 Good morning and welcome to this public meeting of the consumer product safety commission. Before we start, can I confirm that all the commissioners are here? Commissioner Feldman. I'm here. Thank you. Thank you, Mr. Trump. I'm here. Good morning. Good morning and Commissioner Boyle and I am here as well. Thank you this morning. CPC staff will brief the commission on draft supplemental notice proposed rule making regarding information disclosure under section 6 B, the consumer product safety act. Or the 6 B regulation, this proposal is a continuation of the work commission started in 2014 to update our section 6 B regulation. Those who are unfamiliar section, 6 B of the CPSC, which is our authorizing statute. Places of strict restrictions of how and when CPSC can discuss a manufacturer's consumer products. Before the agency can tell the public about a product, we generally must negotiate with the manufacturer over what we say and when. This can prevent CPSC from issuing timely warnings about dangerous products and put Americans at risk. We're the only federal safety agency with such a statutory restriction. And while I believe the best solution would be Congress to step in and appeal the the statute and put us on par with our sister safety agencies. As long as we have 6 B in place and raise the law, the commission. Can and should do better to ensure that our regulations are as consumer friendly as possible and don't restrict us beyond what the statute requires. I look forward to working with my colleagues to review this package and make the proposal available for public comment. In a moment, I will turn this meeting over staff so that they can brief us. Once they completed the briefing, each commissioner will have 10 minutes to ask questions and staff multiple rounds necessary. As a reminder to my colleagues, if your questions address the agency's legal authority, other legal advice, please hold them until closed executive session has been requested to be held later in today, following the public briefing briefing. Us today is Amy golden attorney in the office of general counsel. Also, with us are Austin, general counsel, most of the handshift, excuse me, assistant general counsel and Alberta mills commission secretary. Thank you and without, I'm going to turn the microphone over to miss Colvin. Good morning, chair and commissioners. My name is Amy Colvin and I'm an attorney in the office of the general counsel in the division of federal court litigation. I will brief the commission today on the draft supplemental notice of proposed rule making to update 16 CFR part 1101. Information disclosure under section 6 B of the consumer product safety act. Next slide. So, section 61 of the consumer product safety act states prior to its public disclosure of any information obtained under this act, or to be disclosed to the public in connection there with. The commission to the extent practicable must provide manufacturers for private labelers with advanced notice and a reasonable opportunity to submit comments on the proposed disclosure. If the manner in which such consumer product is to be designated or described in such information will permit the public to ascertain readily the identity of such manufacturer or private labeler. And section 3 of the consumer product safety act defines manufacturer to include an importer. Next slide. Section 61 of the CPSA requires the commission to take reasonable steps to assure that the information the commission intends to disclose is accurate. And that such disclosure is fair in the circumstances and reasonably related to effectuating the purposes of this act. Next slide. In disclosing any information under section 6 B, the commissioner may and upon the request of the manufacturer or private label or shall include with the disclosure any comments or other information. Or summary, there are submitted by such manufacturer or private label or to the extent permitted by and subject to the requirements of section 6. So, that was an overview of the requirements under section 61 of the CPSA in the next slide. I'll talk about the updates that the consumer product safety improvement made. So, next slide. The consumer product safety improvement act of 2008 amended section 6 of the consumer product safety act. First, it shortened from 30 to 15 days. The total period for manufacturers and private labelers to have notice to receive notice and have an opportunity to comment and information the commission proposed to disclose. Second, CPSA eliminated the requirement that the commission publish a federal register notice when the commission makes a public health and safety finding to shorten the time for providing notice. And finally, CPSA brought in the statutory exceptions to section 6 B. Next slide. So, the commission published a final rule interpreting section 6 B in December of 1983 in November of 2008, the commission published a final rule amending the 6 B regulation to reflect the CPSA amendments. And in February 2014, the commission published a notice of proposed rulemaking to amend the 6 B regulation. The 2014 MPR was based upon principles contained in the commission's fiscal year 2013 mid-year review and operating plan adjustments. The 2014 MPR proposed to modernize the 6 B regulation to account for the significant improvements in information technology that had occurred since the regulations initial adoption in 1983. The 2014 MPR also proposed to streamline the regulation to align it more closely with the text of section 6 B, including with respect to protect protecting information filed by firms under section 15 B of the CPSA. The commission received 24 comments from the public on the 2014 MPR. Next slide. The draft supplemental MPR retains many revisions that were originally proposed in the 2014 MPR with smaller note change. It also supplements the 2014 MPR based upon comments that we received and or to further modernize and more precisely align the 6 B regulation with the statute. Finally, the draft supplemental MPR responds to comments on the 2014 MPR. So, the next set of slides will be will provide a brief overview of some of the proposed revisions. Next slide. So, the first set of revisions