, 2018
  2. 2. • RILA’s Primary Mission – Education, Advocacy and Collaboration • Disseminate information • Educate members on legal requirements, voluntary standards and compliance obligations • Facilitate benchmarking on leading practices • Be the voice of the retail industry for regulators and legislators • Advocate on member’s behalf • Build coalitions to further association reach Role of Trade Associations 2
  3. 3. RILA Consumer Product Committee 3 • Comprised of in-house product compliance professionals and counsel • Bi-annual in-person meetings • Monthly Calls • Educational Component to all monthly calls, including legal experts to provide guidance on regulations and legislation impacting members • Provide forum for members to discuss current issues within their companies and share leading practices
  4. 4. • CPSC compliance is just one piece of companies’ broader compliance programs • Companies also have compliance plans for a broad range of issues, including: • OSHA • Environmental compliance, including EPA requirements • FDA, food safety • Pharmacy • Human resources • Marketing and advertising compliance • Foreign Corrupt Practices Act • Potentially differing state programs for all these areas Retailers Focused on All Compliance Activities 4
  5. 5. • Retailers are often the face of a recall for consumers • Retailers put in place “stop sale” technologies for stores once products are recalled • Often retailers are not alerted to a recall until the day of, or even after, recall has been announced • Useful for UPC code to be used rather than SKU • Helpful when U.S. Government agencies partner on joint announcements (e.g., lithium ion batteries with Department of Transportation) • Poster recall announcements should be used sparingly Compliance in Reverse Logistics 5
  6. 6. • Board of Directors increasingly focusing on companies’ overall compliance risk, including product safety • Increased number of “chief compliance officers” • Increased budgets being dedicated to compliance efforts across programs Retail Compliance Programs 6
  7. 7. Autumn Moore Director, Regulatory Affairs & Compliance 703.457.7919 Autumn.moore@rila.org
  8. 8. CPSC Compliance Program Seminar Panel 3: Industry Trade Groups Jennifer Cleary November 1, 2018
  9. 9. Compliance Plans Are Only One Piece of the Puzzle AHAM does not have policies or procedures on how to develop a compliance plan—there are many other resources on this to which we direct our members AHAM members’ top priority is to design appliances that are as safe as they are useful Compliance plans are only one piece of the safety puzzle Hazard-based safety engineering and risk assessment are the foundation—assessing risk and designing safety into the product AHAM members test products to ensure they meet or exceed safety standards and continually work to proactively improve standards based on new innovations to reduce potential risks and further improve consumer safety Consumer education is another key element 2
  10. 10. Building a World-Class Safety System Key elements for building a world-class safety system: Organization within the company Safety should not be bound by traditional reporting structures, but should be part of a matrix organization Alerts, training, and communication are key Product safety responsibilities present in company culture, functions, policies, communications Need safety committees, procedures, and managers Necessities for corporate consumer safety policy Elements of a company-wide product safety system Going beyond the minimum Go beyond minimum safety standards and requirements 3
  11. 11. Key Elements for Corporate Consumer Safety 1. Corporate Policy 2. Senior Management Ownership 3. Directed responsibilities 4. Clear Objectives 5. Corporate Product Safety Function 6. Processes with Disciplines 7. Regional authority 8. Hazard communications processes 9. Monitoring product safety performance 10. Defined Corrective Action procedures 11. Ability to modify procedures 12. Training 4
  12. 12. Elements of a company-wide safety system  Management support from the very top  Clear policy/policies  Decision to meet all standards and regulations around the world  Establish decision-making procedures that account for all risks  Unified level of safety in all regions  Establish a world-wide post-sale monitoring system  Train personnel world-wide on documentation  Use attorneys (counseling and litigation) Recommendation 5
  13. 13. Establish a company organization that works  Find the system that works  Reporting structure is important, but access is greater  There is no one-way to structure product safety reporting  Make resources available for:  Training  Investigations  Failure analysis  Communications  Consultants  Don’t try to imitate other companies Recommendation 6
  14. 14. Recalls AHAM members, like other manufacturers, produce hundreds of millions of products each year. Strive to and succeed in designing and building products to highest levels of quality and safety Demonstrated commitment to internal safety design, monitoring, and evaluation/failure analysis systems. Sometimes, it is necessary to work with CPSC through reporting and, sometimes, corrective action plans and recalls. A recall, or even several, is not an indication that a compliance plan is inadequate Multiple voluntary recalls over time often indicate that a firm has a broad product scope, makes many products, and most importantly, has a robust compliance program. Many companies that have effective compliance programs will have recalls from time to time because an effective process will identify potential hazards and prevent future recalls. A firm without such a program will likely fail to identify potential hazards. 7
  15. 15. Juvenile Products Manufacturers Association Kelly Mariotti, JD, CPA, CAE Executive Director November 1, 2018
  16. 16. Who we are The Juvenile Products Manufacturers Association (JPMA) acts as the voice of the industry on quality and safety for baby and children’s products in North America. It does so by advancing the interests of manufacturers, parents, children and the industry at large through product performance certification, events, consumer education, and advocacy with the goal of bringing safe, functional products to market.
  17. 17. The Role of the Association Member Company Support and Education Public Affairs and Advocacy Certification Program
  18. 18. Compliance Programs Best Practices • Evaluate Risk • Trusted Partners • Testing Laboratories • Supply Chain Transparency • Build the Corporate Culture • Ongoing Maintenance and Evolution • Certification • Testing ≠ Compliance
  19. 19. Role of Technology Evolving Technology = New Solutions • Needs assessment and implementation • Vendor surveillance • Document management • Data synthesis and analysis
  20. 20. Communications Collecting Consumer Information • Embedded technology • Product registration at point of sale • App-based registration solutions • Consumer outreach to company • Product evaluation
  21. 21. Thank You Kelly Mariotti, JD, CPA, CAE kmariotti@jpma.org
  22. 22. CPSC COMPLIANCE PROGRAM SEMINAR November 1, 2018 Kristen Kern, Government Relations Representative, American Apparel & Footwear Association
  23. 23. ABOUT AAFA
  24. 24. Supply Chain As the industry’s source for supply chain compliance, AAFA helps you stay ahead of sustainability and social responsibility matters, chemical management, transportation and logistics, and more.
  25. 25. AAFA COMPLIANCE TOOLS • AAFA RSL • State-level Guidance Tools  Prop 65  State Chemical Reporting Laws • CPSIA Testing Guidance • Industry Recalls Running List • International Labeling Matrix
  26. 26. CHEMICAL MANAGEMENT • Key element to compliance program • Restricting chemicals in products and factories  Consumer safety, worker safety, environmental sustainability
  27. 27. TESTING PLANS • Testing as verification of compliance • Testing as indication for state chemical reporting  Prop 65- indicator to use/not use a product warning label  Children’s products laws in Oregon, Washington, Maine, Vermont
  28. 28. REGULATION TRACKING • Staying up-to-date on regulations is key to compliance  State, federal, international • Plan to update compliance plans
  29. 29. www.aafaglobal.org | @apparelfootwear THANK YOU Kristen Kern kkern@aafaglobal.org