 Public meeting and consumer product safety commission before I start, I'd want to confirm all the commissioners are here. Commissioner Bianco, Commissioner Feldman. Get on mute and start it up. Everybody is muted. I'm here, Alex. Thank you. Great. Commissioner Trumpka morning. And Commissioner Boyle I'm here and I do want to know that this is the 1st public meeting, which commit. In which Mary Boyle is participating as a commissioner and I want to welcome you to your new role. I know that the commission will benefit from your extensive knowledge and experience. This morning, CPSC staff will brief the commission CPSC strapped 2023 to 2026 strategic plan. Last time the commission approved a strategic plan was in 2017 covering the years 2018 through 2022. A lot has changed over the last 5 years. The workplaces shifted dramatically as we learn very quickly how to operate virtually. We also have new leadership at the commission and none of our current sitting commissioners were in these seats. So last time the agency approved a strategic plan. Market place is changing as well, most notably with the continued expansion of e-commerce. We have new tools that can be used to protect consumers, including. The potential to integrate machine learning and artificial intelligence more fully into our work. And that being said, many of the challenges faced by our predecessors carry forward today. The agency strategic plan establishes our vision and goals over a multi-year period. As a small mission driven agency with life or death literally on the line that can be consumed in the day to day issues that come before us. Developing this plan enables us to think bigger picture and reflect on how best to achieve our mission. Today's briefing is 1 step in the congressional mandate of process for developing our strategic plan. There is more that needs to be done for this document is complete. Over the next couple of weeks, we'll have the opportunity to amend the staff draft, which will then be put out for public comment. This is an essential part of the process we need to hear from the public regarding our priority setting and welcome all comments. Once the common period closes, staff will review everything that we have received incorporate comments into the document and the commission will have a 2nd opportunity to consider the plan before it comes final. In a moment, I will turn this meeting over to the staff so that they can brief us once we've completed that they've completed the briefing. Each commissioner will have 10 minute rounds to ask questions to the staff with multiple rounds necessary briefing us today will be Jason Levine, CPC, executive director. I know that this also marks his 1st meeting is public meeting as executive director and he too brings much experience expertise and passion to the commission. He is joined by James Baker, chief financial officer, Dwayne Ray, deputy executive director for operations, Dwayne Boniface, assistant executive director, Rob Kay, director, compliance field operation, Pamela Springs, director of communications and as always Austin Schlick, general counsel and Alberta Mills, CPSC's secretary. With that, I'd like to turn this over to Mr Levine for the briefing. Thank you, Mr chair and thank you. Good morning to all the commissioners if we could get the slide deck up. We'll jump right into it. Thank you so much. So we're going to go right to our next slide slide number 2. And talk about strategic plan and the process and the document. That that everyone should have with them at least not in front of you. Close by so strategic plans as many of you know our statutory required by Congress under GIPRA. And as well, they're detailed with some guidance in the circular 11. On a normal course of business, federal agencies submit their plans every 4 years beginning with the new term of administration. And generally published the year after due to our lack of a chief executive officer newly confirmed last year. When we were supposed to start our process, which would have made it a 2022 to 26 strategic plan today. We are looking at a draft version of the 23 to 26 strategic plan. But we did make sure to notify a Congress and OMB both in August of 21 and March of 22 of our plan for moving forward in an off cycle. Style with respect to the strategic plan. Next slide, please. So a little background on our draft strategic plan specifically. And as you, as you know, reflect the agency's mission, vision, long term strategic goals and objectives. As well as strategies approaches used to monitor progress. I think that's. Amongst the most important pieces of it is that it lays out at an enterprise level. The concepts and how we will move forward. Over a 4 year or 5 year this instance and say 4 year period. As we put together the various annualized documents that the commission. Approves every year. The framework itself is a 4 tiered. Set up so strategic goals, strategic objective strategies and initiatives and each at each layer. They get a little more detailed. Than the one before it. Next slide, please. So here. This lays out actually 3. 3 different pieces of the strategic plan. Mission. Vision and those overarching sort of pillars of the strategic plan. The goals 1 through 4. Not going to read them to you. You can all see them for yourselves, but I will note. Some high level items that have changed from the previous plan. The new version has a slightly different mission statement. Still remains in plain English. We'll talk about that in a second, but it's a little more nuanced. 1 new strategic goal out of the 4 strategic goals. And there are 5 new strategic objectives out of a total of 14 spread throughout the document. Next slide, please. So, as mentioned, the. The mission language itself has changed a little bit. Remaining again in that plain English style, but being a little bit more specific. And nuanced than the previous version, which was keep keeping consumer safe. It is now protecting the public from unsafe consumer products as this overarching mission concept. Next slide, please. Okay. Strategic goal 1 to the main. Item I would note here is that we have. Shifted goals to 3 and 4 from the previous strategic plan have been moved up to goals 1, 2, and 3. And the strategic plan and there have been obviously some tweaks within that as well. Generally speaking, the 23 to 26 strategic plan builds on the framework of the previous strategic plan so that much of the. The foundation remains similar familiar feeling though there have been. Changes in an attempt to find places where things can be improved made more robust. And more specific, both with respect to the actual activity. That is contemplated, but also with respect to measurement and how we're going to do that. The. The goal, sorry, the lead office for for strategic goal 1 prevent is the office of hazard reduction contributing offices include. Import surveillance and our international programs. I would note throughout while we highlight and there are offices that take the lead. For each specific goal because it's important that there is an office that is tasked with rounding up the information, particularly when we get to the measurement piece. It's hard to suggest that any of these goals are only within 1 office and they do have a. Across the agency there, there's significant input from from all the offices and we'll get to that a little bit more when we talk particularly about goal for. Next slide please. Okay. So. Sure, my notes are matching up. Okay, so here in street objective. 1.1, which you'll see as a highlighted change, emphasizing the importance of timeliness and identifying hazards when we talk about prevent. We talk about our hazard office hazard reduction. This is an area where we're thinking about preventing the hazard. Ideally, you know. At the source as it were, which is why we're talking about in the rule making space or the international space, the import space trying to stop it before it gets. Into consumers hands and trying to do that in a timely manner as possible. In 1.2, you'll note a change from the previous. Strat plant strategic plan highlighting the criticality of effective safety standards. Those those seem to worth highlighting you'll note 1.3 has remained the same because we remain to think it's it's useful and how we do what we're doing. Next slide. Okay. Here what we've done is, is in an effort to emphasize the importance of being proactive. The terminology has changed from response to address. And as you can also see, we've. We've changed the we've added the concept and making sure we are talking about in a fast and effective manner again. It's not to say that we weren't in fast, effective manner previously, but it's really emphasizing the language emphasizes what's important. And we're continuing to do that in this goal here. The lead lead office here is going to be our office of compliance contributing offices are including hazard reduction and international programs. Next slide. Again, getting a little bit deeper into the details of strategic goal to you'll note some changes throughout here. Some that I would highlight certainly by the one I highlight the most would be strategic objective 2.4, which is a brand new strategic objective within this office within this goal. That talks about how we monitor post recall activity. You know, a lot of our work, a lot of our emphasis goes to. Obviously, I. If a product, whether through a defect or regulatory circumstance has reached the marketplace has reached consumers. We want to a lot of work goes into getting that product out of consumers hands out of the marketplace. But what are firms doing after that recall takes place to help continue to whether to get the word to consumers for fill any obligations that they have agreed to with the commission. So that's 2.4 reflects this new. This new objective and the importance of the need to make sure that