appear at section 11, 1.11 B where the draft supplemental MPR proposes to add 3 categories to the list of information that is not subject to the requirements of section 6 B, 1, because it does not constitute a disclosure to the public. These categories were initially proposed in the 2014 MPR and based upon comments that we had received the draft supplemental MPR proposes some minor revisions to some of the categories and also provides examples for clarity. The first category that the draft supplemental proposes to add to 11, 0, 1, 0, 11 B concerns reports of harm that are posted on the publicly available consumer product safety information database, which is otherwise known as saferproducts.gov. So, section 6 A F 1 of the consumer product safety act specifically excludes reports of harm from the provisions of section 6 B. And under the draft supplemental MPR is proposed approach, the commission may release for identify information contained in a report of harm that is provided that is posted to saferproducts.gov without providing notice under 6 B 1. If the commission does not characterize the information contained in the report and the commission's use of the information is accurate and not misleading. So, for example, the commission could state that saferproducts.gov received 15 reports involving a particular manufacturer's lamp, but the commission would have to provide 6 B notice an opportunity to comment. If that same release then also warn consumers to stop using the lamp because of a hazard or contained other information that would constitute a public disclosure for which 6 B 1 notice would be required. The supplemental MPR also explains that the commission will continue to provide 6 B notice before disclosing reports of harm that are not posted on saferproducts.gov. Next slide. The second category of information that the supplemental MPR proposes to add to 11, 0, 1, 0, 11 B involves information that the commission has already disclosed in accordance with section 6 B 1. This was initially proposed in 2014. I'm sorry. I'm sorry. Let me go back and talk about publicly available information. The second category of information is publicly available information. So commenters noted that publicly available information may be misleading or inaccurate or biased and that the commission's reference to that information can imply that the information is verified or accurate. So the draft supplemental MPR proposes a modified approach based upon the comments that we received. And so under this proposal, the commission may release or identify information that is available to the public provided. 1, the commission clearly indicates the source of the information to the commission does not characterize or delay new information and 3, the commission's use of the information is accurate and not misleading. So, for example, the commission could state that it is aware of a particular newspaper article that references 15 reports involving a particular manufacturer's stroller provided the commission credits the source. It is reasonable to attribute integrity to the newspaper. For example, the newspaper follows journalistic standards and the commission's description of the newspaper's report is accurate and not misleading. And then the final category of information that we propose to add is information that was not previously disclosed that in context is not disclosed materially more or materially different information about a consumer product than what the commission previously disclosed. So this approach simply expands upon the commission's current practice of disclosing a summary of a press release that was initially issued in accordance with section 6 B1. So, here, for example, a commissioner could relate in a speech, the findings regarding manufacturer A's blender that appears in a CPSC staff report that was previously subject to section 6 B1 and posted to our website. But the commissioner could not discuss other staff findings that are not in that report unless the commission already provided the firm with notice and an opportunity to comment. Next slide. The 2014 MPR proposed requiring that the commission communicate electronically with firms and providing 6 B notices commenters overwhelmingly supported this proposal, but they did see clarification and some of the procedures that we would use. So, the draft supplemental MPR continues to propose that to the extent practicable, the commission will use electronic transmission of 6 B notices to avoid delays inherent in other methods. In response to comments, the supplemental MPR clarifies that if electronic transmission is not practical or the commission cannot confirm electronic receipt of the notice, we will use take appropriate steps to provide notice using other means, including delivery. Via US mail. Next slide. The draft supplemental MPR proposes 2 changes with respect to firms comments. So, section 6 B1 requires the commission to include with its disclosure of firms comments or other information or summary thereof. Only if the firm requests inclusion and such such inclusion is permitted by and subject to the requirements of section 6. The 6 B regulation currently, however, requires the commission to disclose comments that a firm submits in response to a section 6 B1 notice, even when the firm does not request disclosure. So, the draft supplemental MPR proposes to conform the regulation to the statute. It also requires that any requests for withholding must be made in writing. Next slide. The 2014 MPR proposed requiring the manufacturer of private label or to provide a legal rationale such as a statute of regulation to support withholding its comments. Because disclosure when it's not requested by a firm generally would become discretionary for the CPSC. The draft supplemental MPR instead proposes that the firm must explain any request for non disclosure. Next slide. So, section 6 B1 requires the commission to provide notice to the extent practicable there. The current regulation at 11 and 1.26 B provides examples of instances where it not be practical for the commission to provide 6 B notice. The draft supplemental MPR proposes to add 2 additional examples to the regulation. And this