the recall process doesn't end with the announcement of the recall. Next slide strategic goal 3 communicate. You know, this would be another example where perhaps. The the 1 to your goal that is literally synonymous with 1 of our offices, the office of communication. And yet again, it's just an example where the entire. Agency is often involved in trying to make sure we're fulfilling. The goal here of communicating actionable information about consumer product safety quickly and effectively 1 note on the change from useful to actionable here with a real emphasis. On the need to get information into consumers hands upon which they can act. Whether that be recall information, whether that be information in the context of an information and education campaign with a real desire where possible. Not only to reach consumers again in that quick and effective manner, but in a way in which they can act on on receipt of that information. Contributing offices in addition, of course, to the office communication leading this effort, small business ombudsman consumer ombudsman. International program and office of general counsel all are contributing offices. As noted in the plan itself. To strategic goal 3 next slide please. As you'll note in the 3 strategic objectives underneath strategic goal 3, not only is that change to actionable present throughout. But also the. The emphasis on diverse audiences reaching diverse audiences that variety of diverse audiences and underserved communities as well. Again, I think it's something that. Is is real renewed emphasis throughout everything we're doing and it's reflected here specifically within strategic goal 3. Next slide please. Goal 4 support so this is a new strategic goal for for the agency that previously. Some of these ideas were captured in 2018 to plan as workforce. But this is a total sort of rethink of how we describe the activities. Of a large swath of the folks here at the agency and the offices and. The work that they do every day to support all the things we just talked about. And so this covers as noted on the slide. Not just our workforce, but also our financial management ethics and government information technology. Where we're talking about the use of agency resources. We're talking about. Information technology ethics, but all these different pieces have now been set out in a way that both highlights and raises the profile quite frankly. Of these vital pieces of the agency, but also sets out performance measures. Within within the concept of the strategic plan that had not previously been there because again. Having those that emphasis and that that raise profile also allows and encourages the opportunity to measure. In ways that we can the vital work that these folks do these offices do to support all of the work of the agency. So, as you might expect, there are more lead offices for for goal 4 than anything else than any of the other strategic goals. This would include. Resource management, financial management, office general council. And the office of information technology with contributing offices, including the office of equal employment opportunity diversity and inclusion. Next slide, please. Set the next slide out. And I should know there weren't any changes from the previous one. And that's like, because there was no previous similar support goal in the 2018 to 2022 version. So, in, in, in wrapping and wrapping this up in terms of. Process and logistics, as has been previously announced, there will be a commission. Decisional vote on. This draft plan on August 10th. Following a commission approval. Of a strategic plan, it will go out for a 30 day comment period. To hear from the public outside state external stakeholders. At that point in time, staff will collect review and corporate stakeholder input. Into a revised version of this draft plan. Present it back to the commission for review. And eventual approval after that point in time after commission has approved it will be adding in the pictures. That are so sort of recognizable from, from our strategic plans in the past. And then we will be submitting it. The plan is concurrently with our fiscal 2024 performance budget. Request to Congress, which historically has been early in February, although. One would note in previous years, including this year, it can be. Far later in the calendar year into March, sometimes late March, which is something that is. Not dictated by any decision of the commission. So, in terms of that piece of it. That is, I believe our last. There's this white slide. So that's our last slide. Thank you so much for your attention. We stand ready for questions about strategic plan. And thank you for. Let's talk about it today. Thank you, Mr. Louie. So at this point in time, we'll turn to questions from the commission. As I said, doing 10 minutes of commissioner with multiple rounds necessary. Again, I believe that the slide deck is still up on the screen. If you could pull that off and move to the individuals that appreciate. So, I will start with myself for 10 minutes. You know, first of all, thank you very much to the staff for putting together this. Draft strategic plan for the commission's consideration. Many of the elements of the work new workforce goal in the strategic plan. Or the, the workforce goal in the past strategic plan or been incorporated on support goal. And I was wondering if you could expand a bit Mr. Levine on the rationale behind the change and how the support goal is different than the workforce goal for previous. Strategic plans. Sure, thank you for the question. I think. Probably it's best the best way to describe it is it does a far better job of. Capturing the variety of. Support administrative and otherwise that goes on in the offices mentioned within the goal. That had not previously necessarily been highlighted. I think they had sort of been sprinkled. Let's say throughout strategic plans, but they hadn't been sort of given. Stand alone opportunities to really be focused on and. So, whether we're talking about internal controls and financial management or some of the very important work that information technology is undertaking. And on and on these, you know, these are really the backbone administrative work. Of that helps everyone else that sometimes gets gets the headlines. Do our work and so I think, you know, we think it is important to make sure we highlight that and then also have that opportunities to have the measurement piece. And so the goal was to bring it forth in a different way than we had previously and. Hence number 4. I appreciate that I do think number of the internal controls and. You know, focusing on the ethics makes a lot of sense along with being able to figure out how to maintain and attract strong talent to the agency. I mean. The staff is the core of what we do. It's not the commissioners to be honest is people who are actually doing the work. So I do think that is an important goal overall. I appreciate the greater emphasis also on enforcement recall effectiveness and rule makings plan. Can you expand on how the key performance measures track the increased focus? Sure. Thanks for the question again. The. There's a number of ways, both sort of at the strategy level and the initiative level. Within the key performance measures specifically where the draft plan has increased focus on these different areas. You know, at sort of the most basic level. You know, elevating prevent to that 1st goal spot demonstrates the need that that's our 1st and foremost we're going out to try and prevent hazardous products from reaching consumers in the 1st place and sort of that that shift just sort of. We're visually in an order of priority. I think demonstrates that, but more specifically when we talk about the actual measurements. There's 3 that I would highlight. There's some others, but 3 that I would highlight right away. 1 would be strategic objective 1.2. Includes an addition of a measure which emphasizes the need to conduct timely inspections of repeat offenders. Strategic objective 2.2 has key performance measures that track the increased focus on minimizing further further exposure to hazardous consumer products through our enforcement actions. And brand new strategic objective 2.4 includes that entirely new measure based on that new objective, which involves monitoring post recall activity. By firms, the measure itself is intended to assist CPSC to identify the need for additional compliance. Enforcement or communications activities in that post recall period. I think it's really an attempt to find ways not only to talk about these things, of course, but to emphasize moving them forward in a measurable manner. And that makes sense. 1 other change I wanted to get a little more information on really isn't the communications goals or the strategic plan that is to hone in on the addition of the word actual to communicating actual information to the public. I want to ask how is this different the previous plans and how will this inform your communication strategies. And sure, so, well, I'm happy to talk about anything like this. I think probably Pam Springs might be in a better place or director of communications. Yes, I did. Thank you. I was going to direct it to Pam. Miss Springs. Thank you so much. Thank you so much. And thanks for the question. I think, you know, I think what we, my goal is to go beyond just pushing out. Recall information safety alerts. That's very important. But what we also want to do is to provide consumers with information to keep themselves. And I'm going to use a word empower themselves to stay safe in their homes with regular, you know, products. So, for example, you know, we've got the anchor at campaign, but there may be some people for whatever reason are unable to anchor. Their, their furniture, but we can still provide them with information to keep themselves safe. For example, you know, keep items that may be attractive to young kids away from edges. So they aren't, you know, they aren't prompted to try and reach for it. So it's, it's providing that kind of actionable information, not just pushing out information, but giving consumers, you know, a call to action, something that they can do to really protect themselves. And in some ways help us protect them through going to saferproducts.gov and reporting their own product hazard experiences and potentially helping other people. So that's really where actionable comes from giving consumers something that they can do to keep themselves safe. Thank you. And one more question for you. How does the agency plan as far as strategic plan to reach out to diverse audiences, including vulnerable and underserved communities? Yeah, that that's very important to me. And thank you again for that for that question. You know, we want to meet audiences where they are. So just at a high level. We want to, we want to drive micro targeting strategies and tactics. We want to leverage all media platforms. Not everybody's on the internet. Not everybody reads newspapers. We want to leverage all platforms to reach all of our communities. So, for example, some of that's actually already going on. We've got billboards in indigenous communities to provide safety information because, you know, we were instructed that that's where those communities best receive that information. So, you know, over the next year we'll be doing lots more of that reaching out on mobile reaching out on radio. Needless to say, the Spanish language is very important. So, you know, broadly speaking, meeting audiences where they were leveraging all platforms and micro targeting where, where necessary also, sorry. Pursuing collaborations with trusted voices in communities as well as with state and local agencies that can help us socialize safety messaging. Thank you very much. I know my time is just about over. So, I am going to turn to Commissioner Bianco. Thank you, chair. And thanks to everyone who has presented particularly Mr. Levine and Miss Springs. I appreciate your input and welcome to Mary Boyle. Our first, our newest commissioner at our first public meeting. So welcome. Glad to have you here. So I have, I have a couple of arching questions. Jason for for you. And you mentioned, you mentioned the different mission statement, which I definitely like better. And there are statements throughout the, the plan, but the one knit, I guess it's not really a knit. It's the, the term that we tend to use a lot is, is unsafe. And that is not in our statute as far as the agency's mission. The mission is to protect consumers from the unreasonable reasonable risk. Right. A farm from consumer products. So I would like to see throughout this plan, those, those adjustments made because this brings me to my, my next point. My next point, some of these terms like unsafe are subjective and we have many terms throughout the plan that are, I mean, we can all sit around and say, okay, I know what unsafe means or I know what timely means. But they're not really defined. And I think that's important for us to do. And that brings me to my question about how are we planning on defining some of these terms. You know, hazardous is another 1 that I saw in strategic goal. Number 1, you know, hazardous means a lot to a lot of different people. It's defined differently in different parts of our statute. I mean, do we have any way to actually put a finer, finer point on some of these key terms. Sure. So, thank you so much for the question. And I would note that the vision statement itself is specifically. Nation free from unreasonable risks of injury and death from consumer products. So it's certainly a recognition of that statutory charge. I think, you know, using terms and strategic plans again remember are designed to be at an enterprise level like prevent hazardous products from reaching consumers address hazardous consumer products. I mean, you're right that that's going to vary depending upon exactly what the circumstances are and the product is. But I think it's a recognition of the steps that we go through on a technical side to evaluate a given product. And so that may be a circumstance where there's an existing regulation that has by commission. Vote and publication in the federal register of code of federal regulations deemed essentially something to be hazardous and hence we are are working to get it off, you know, out of the marketplace. There are going to be other circumstances where it's more of a defect sort of question and we're going to have to try and determine through the technical work that we do and hazard reduction to test and determine whether something is hazardous in the context in which the product is being used. So I think I'm not sure that I would use the term subjective personally, but I do think it's going to vary based on the circumstances. Has there been any discussion of having any type of glossary to define the terms as used in the strategic plan or is that something that has been dismissed? Or it's just a bad idea. It's just a question that I had as I was listening to you speak. Sure, I'm not to be honest. I don't know the answer to that question. I do know that when we get more, when we get to the operating plan and the budget request documents, you know, that is another level of specificity that we do lay out in terms of some of these priorities. But in terms of definitions of words, you know, I'd have to get back to you. I think our goal is to get a plain language. Sort of, you know, sort of the goal and in the strategic plan, and then get down to that, that more definitive specific level in these more annualized directional documents. Okay. So I'm going to beat this dead horse just a little bit more. In looking at the key performance measures. And a lot of things have in here percentage of percentage of number of, but it doesn't the performance measures don't set out what those percentages are what those number goals are. I just wanted to get your input on that. Sure. And thank you for that. And I think this is a common question for this strategic plan. So you asked it first, but others might be thinking it as well. So the strategic plan lays out the the key measures over the course of the period of time covered by the strategic plan in this instance fiscal 23 to 26. It's then those annualized documents I mentioned the operating plan and the budget where each of these measures will then have specific numbers attached to them. And so they might vary from year to year based on previous year's performance resources priorities in terms of where the commission might go in a given year. So if a number, let's say of imported products to be examined is 40,000 in a given year. It might be less or more the following year, depending upon commission direction. Okay, that's helpful actually. Thank you very much. One of the things that I've been thinking about recently is, you know, we have safer products dot gov for people to report their experiences with products. Have we talked about and maybe it's not appropriate for the strategic plan, although I think it could be some type of program where members of the community can report when they see they're online, they're about to buy something and they see a band product because I think it would help have to have something other than safer products dot gov dot gov for people. We're stakeholders if you will to report into us because you know we can't monitor every possible site at every possible time. So do we have any plans for for something like that. Certainly something that has been. I think discuss I know that you've mentioned it before and I think we're going to try and figure out the best way to accomplish this and certainly. Certainly safer products dot gov is 1 place to receive information from consumers, but you know we should be open. The hotline is another place and general sort of incoming information from via email that the commission receives. But you know it is sort of to our benefit to find ways to receive important information like that from consumers at the same time. You also need to be mindful of. Trying to brand something in a way that so that people know where to go and find it. So I think that's the balance we're trying to strike, but look forward to trying to figure that out. Yeah, safer products dot gov. I'm still not seeing it as a user friendly site. And to have somebody, you know, I take these calls all the time as I'm sure a lot of us take these calls where somebody picks up the phone. It's a commissioner or a staff member. I see this I'm going to buy this and I see this product has been banned for 5 years. Why is it still up there? And, you know, I'll pass that along. We all pass along, but we really don't have a channel for that and safer products dot gov. I just don't think it's intuitive. First of all, to report something like that on safer products dot gov. And then secondly, it's safer products dot gov is still very user friendly and in my humble opinion. So I do think that should be made part of the strategic plan. I think it's important, especially for limited resources to have something like that. The talent section and the workforce section, I think is a is a nice addition talent is key. I am looking forward to, I know we're a little down and headcount. So I'm looking forward to putting that into place. And I do have some questions about post recall, but I think I'll hold those for now. And I think my time's about up and I can follow up with you on that. Thank you very much. Thank you. Thank you, Commissioner Bianco, Commissioner Feldman. Thank you, Mr. Chairman. And thank you, Mr. Levine for that presentation. Just to start off. I appreciate all the questions that my colleagues have been asking. I think that's thoughtful. I very much agree with Commissioner Bianco that what what