is a new proposed revision that did not appear in the 2014 MPR. The 1st example is when the commission has been unable after a diligent search to obtain the contact information for the manufacturer or private label or of the consumer product to which the information pertains. And here, this example kind of just represents what happens now commission staff conducts searches in internal databases and other sources to to find the contact information for particular firm. But there have been occasions where staff has been unable to provide or to find the contact information and in those instances, the commission has been unable to provide notice. The 2nd example is when an extraordinary circumstance necessitates the immediate disclosure of information to protect the public health and safety. Well, the commission simultaneously proceeds notification of the manufacturer or private labeler. So, for example, in a holiday weekend, the commission might become aware of a serious hazard involving a new consumer product that is associated with the holiday. And the commission attempts to contact the manufacturer without any success in this instance, the commission could go out with the disclosure and immediately notify the public of the hazard, but also wait for response for the firm. Importantly, how I just wanted to know that the commission would still take reasonable steps to assure that the information it intends to disclose is accurate and that disclosure is fair the circumstances and reasonably related to effectuating the purposes of the act. Next slide. So, this is a new proposed revision that did not appear in the 2014 NPR section 61 requires the commission to take reasonable steps to assure prior to disclosing information. That the information is accurate draft supplemental NPR proposes to add as another reasonable step that commission could take to assure accuracy instances when the commission staff relies on a statement made under oath. Or a similar statement enforceable under penalty of perjury, such as a sworn affidavit that yields or corroborates the information to be disclosed. Next slide. The next revision involves attorney work, so a product and attorney client privilege information. This revision was proposed in the 2014 NPR. So, in general, section 61 requires the commission to take reasonable steps to assure that disclosure is fair in the circumstances. The regulation currently at 1101.33 B3 provides examples of disclosure that generally would not be fair in the circumstances. So, the supplemental NPR proposes to delete the current example of releasing legally privileged information that has been provided to the commission intentionally. We believe that firms waive privilege when they provide legally privileged material intentionally to the commission. But if a firm inadvertently provides, submits privilege information, we will treat that information in accordance with inadvertent disclosure. Next slide. The final set of changes involves information containing the section 15 B report. So, in addition to the requirements of section 61 section 65, the consumer product safety act imposes further disclosure limitations and information submitted pursuant to section 15 B unless certain exceptions apply. The current current regulation at 1101.63 states section 65 does not apply to information independently obtained or prepared by the commission staff. The draft supplemental notice of proposed rulemaking proposes 2 revisions to this section at 1101.63, which we propose to designate as 1101.63 B next slide. So, the proposal proposal states section 65 does not apply to information independently obtained or prepared, which is language that is in the current regulation. And here's the new language or developed through subsequent investigation and verification by the commission, any member of the commission for any employee agent or representative, including contractor of the commission in a official capacity. And so this, this is a new proposed change that did not appear on the 2014 NPR and this change simply reflects current practice and recognizes that information that may appear in a 15 B reports such as contact information for consumers who. Report incidents to a firm or the names of retailers and distributors that the commission can contact those consumers to obtain additional information about the incidents or contact the retailer. To obtain additional information about a product that the retailer sells, even when the underlying information appears in a 15 B report. Next change next slide. I mean, so this is this is a change that was initially proposed in the 2014. NPR and we made slight adjustments. So, section 65 does not apply to information that's already available to the public, including, but not limited to information appearing in a company's press statements, websites, FAQs, product user manuals, sales materials, SEC filings or other public statements or documents. And so this is just to represent that section 65 is additional limitation on disclosure of 15 B information. Does not apply to information that is already available to the public, such as the price of a particular consumer product, which the public can find by walking into a retail store or conducting a search online. Or the sizes or colors of a particular product, which could be found simply by looking at a retail display. But depending on the information proposed for disclosure section 61 notice may apply. So that concludes my presentation. I'm happy to answer any questions that you may have. Thank you, Ms. Dolbin. I appreciate that. Appreciate the presentation as well at this point in time. We're going to turn to questions from the commissioners. As mentioned, we'll be 10 minute rounds, multiple rounds, if necessary. I'm going to start with myself. So, under the proposed revisions information is Raven may develop the public through sources, other than the commission press or so it's not covered by 60 as long as the commission indicates the sources of the information. And the commissions use the information is accurate, not some sleeting. How does this type of. Proposed revision address concerns that this type of information should be covered by 60. So, Congress applied the 6 B procedures only to the commission's public disclosure of information. So, public disclosure just by definition includes only kind of material that is newly available that that we are releasing and it's we're making known something that was previously unknown. And so when we view public information, we don't consider it to constitute a public disclosure under the act because we are not. Presenting new information, it's already out to the public, but we do recognize that there could be fairness issues in particular those issues raised by commenters that. Information that's publicly available could be misleading or inaccurate. And so the draft supplemental provides other protections to ensure fairness. 1st, the source of the repeated information must be identified. So the name of the newspaper or the scientific journal 2nd, the commission must provide the information itself without characterizing it. Or adding any kind of additional information that would constitute a disclosure and trigger the requirements under section 6 B. And then finally, the reference, the commission's reference to the information must be accurate and not misleading. So, a follow up to that, and then how do you assess the argument that the commission's repetition of information that's already in the public domain somehow fundamentally changes the nature of the information. And so, CPSC is legally required to go through a 6 B process. Right. So, we 1, I'm sorry, I miss has been careful to give her answer to your last question in terms of what's already in the document. And now we're probably crossing over into. An assessment of legal arguments that might that might be made by commenters. So, if we'd say that for a closed session, please. Okay, um, in it, um, so, Miss Colvin, can you explain the origin of the proposal that the release of public information should be accurate and not misleading and how that might work in practice? Um, sure. So, when we were considering referencing publicly available information, we looked at section 6, a 7 of the consumer product safety act and this section contains the retraction requirements. So, it requires the commission to publish or retraction of inaccurate or misleading public disclosures. And while section 6, a 7 doesn't technically apply, if we're just pointing to information that's publicly available, because it's not a public disclosure, the principles in section 6, a 7, certainly are should be considered guiding principles to both the commission and staff. That, you know, the accuracy of the information that the commission that the information, the commission releases is accurate and that we avoid misleading the public. So, the draft would require each commissioner and commission staff to look at the standard in 6, a 7 and ensure that they, when they release information that is publicly available, that their use of the information is accurate, not misleading. And would certainly be available to assist in any assessment and to provide any guidance. So, will the pros changes affect commission's treatment of confidential commercial information or financial information? Absolutely not section 6, a of the CPSA still applies and has very strict requirements on the commission's disclosure of any confidential, commercial or financial information or trade secret information. Firms are still able to submit comments that contain that information or to comment on proposed disclosures and claim that the information that the commission intends to disclose or the information, their comments contain confidential, commercial or financial information. They just need to submit the claims in accordance with the commission's FOIA requirements and the FOIA regulations specifically at 10, 15.18. Well, thank you. I'm going to reserve the rest of my time and defer to the other commissioners at this point in time. Commissioner Feldman. Thank you, Mr. Chairman, and thank you, Ms. Colvin and Mr. Schlick, our general counsel for all the work that's going into this and for the presentation today. I know that this is something that's been on the agency's books as a pending rulemaking since as early as 2014. And I'm glad that we have the opportunity to talk about it today. Ms. Colvin, I did have a couple of questions that I did want to raise it when we're talking about the disclosure of information that's already publicly available when we're talking about disclosing media reports that are that are already. Out there and published it would seem to me that the commission's disclosure and distribution of that information necessarily involves some sort of assessment on our end. Of the, the integrity of those media reports and is that accurate? Is that an assessment that we would have to make? Well, right, there's, we would certainly look at the integrity of the source. So, for example, does the newspaper follow journalistic standards? Does the scientific journal, do they have a peer review requirement? So, we would certainly definitely consider that and determining whether or not we could point to a particular publicly available information. Okay. I mean, in other contexts, we've relied on studies that haven't been peer reviewed, but we're talking about a different context, right? I mean, we would just look at the standards that the particular publication uses. So, you're right. I shouldn't say that it needs to be peer reviewed, but we would definitely. Okay. That's concerning to me. I appreciate you putting a little bit more meat on the bones of how we would sort of begin the process of assessing the integrity of a particular media outlet, but that sounds awfully close to content moderation and that's not something that we have much experience with, nor is that, it's a very dangerous road to go down. I think that gives me a significant amount of pause. But for more than that, it's troubling to me, you know, whenever we put information out from a particular source, the proposition that that stands for almost certainly is going to be sort of attributed back to CPSC as our own. How do we go about avoiding that? The proposal states that we would 1st point to the source of the information and clearly indicate the source. We