is the language that's included in the strategic strategic plan should mirror. Our statutory directive just so that we're not introducing extraneous ambiguity into our various documents across the board. I think that consistency is important because it lends itself better. I think to clarity, but I wanted to get to my questions and in the chairman mentioned that that that staff is the core of this agency and I agree with that. I believe in particular that with a planning document like this, an important planning document like the one we're considering today, we all have a role to play and we should be hearing from all employees agency wide. I know that when the commission developed its strategic plan the last time, which was the original strategic plan at CPSC this process involved in agency wide canvas. I think that we should be seeking input from the frontline staff to the 7th floor and everybody in between when when dealing with something like this. And to that end, I'm currently in Los Angeles. So I apologize for the spotty Wi-Fi if that ever becomes an issue. But I'm here with my office where we had an opportunity to meet with our import surveillance team at LAX in the ports of LA and Long Beach. And I'm pleased to see that because of the efforts that the commission took back when we considered our current operating plan that this import surveillance team is more than double than size. And working together with CPC, we're interdicting now more dangerous products from entering domestic commerce. But in the tour that we took yesterday, we had an opportunity to sit down with these frontline workers and to have them share their thoughts about what's working, what isn't, where the commission should be headed and that kind of feedback is always invaluable. So with that in mind, Mr. Levina, I was hoping you could talk a little bit about how this plan was developed and specifically who was consulted. I understand that this was a very collaborative process the first time. So I do have some questions about what your plan of attack has been. Sure, I appreciate that question and glad to hear that it has been a good experience out at our ports in LA and Long Beach. Our folks at the ports and in the field are, you know, in any ways the face of the agency. So I'm glad to hear and do such important work. So glad to hear that's been going well. With respect to development of the draft plan before you the work started. Last fall after, after confirmation of the chair with a. A general consultation with a planning committee that consisted of a variety of staffers and a general consensus. Internally, I admittedly at a leadership management level to base this strategic plan on the existing plan. I think it's important to note. The, the most recent, the current plan as it were that we're operating under was a rewrite of the original strategic plan that was done. I want to say somewhere on 2011 or 2012. And so the thought was, well, this was a, this was a rewrite. And fundamentally was something that people felt comfortable was. Efficient in achieving the long term goals and. Did not necessitate a complete rewrite because we're already off cycle a little bit. With sort of where we were in the cycle. So the, the, the consultation with staff went through. Man leadership of the variety of offices with a real desire to include more offices than had previously been involved as you see. The existence of strategic goal for which then led to a. The continued development followed by the priorities hearing in April, which. Also helped inform the document in front of us. It's as, as you all know, where the. Community stakeholders can come in and talk about their thoughts on our priorities. And then it went back through the wash of the rewriting financial management heads the. Bringing together of the document itself, but again, with a regular consultation with all the variety of offices that are impacted. By the strategic plan, so it was not an agency wide survey, certainly, but it was something that was developed in consultation with all of the offices. You know, at a staff level to present the document in front. I appreciate that answer. I have no further questions at this time. We're still continuing to review. The slide deck that you put together today and also the, the underlying language of the plan itself. I do appreciate the work that you've done. I, I do wish that this process had been more inclusive of folks other than just senior agency leadership at a. A planning committee stage, but in fact included agency wide canvas. But, but, but again, we're still reviewing. Thank you. Thank you. Thank you, commissioner commissioner Trump. Thank you. So, you know, as we think through this strategic plan, I'd like to take a little time to reflect back on where this process has taken us in the. So, how would you describe our biggest achievements and successes and meeting goals under the. I'm sorry, you cut out a little bit there. So, I'm not sure what the end of that question was the end of that question was, how would you describe our biggest achievements and successes and meeting goals that we said under the 2018 plan? Well, I mean, that's an interesting question because I think the the unusual factor when we look at the strategic plan as any strategic plan, you know, ours or other agencies is that because the individual measures aren't built in. To the plan itself, as we talked about sort of the annualizing of those specific measures. It's hard to sort of specifically benchmark, did we meet or not meet them specifically because the, the, the numbers themselves, the actual mark you're shooting for changes annually. That said, I certainly think a lot of the. The previous or his current plan had a real focus on developing a. A more thorough recognition of the, the need to address things like e-commerce, the need to put in place plans, even just develop them for areas that the agency had not necessarily previously. Really focused on in the, in the data gathering space and enforcement space. And I think it did a good job of sort of. Really making that transition for us from a period of time to just post CPS, where the agency was thrust upon a whole host of new requirements and new areas to take on and get us sort of to now. That's part and parcel of the work that we do. We need to build up plans and make sure we're implementing all of that. And now I think what you have before you is that next step that strategic plan that's going to take us moving forward. To the new reality in which we live that CPS, IA authorities are built in and baked into what we do. And how are we addressing that moving forward the e-commerce piece and our recognition of our new new. The new world in which we live from both an e-commerce and an IT space. So I don't know that I have a specific. We did this and didn't do that, but I think it's more about the sense of they built a pretty good foundation. Now it's time for us to start furnishing the house and make sure it's it's doing what it should do. And I think you're right that the e-commerce is definitely an area that the agency made great strides in under under that last period of strategic planning. But, you know, I do think it's important if we're going to go through this exercise, which obviously we have to go through this exercise that we look back at the end and measure up those year to year goals that fit within the strategic plan and see how we did and I hope we do that for years from now and see how far we've come. What about areas that we fell short in meeting goals under the 2018 plan? Well, I mean, again, I think, and by the way, I'd be remiss in saying not not noting, you know, there were things that we put in there, like making sure we're dealing with we're starting to think about AI and machine learning and the the ideas of how to really address hazards in a way that we hadn't sort of significantly taken on before. But to your point of what we missed again, I think. Because we don't measure it from year to year. It's hard to say. We did start. We do measure from year to year. We don't measure it within the context of strategic plan. What we can say, and I think a better way of thinking about it is in circumstances where things look as if we needed to essentially keep the same goal because we're still moving forward in a way that we're not. That requires an implementation of a plan. That means sort of, all right, we developed it. Now we have to implement it. Maybe there are areas and I need to go back and happy to do this. 1 by 1, but areas where we thought maybe we'd be able to develop and implement a plan in a 4 or 5 year period where we developed and we hadn't really had a chance to do that implementation. But I need to go back step by step, but again, it's this is more of a direction for us to build in those year by year goals. And our operating plan and budgets as opposed to measuring against strategic plan itself, which is why it's such an excellent exercise to regularly refresh it. Yeah, and I would really love to have that conversation with you within the next week. About those those things that you were talking about that we didn't have time to implement and we have put them back in this plan so we can finish that job. So I'd like to understand. What those are and why we are where we are on those. You know, I think 1 tremendously positive improvement in this plan over the previous 1 is the inclusion of a focus on deterrence as a tool that we can use to. Prevent firms from bringing dangerous products to market and from from keeping those products on the market. For example, we explicitly mentioned using civil penalties and criminal penalties, penalties everywhere they're appropriate. Can you explain how our approach to using deterrence will be different from the past if we adopt this plan? Well, I mean, I think there's a real recognition of the. Of the value of deterrence in the use of civil penalty authority. And that that is something. And even to the extent criminal referrals need to be made in certain unusual circumstances. That is not to say that the commission had previously never undertaken civil penalties. But by putting it front and center within the strategic plan context. It highlights the value of the tool and the importance of the tool. Should the commission adopt the plan to the commission and so I mean, I think it's. A recognition that recalls are intended to get that hazardous unreasonable unreasonably risky product out of the hands of consumers. But the civil penalties when we are talking about them. Particularly involving lateness or other violations that lead to a civil penalty circumstance. Aren't the recall isn't isn't isn't alone going to necessarily deter. That behavior and criminal and the civil penalty does allow for that. And ideally sends a message to other similarly situated first. That the commission believes that this is important enough to take the time to make sure that everyone knows. And I think that's an important distinction you made. So to deter this company from, from the same bad acts again, but also to let everybody else know. So that they're deterred from, from taking similar actions with their products. So I've got several questions about how we approach chronic hazards in this plan. And I think the 1st 1. Is just a point of clarification. But the description of our approach to chronic hazards has a focus on new products and new uses of older products. And I think that just seems to be lead in language, but, but, you know, because we're learning that new information all the time about. Existing hazards in our home PFAS know of ours or 2 examples out of many that come to mind. So we can find out in the future that we've been living with chronic hazards and products we're using the same way all along. And, and I think that the wording gives the impression or it could give the impression that we're focused on new products and new uses. I have to imagine if that's my reading that's that's an unintentional consequence there, right? But I just wanted to confirm that. I would think so. I mean, I need to look at the language specifically, but I mean, I think. You know, look, the state of science knowledge is always going to continue to evolve. And so what may have previously been seen as an acute hazard turns out not to be, but turns out to be a chronic hazard. And so. While that can be a new product, it can also be a newly understood chronic hazard. In an old product. And so I think that's the goal of the description. And I think the approach that the staff takes. Well, that's good because, you know, if we find out this has chemical X in this coffee mug that I've had for 10 years. We don't know it's dangerous today. We find out it's dangerous tomorrow. We're not saying that we're going to ignore that. I just want to make sure it certainly should not be read that way because that's really not going to be the approach. Excellent. And then suppose that that happens or suppose that we want to add to the operating plan next year. A direction to more quickly address several specific emerging chronic hazards. There's nothing in this document that would impede our ability to move quickly and addressing those hazards. Is there. There shouldn't be again the. Not there's no specific product. Listed in a strategic plan because that's not really the goal of the of the plan itself. It's to allow. An overarching enterprise wide framework for how to approach it. But the decisions as to what to go ahead and enforce or regulate. Or research or any of those different pieces is going to be made on an annual basis and at the commission level based on. Policy decisions available resources science, et cetera, et cetera. So no, there shouldn't be anything in here that impedes. Anything, of course, other than I guess jurisdiction. I'll just ask 1 last question on chronic hazards and I'll wrap up this this segment here. The draft plan didn't carry forward. An initiative that was in the 2018 plan to enhance our coordination with relevant federal agencies to address chronic hazards. Yeah, I think maybe this could tie into what you were talking about before, but can you explain why that coordination initiative wasn't carried forward. I would need to go back and take a look at exactly the change and whether it's. What I think I want to double check this, but I think that got moved, not not removed. I think it's now a recognition. I believe that's now. I understand an external external factors, I think is now. So I think it's still there. We'll go back and check. I'm pretty sure that coordination level. In fact, I remember reading about state and federal coordination on chronic hazards. So we'll just need to find it located, but if not, we'll get back to you, but we'll certainly. Particularly because the size of our of our bill of our of the agency and our resources, we are going to continue to have to work with our federal partners on on these issues because they are often so much bigger than us. And quite frankly, you know, our resources are limited and trying to get after some of the science in a way that we couldn't do alone. So one way or the other. We're going to be doing that. So we'll get back to you on the details of it. But the idea is we're going to need to leverage federal partners because for a variety of reasons. Agreed. All right. Well, well, thank you. I appreciate that. Thank you commissioner commissioner Boyle. Mr chair. Thank you for your warm welcome. I'm really incredibly warm welcome I've received from all my colleagues and the staff with really gratified by the good wishes and support that I've gotten. Really happy to be here and hit the ground running. So thank you for everyone from everyone. And I guess Mr. Levine, I'll continue the course of appreciation and thank you for a very well done presentation today and very well done draft. I wish you the best of luck in your vision and today's any indication you're going to do a great job. So thank you. And of course, thank you too. I know all the staff work that goes behind these documents. So, you know, who I'm talking to out there and I appreciate all of you very much. So there have been a lot of thoughtful questions. So I think I'm going to spend most of my time, providing a couple of comments. I think I'd like to start with seeing what I liked about the plan, which was a lot. I did like the shift in the focus of the first two priorities to enforcement and prevention. I think that was an important change. I agree with Commissioner Chonka, I like to focus on civil penalties and deterrence. I also was very impressed by the focus on the disproportionate impact of hazards on certain populations and I was particularly happy to see that moving throughout the whole document and not just confined to one area that was really important. Like the emphasis on improving data and we call effectiveness and I also like the emphasis on increasing collaborations with state and local entities. So I think all of those things were good things and I was happy to see them. There is one area and I think I'm going to be pulling on a little bit of a thread that Commissioner Trump could just talked about that I thought perhaps didn't receive enough attention. And that would be chronic hazards and I'd like to ask you about that and ask you to comment on that whether you agree with that characterization or just how we thought about how the staff thought about incorporating chronic hazards and in particular what we were going to be doing about chronic hazards. Because I would note on where it was referenced in the document on page 7 and 10, there was a focus on identifying, researching and informing the public about chemical and chronic hazards, which is really important, I agree. And then the initiatives on page 10, we again say we're going to identify, evaluate, acquire and integrate data sources pertaining to chronic hazards. But I frankly think there was the address part that was a little bit missing. This is a four year plan. And I just want to ask you to comment on that. Well, I mean, so thank you for the question and before I even get to that, thank you. Really looking forward to the opportunity of working with you and this new role that I'm in and this new role that you're in. Thank you for your kind words. I think specifically with regard to chronic hazards, I mean, they're clearly going to be a key focus going forward. You know, there's a variety of different ways we have historically and I think continue to plan to try and get after chronic hazards. Whether that be from a standards perspective from a manager or a volunteer, whether that be an information education campaigns and I think most importantly, from that research perspective. Now, the address piece only comes after that last one, right. The research and I think what we have historically struggled with and probably will continue to is identifying the available resources to determine how we can act. On given chronic hazards, particularly in a chemical kind of circumstance, but there's no to the extent there's an impression that the idea is just to identify and walk away. I certainly think that that's not the intent of the plan. So maybe, you know, we need to make sure that we are identifying within the plan areas that be clear we're going to address. Where we're going to go after items, but I think once I think what's a little bit different on chronic hazards is that once we've identified. The hazard and the approach, then in many ways they become like any other hazard and we then move over into the how we address it from from an enforcement perspective. The identifying is obviously much harder than the chronic hazard circumstance. I think hence the larger emphasis on that identification, but we'll continue to make sure it's a key