would not provide any kind of characterization of the information or provide any new information that would constitute a disclosure. And then we would make sure that our use of the information is accurate, not misleading. So, for example, we could state the New England Journal of Medicine just published a report on manufacturer A's product. Okay. Yeah, it's not a hypothetical concern though. You know, recently and under prior leadership, our Office of Communication published recommendations. For example on how deep to bury beach umbrellas. We took information that came from an outside source. It was the community publication in Ocean City, Maryland, that made the recommendation of burying a beach umbrella 2 feet. We published that. There's no independent CPSC testing. But we sort of regurgitated media information that was already publicly available. And then on multiple occasions, watching this story and this recommendation get regurgitated. This 2 feet recommendation was parroted back as if it were a CPSC recommendation and it wasn't. It was from a community newspaper in Ocean City, Maryland. So, again, not a hypothetical concern. It's a real concern. And it's a concern that I have and I think glad that we're putting this out for publication, because this will be an opportunity for us to receive comments about how best to proceed on this run. I did have one other question that I want to be mindful of the time. In the presentation, you talked about instances where they're there. We're noticing comment isn't practicable. So this would be staff's proposals to expand 16 CFR 1101.26 B. And the staff proposal, as I understand it would allow the commission to act in extraordinary circumstances that would necessitate immediate disclosure of information to protect public health and safety. While the commission simultaneously pursues notification to the manufacturer or the private labeler. My question to you would be, who makes the call about what constitutes an extraordinary circumstance? Would this be sort of delegated to staff to pursue that? Or is that a call for the commission to make? You know, that's a really good question that I don't have the answer to, but I'm happy to get back to you on that. I appreciate that miss Colvin. Thank you very much. I may have additional questions, but for the time being, I'm going to yield to my colleagues. Thank you. Thank you, commissioner. Commissioner Trump. Thank you. So like the gag rule puts inappropriate and dangerous restrictions on the agency's ability to timely share. Critical information on safety with the public. And people can be hurt and killed as a result of this inappropriate statutory burden. I know that Congress is considering the sunshine and product safety act to correct this. And I hope it passes. But this agency, I think what we're recognizing today is that the agency's also historically put additional burdens on ourselves on our ability to communicate through overly restrictive interpretations of the act. And I agree that we should change that wherever that's appropriate. I'm not sure we go as far as we need to with this proposal. And so I would love to hear great ideas through a robust comment process. I do have just a couple of specific questions on the proposal. So in, in the proposed draft section. 1101.11 a 3. Would read the information must be obtained generated or received under the acts to be disclosed to the public in connection there with. Does the word generated appear anywhere in the statute. The word generated does not appear in the statute. Okay. And then in 1101.11 be 5 and be 6. We exempt certain information from 61 requirements, specifically a report of farm on safer products dot gov. And information that has already been made available to the public through sources other than the commission provided that we clearly indicate the source of the information. And the commission's use of information is accurate and not misleading as you just went over how that process would work. But in the preamble, I think we create some ambiguity and how we describe those exemptions preamble states that we can release information without 61 notice. As long as quote 1, the commission does not characterize the information contained in the report. And to the commission's use of the information is accurate and not misleading. We already have an obligation there's 6 b 6 and and 6 b 7 to not release information that is inaccurate or misleading. But the part about the not characterizing the information could be an issue. As it's undefined and I think that could be broadly interpreted. Does the word characterize appear in the statute. Yeah, it does not appear in the statute. I think to remove some ambiguity there and and retain our ability to put information in proper context when we talk about it. We may need to change to that characterization part of the proposal to add some clarity and hopefully we can discuss that through the comment process. Last question that I have here for for fairness, we allow firms to include their comments. We give them the opportunity to provide their comments alongside ours and really certain information. Many times they want to do that, you know, they want to be able to explain or put things in their own context. But in this package, we develop a lot of attention to the idea of firms objecting to their own comments being released with our release. How often do we find firms objecting to their own words being made public. I don't have specific data, but in my experience, and this is just my. Experience reviewing comment letters, the majority of firms request that their comments be withheld. And do what kinds of issues do they raise as to to justify not wanting them to be released. Typically firms will state that their comments contain confidential commercial or financial information that is protected under section 6A to. And the commission's FOIA regulation. They also. Claim that release of the information would violate section 61 because, for example, they provided information. In connection with settlement negotiations. And so they would object to the release of that information. Is it ever that they would just simply be embarrassed by some of the