focus. And if we need to make sure that that language is clear, we're going to do that. And, you know, but if we think about, you know, think about phthalates and how long that's taken that was the statutory construct. You know, it sometimes can take a long time, but we're not letting them go. No, I think you make a great point about phthalates and lead. I think the agency has done a tremendous job on those 2 items and I think we can do, we can expand that portfolio in terms of taking action. And so I just encourage that. The 2nd question I had has to do with the appendix a and the external factors that you identify. And I just sort of would like to ask you about those factors and particularly you just to it resources and how that affects the development of the strategic plan where there are areas that you all considered and just left out altogether just because. The reality of limited resources that we face. Um, I don't think that there was a sort of entire category that we left on the floor. I will say, and that's sort of part of the purpose of having an external factors list or discussion is that there are things in the plan that aren't necessarily. Funded as robustly or maybe even in a realistic way, because of our limited funding. So I think the plan covers is realistic. But it's probably leans on the aspirational side with respect to available resources. And I think you'll note throughout the plan where we talk about some of the challenges involved. In terms of achieving the goals. And some of them really do go to resources and chronic as a perfect example of that. We're in terms of having the ability to spend the money to to conduct the research. To get to answers to then get to address those, you know, some of those are not even traditionally been at our baseline appropriation. In terms of the dollar figures that we're getting back from Congress. So I think. The, if you go before appendix A, I think that it covers what we're what we think needs to be covered to fulfill our statutory mandate. However, I think it's a recognition of the challenges, most primarily resource, but some of them, you know, on the science that we are facing. So if we had unlimited resources with with this document with very much different or it's a matter of degree. I like imagining a world with unlimited resources. I think it would be more of degree. I mean, I don't know that we've ever contemplated a strategic plan with unlimited resources. I think we try and be more or less realistic. But I think it'll be more of degree. I mean, I think that the staff real realistically try to try so all the time scope out the, you know, the areas of consumer product hazards. Based on what we can address and sort of filtered through an analysis of the most risky. Consumer product hazards. If we, but as I noted, since the plan doesn't list specific product hazards. We would just get to do more and more and more as we work down through that that risk scale list with greater resources. But it's certainly an ambitious concept that that is captured in the plan and unlimited resources would allow us to fulfill it all and maybe even more. Fair enough. Fair enough. Okay, just one other on the key measures and I could have missed it so apologies if I did. Given the new focus or increased focus new focus on civil penalties and deterrents. Is there a key measure on that topic. I know it's hard to do, but just wondering if there is one. I don't want to misspeak. I don't. I know 1 of the things we added, for example, was the measure, including that notice of hazards being issued where previously we hadn't really made that part of a measurable. But I don't believe I'm sure someone will correct me if I'm wrong. But I don't believe that there's a specific key measure tied to civil penalties. In part, because some of that is, is going to be really variable from year to year. Ideally, we live in a world where we don't need civil penalties. And there may be years where there's significantly more of them. But there's nothing right on that point. I think we try to capture more of the activity that would sort of lead up to it to that circumstance. Well, thank you very much. I am out of time. And again, thank you for great presentation and all the staff work that went into it. Thank you. Mr. Thank you, commissioner. I would ask my fellow commissioners if they would like another round of questions. Getting a yes from commissioner. So I will go in order then and start with commissioner Bianco. Did you have additional questions? Thank you, Mr. Chair. Actually, I just have two follow-ups from commissioner Boyle's points and questions. I think that one of the having a key measure for civil penalties would be very difficult. I mean, you can't find conduct that doesn't exist. So I would be interested in hearing some of the other potential options, I guess, on any type of measurement under that category. And I really, really liked commissioner Boyle's question about if you had unlimited resources, you know, what the document looked differently. I think that's a great place to start when we're doing these types of strategic plans. I mean, if you had unlimited resources and believe me, I think about it every day. Unlimited resources, you know, jot down what you would really like to have and then, you know, take out things that you just can't, but it would set up goals for us to work for or to seek funding for as we go along. Because I can think of a lot of things that we should be including in the strategic plan, but we don't, for lack of, we just don't have the ability to implement them. I'd like the concept of start from having unlimited resources, what we would like to have. And there are things I think that the commission can do with that information. So thank you for that point. I think it was a very good one. And for now, I don't have any additional questions. So thank you. Thank you, commissioner commissioner Feldman. Do you have additional questions? Thank you, Mr. Chairman. Again, I appreciate the discussion at this point. I do not have additional questions. Thank you, commissioner commissioner Trump. Thank you. And let me follow up on that point that that. Commissioner Bianco and commissioner Boyle made there about the unlimited funds. You know, I think what we could do with that, as we started thinking through those things that. Don't get funded if we could point to Congress and say, you cost 5,000 lives this year that we otherwise would have saved with appropriate spending. That would be super useful next year when we go into appropriation. So it could be it could be a good exercise. But so is it possible to put the strategic plan document up on the screen because I have questions about. Specific language and the key performance measures in appendix D and it'd be helpful to have that up there while we go through that. I don't know that. Yeah, Cynthia is working on that now. Yeah, I mean, we have well, no, we have this is the slide deck. I think what commissioner is looking for is the plan itself, which I don't think we pre. I don't think we have somebody just, I think Dan just emailed a PDF of it. No, no, that was the PowerPoint. Never mind. But yeah, so we should be able to share it. But I think it'd be useful, but I can get started without it and read that while we're pulling that up, but I would really appreciate it. I think it'd be much more useful to go through if we have up on screen. So strategic objective 1.2. There are multiple performance measures within each 1, but I'm talking about the 1st measure there. The percentage of firms that are engaged with a timely establishment inspection after being identified as a repeat offender. Can you explain what that measure means? Sure. Thank you for the question. So the. There's different pieces of this. Obviously, the percentage piece goes to the specific year over year as we discussed how we measure how we're looking to measure that. And that could change on an annualized basis. The. The goal here being, particularly when we're talking about. Import context, import surveillance context. Quite often repeat offenders are likely to repeat again. And so are we it is it is an acknowledgement of the need or the the conclusion. Again, based on limited resources and can't inspect everyone all the time, where do we focus our enforcement efforts? And 1 of the things we choose to focus on is in the area of repeat offenders. Are we able to. A timely fashion, which is going to vary depending on the context of the case involved. Make sure we are conducting that that establishment on on premises inspection. Which it's an acknowledgement of best practice that has previously existed. But an attempt to raise the importance of this activity as well as note. It's not just important that we're doing inspections and timely fashion or an establishment inspections, but that repeat offender group is going to get that special attention. And as effective and efficient of ways possible. So it's mainly raising something we already doing and making it a. A goal in and of its performance measure in of itself. The concept sounds like something I entirely agree with. I just don't understand what we're talking about the you mentioned import. Are we doing establishment inspections at foreign manufacturing facilities? I mean, what what establishment are we inspecting and for what violations. So, no, so let's start with, we are not doing our jurisdiction does not. Extend in that way to inspect in. In that fashion, this would be inspecting the establishments of importers upon, you know, they're having received. Imported goods got it. Alright, so a strategic objective 1.2. The 2nd measure within that and that is the number of voluntary standards activities in which CPSC actively participates. That doesn't seem like a measure that has any variability. I mean, don't don't we set the number and identify the exact voluntary standards that staff will participate in in the operating plan each year. Yes, but it changes annual basis. Well, the number might change, but unless there's the number changes, but, but this doesn't set a number. So, if the operating plan said, let's do 80 this year and here's the 80. Unless staff disregarded that instruction in the operating plan, this would always be 100%. So does it still make sense as a performance measure if it can't be anything about 100%. I'm not sure I fully understand. I mean, the commission could set a number that staff for a variety of reasons. Didn't meet met or exceeded. I'm not sure. Maybe I'm misunderstanding the question. I'm asking why we're setting a performance measure in the strategic plan when in the operating plan each year, we do give the exact number and the exact specific voluntary standards. It seems unnecessary to have a performance measure that's so unlikely to not be hit. It makes more sense to just keep it each year in the operating plan, doesn't it? Sure. So, um, I believe the answer again, if I understand it correctly, is that the, the, the measures that are in the operating plan are, are, are tied back to the strategic plan. So, because it's because it's here in the strategic plan, it's going to be in the operating plan. But what that level is is going to be set on that annual basis. But again, I'm not sure I hear what you're saying in that. Well, it could be met depending on what that level set is. But the reason that it's that it's here is because it's part of what you every year. But this doesn't the existence of the measure in the strategic plan doesn't have any influence on what that level setting is by the commission. It could be the same. Let me ask that a little bit differently. We could put it in the operating plan every year without having this as a key performance measure in the strategic plan. Yes. Yeah, I believe that's accurate. Yeah. Yeah, I don't think it's necessary to have this 1 since we do set this 1 specifically each year in the operating plan. I think that that that is accurate. I think. I would note the overwhelming and I think all of these wind up in the operating plan and it's certainly accurate. Just go to add things to the operating plan. But it's true for for anything anything that's a number. Also, maybe falls in that same category, but yes, it doesn't have to be required. And this is a more general question same topic about voluntary standards, but I just want to say, I mean, I'm sure you agree that it makes sense to evaluate participation and voluntary standards. On a case by case basis instead of something more like an across the board strategy of always seeking a voluntary standard before we begin rulemaking is that fair? I'm not sure I fully understand the question because some constructs were required to by law. Others were not so, but I would say, yeah, as a general matter. We should do everything on a basis and where we're doing some analysis on a case by case basis unless mandated by Congress. I appreciate that. I think the mandate is if a voluntary standard exists that takes care of the problem. We can't do rulemaking. So, if it doesn't, we can do adequately address. Yes. Yes. Thank you. So, in strategic objective 1.2, the 4th measure recalls per billion dollars in consumer product imports for top 50 import sources countries for administrative areas. Can you unpack what that 1 means? Sure. So, this is a sort of this is 1 of those examples of something that involves multiple offices. Obviously our import surveillance, but also our international programs in terms of. A measurements and it's sort of in some ways it's. It is a way to determine a metric for what the dollar value is of what we're recalling. Not just sort of from around the world from the 185 plus countries, but sort of a way to distinguish the larger group that the top 50 gives us a sense of sort of where the majority of issues are. I'm saying it poorly. It's basically it's a relative measure to allow us to sort of look at top importing countries and the recalls and it allows us to sort of track on an annualized basis. Sort of that relativity. So, as we set this goal each year and the operating plans is our goal achieved by more recalls per billion or less recalls per billion. Well, the goal, I mean, the goal would be. I mean, the goal to reach the goal, we have to reach the goal. So I'm not, I'm not sure. So depending on where. But what I mean is if you set the goal at 20 recalls per billion dollars from these groups is 19 good or is 21 good. Which side are we trying to get to? Well, I mean, again, because it's a relative measure, I think what it's mainly giving us is data on those top 50 company countries. And it helps us determine where to focus our energies and resources, but I think it all depends on sort of how one chooses to look at recalls is the goal to be fewer recalls because that lets us know that we're doing better because there are fewer violative things in the world where's the goal more because we know that there's so many out there and we should be making sure our numbers are always going up. I think the value of the metric is actually just allowing us to target. I mean, it's a key performance measure, which means we're going to be setting a percentage or setting a number in the operating plan and we have to know whether going higher or lower is what we're trying to do. Well, but that's where the target is. I thought you're asking, do we prefer to be under the target or over the target? Well, we want to be over the target. I think more recalls per billion. We want, again, it is a relative. It's a relative effort allows us to. I guess I'm just not maybe I need to sort of go back, but our current goal is less than 0.33 per billion. If that helps. So, ideally, we want to. That does help. Yeah, so we're trying to lower. Okay. My time has expired, but maybe we can finish this up later. Just to make sure I understand I have more questions, but I'll wait for another round. So, sorry, I should just told you the number that would have made life a lot easier. Thank you, Mr. Trump. So just to be clear, you want another round of questions. Yes, please. Commissioner Boyle, do you have questions? Thank you, Mr. Chair. Less a question than just a comment to thank you to Commissioner Bianco and very much appreciate her comments. I agree, especially on the performance measures for penalties. That might not be something we could actually do, but I do think it's worth looking at since we're sitting at something that we're prioritizing. It could be something along the lines of timing the number of cases that we've evaluated on whether the civil penalty is warranted. I mean, they're, they're probably better ideas that just popped into my head. Okay. But I agree. It's very difficult. But I do think it's something that you are prioritizing with possible to put a measure in for that work to reflect these that work that people are doing would be something worthwhile. So, and then that I don't have any additional questions. Thank you, Mr. Chair. Thank you, Commissioner and start another round that some of the commissioner Trump can watch on. I'll start with myself and I think I've been advocating for more resources for the agency for a long time. I think the agency is significantly underfunded and we could do a lot more with more resources and I think all the commissioners have agreed at different times with that concept. I would worry about spending a lot of time thinking about what the world would look like an unlimited resources because we had unlimited resources. We'd be doing so many different things from reaching out to individuals in their homes a minute they have a baby to, you know, to tremendous more research and exploring a different. You know, hazards that are that are out there. So, I think we need to balance that in the end of the day. That's all I'm saying you want to be able to figure out realistically. What do we do because we don't want staff to be thinking on ideas that we all know will never reach at the same time. TG plants need to be forward looking. They need to be aggressive and they need to be able to think about things that we would want to do. And honestly, on some levels may never achieve because we want to be able to push forward. So, I agree thinking broadly makes sense. I would just want to balance that out going forward. And then with respect to the different metrics that are in there. You know, Mr lean my understanding to some degrees that we have these metrics set forth in the. The strategic plan and because they are in the strategic plan, they necessarily need to be reflected in the operating plan. Is that fair? Yes, that's correct. So, while we can add additional metrics in the operating plan by having it in the strategic plan becomes a basis by which we will then. Staff necessarily will figure out what those metrics are. Is that fair? That's fair. I guess I would also add, it's just to start. It's not to say that we are limited. Operating plan or budget requests to only talk about the. You perform to only use the key for one of that measures. That are in the strategic plan. But we do start those documents with these key measures. But I will also note, because it's a 4 and 5 year period. There have been instances historically where for a reason sort of the commission determines a key measure. Several years after the strategic plan was written is no longer really valuable to the work of the commission. The commission can choose to change that or or delete it or adjust it. But traditionally speaking, we start here and then we build from there. So, if it's issues like working on voluntary standards, which is part of our statute. That would mean that the operating things would need to have them in the strategic plan or for civil penalties. If we put something in for civil penalties, it would be necessarily included in the