arguments they make to try to keep their statements private. I have never experienced that or seen that in my review. I have no further questions. Thank you. Thank you, Commissioner. Commissioner Boyle. Thank you, Mr. Chair. Thank you to the staff who worked on this. Package, I actually don't have questions. I appreciate the opportunity to take a fresh look at the regulation in light of the need to modernize and modern communications. I think it's a good idea that we do so. And I am looking forward to the robust comment period that I am anticipating. So I appreciate the work and thank you. Thank you, Commissioner. We can go to a second round of questions. Anybody has any. Commissioner Feldman. Yes, I don't have any so good. Commissioner Feldman. Thank you. Miss Colvin, we heard some discussion today about the information publicly to put that information. In the proper context. And I understand why that's that's important because. Serve consumers better to have actionable information that's appropriately contextualized, but at the same time. With what I'm reading in staff's proposal, which is talking about. You know, putting out information, you know, within the. What's allowable under 6B that that's already publicly available that in order to do that permissively that we would need to. Keep that sort of without, without putting any additional context on it without sort of comment from the agency. So any, any thoughts from you or guidance? How do we put information in the proper context? But at the same time, make sure that we're not adding. Any sort of additional commentary or thoughts from the agency characterizing that information one way or the other. So, I think I look at it 2 ways 1st. If we're simply referencing or responding to reporters inquiry, did you see newspaper access article on. This particular product and we acknowledge. Yes, we are aware of this article on manufacturer a stroller. That in that context, that is not that cannot constitute a public disclosure. So section 6B and the requirements wouldn't apply because we are not. Why wouldn't that be a public disclosure? Okay. Because the definition of disclosure, a public disclosure is really releasing new material that was previously unknown. And so we're acknowledging that there is a newspaper article out there. That's information that it's already out there and the public is aware of it. So that's my kind of the 1st response. The 2nd is just framing it and to make sure that. We are providing accurate and not misleading information is the steps that we will take to 1st, make sure that people understand we are not the source of the information. We are aware there is this New England Journal of Medical Study or sorry, New England Journal of Medicine study and the commission is aware of it. Number 2, we don't say anything about the information contained in the report. We don't kind of, we don't provide our own interpretation or explanation of the information. And number 3, we don't provide new information. So for example, we would not be able to state. Here's this newspapers article about 40 incidents involving a particular manufacturer's bike. And by the way, the commission is aware of an additional 50 incidents. And that instance, that is new information that we are proposing to and I will use the word disclose that would require 61 notice and opportunity to comment. I'm curious then why why this would be drafted so narrowly that we would be responding just to newspaper articles that we've put out but putting that aside. I'm curious also. How this plays out when the commission puts out a release with with the kind of information that we're talking about today. You know, if we put out a press release character or sort of stating with no additional information what we're learning in a particular article that's that's out there or a medical journal or what have you. In my experience and in communications that's almost certainly going to generate a significant amount of public and immediate inquiries about sort of the nature of the statement. Why we why we made that statement what we believe it to mean. You know, what would the. Guidance be and I'm not necessarily looking for legal guidance, but but how does this play out how would our office of communications handle the media inquiries that are almost certainly going to follow what what what what restrictions would they be under. Well, I think that they could. State, for example, if there is a huge report on a great increase the number of incidents involving particular firms product. This would be a way for the commission and in particular. The office of communications to state consumers go go to safer products dot gov and please report your incidents without saying anything else and that way we have the message out that if there's an incident if you've experienced an incident please report it on safer products dot gov. And I think that's what we've been doing already and that's kind of consistent communication and messaging that the commission does right now. I think that makes sense when when we have an OCM that staffed by competent communications professionals and I've got a great deal of faith in the team that we currently have in place right now but that that hasn't always been the case. So, you know, when you've got a director of communications that that is a professional and disciplined in able to stay on message in situations where that's not the case which we've experienced at this agency. I think that's where I have some concerns. So again, I think this is glad that we're putting this out for comment. I'm I'd be curious to see how the public responds to those concerns in particular. I have no further questions, but again, I want to thank you for the work that you put into this and thank you for the presentation today. Thank you, commissioner commissioner Trump. Did you want a second round? No, I'm I'm sad. Thank you. Thank you, Mr. Boyle. No, thank you. Thank you. Thanks to the staff for this informative briefing and to all the commissioners for their active participation. We look forward to hearing from the public and putting this out for notice as well. With that, this briefing is adjourned. Thank you.