operating plan or other. Metrics with respect to communications or any other. So it's really setting. Boundaries on the staff as to what they're going to have to consider over the next 4 or 5 years. Right that appreciate that clarification. I'm going to turn to Commissioner Bianco. If you have additional questions. Yes, I don't want to speak for commissioner Trump or Mr. Levine, but I think at least what I'm hearing is the. The confusion on on the questions is that the way the performance measure is drafted. It appears to assign a specific number to a specific amount of dollars. And as I mentioned earlier with the civil penalties, if you don't have. Violative conduct, you can't say we're going to have 21 recalls if there's only. You know, 10 or 19 that that we measure as needing to be recalled. So, I think that is what I'm hearing is the confusion that at least for those performance measures, it's giving, you know, assigning a particular quota, if you will, or number that's causing the confusion. But more, more importantly, I think the point is this, we need to go back and look at some of the metric measurements. And I think commissioner Boyle was was right on when she said, come up with, you know, let's think about this from a different perspective. Some other ideas that would would serve as a strong measurement of our objectives, because I agree with you, Mr. Levine, if, if there are less recalls, we are doing our job better at least, you know, that that's the concept. So, I think maybe going back and looking at some of these measure measurements, I had some questions myself about the esoteric nature of them that might clear up some of the some of the confusion just throwing that out there. Thank you. Thank you. Thank you, commissioner term, commissioner Trump. No, I'm sorry, commissioner Feldman. Thank you, Mr. Chairman. I have no questions at this time. Thank you, commissioner Trump. And these are going to go back to appendix D. So, if that document was available, it would be useful. Mr. Trump, I believe you're muted. So, so I am. Thanks. Um, but so, so this goes back to strategic objective 2.1 at the 1st measure there. The percentage of cases for which a preliminary determination is made within 85 business days of the case opening. 85 business days is more like 120 calendar days and and that if 85 business days from today takes us to the week of. So, what are some shorter timeline goals than the 85 day mark that we could consider for this measure? I'm sorry, commissioner, which goal are we talking about? Strategic objective 2.1, the 1st measure within it, the 1 that starts percentage of I got. Okay. I got you now. Okay. And so your question is. Could the could the measure be fewer days? My question presumes that the measure could be shorter. But what are some shorter timelines than 85? Business days that we could consider here? I just want to be clear for this measure, for this specific measure. Yes. Yes. Okay. I believe this was actually a change already from from previously from a previous number, but I wouldn't want to speak off the cuff as to what that number might be. And I think. Right, the goal is always going to be both getting it done quickly, but also getting it done, right? And so, you know, the distinction for, as you certainly know, but for the public, right? The preliminary determinations are going to vary pretty dramatically in terms of the difficulty of the matter in which we're examining. So, obviously, we can go back and sort of come back with the conversation about changing that number. And I also think it'd be important to understand sort of how. How staff has done with respect to meeting the goals laid out by the commission for this sort of metric. In the past, that also helps inform the question of, is this the right, not just the right, right measure, but the right percentage. You know, so, so that I think that is the same as the 2018 plan for this measure. I don't think the 85 days change. Okay. Sorry, I'm sorry. I think of the 90 days on the next one. So, if, if you, if staff could propose some possible shorter alternatives for that 1 that we could talk about within the next week, I think that'd be great. So, I'm sorry, I just want to be clear. Shorter than 85 or this specific measure, that's right. Yeah. Okay, okay. And then strategic objective 2.1, the 3rd measure percentage of cases for which a corrective action plan. Is accepted or public notice of hazard is issued within 90 business days of preliminary determination. So, so this is where we've ID that a hazard exists that we want corrected. And we're working towards a recall cap. Now, my, my question is, is based on this, you know, this strategic plan is a public document. And so the parties that we're negotiating caps against can see our timeline goals. And they know they have at least 90 days to get their ducks in a row before they have to agree to a cap here. And I think many see a benefit to delaying the public announcement. It gives them time to line things up and put spin on it. You know, get their affairs in order to get things ready. And a lot of people take as much time as they can at this juncture. If they saw that our goals here were something shorter, say, 30 days, they would know they had to work faster. And I think we could expect to see quicker cooperation from them. Couldn't we? I really don't know, as a matter of sort of categorizing. Tire panoply of different sorts of firms with which we work and how they choose to approach product safety. Some are very eager and willing participants in the process and move far quicker than others. You know, we do, I think I want to say over 200 a year on average. So, I, you know, I'm not sure that we can say sort of definitively that simply. Changing that number in any direction would. Distinctly influence behavior, but you know, it's hard to know. Hard to say the 1 thing that I think I learned from working at a law firm years ago was that. Work in negotiations is gaseous, you know, whatever your end timeline is, you will expand to meet it. And if it's shorter, you will meet it there too. And so I think that a shorter timeline here would be very useful. And it is a goal you mentioned 1 to see how we've done it. It is a goal that we've done well on in past years. We hit that at 75% last year. So, the next 1 is strategic objective 2.2. The 3rd measure within that the percentage of fast track cases with corrective action plans initiated within 20 business days of case opening. 1st question there is, what is initiated me it's, I mean, it's got an internal definition in terms of when we start the clock. Remember fast track cases are brought to us through the now through our through our portal with businesses in terms of companies bringing to us a product for which they want to conduct a recall. And while the portal has certainly streamlined that process, it is not necessarily meant that everything we get is complete enough to initiate. To start, let's let's not use the word in here to define it to to begin the process of conducting that recall. So. Initiate would be at the moment that staff determines we have received sufficient information from the firm. To to begin the process and also includes a manufacturer agreement to. Telling us, I should say that they have stopped sale of the product. It's a 2 fold process and this is 1 that we've done like unusually well on in meeting this goal. So, 2018, 96%, 2019, 97%, 20, 20, 97% and 20, 21, 95%. And in the most recent budget, we have our goal set down at 90%. But in order to keep pushing ourselves forward here, do you think we'd be better suited to lower the number of days from 20? To increase our target to above 97% or to do both. I would need to go back and look at the numbers behind the numbers and also note it's again, like. Everything, unfortunately, we have to balance is where are we going to put our resources in terms of these activities? So, I, you know, I again, wouldn't want to answer off the cuff. I think we would need to. Examine more carefully the. What a change would mean and which would effectuate the end purpose, which is removing. Hazardous products from consumers strategic objective 2.2 and actually this 1's used throughout the document. What we previously in the 2018 plan had called recall effectiveness. Is now called recall response in this draft. Do those terms have different meanings and why did we move to this phrase? And what are any differences that exist there? Sure, so they're definitely both used throughout the document recall effectiveness remains in the document. It has changed the language specifically in this measure did change from effectiveness to response. So, I think at a micro level, when we're talking about response, it is literally the. The measurement of how many consumers. Respond to a recall in a way that's measurable. And so, when we're talking about a remedy or repair or replacement, how many consumers are taking advantage of that. That offer from a manufacturer with respect to. Effectiveness, that's sort of a broader concept that may include other. More difficult to measure or more. Yeah, more difficult to measure pieces of the recall puzzle. And so, you know, the classic example, of course, being it's very hard to count someone throwing out recall product. As part of the response, that's certainly a response, but it's very hard for us to measure that. But fewer of those products in consumers homes. Would go to the effectiveness of the recall. So, you know, we continue to explore ways to better effectuate recalls and better measure how effective we are at those recalls. But it's as, as you probably are aware, not just for CPC, but for all the agencies involved in the recalls. It's very hard to measure that and effectiveness beyond exactly what consumers are reporting back. So, I guess my only question there, and then I'll make sense to me, I agree with that. But the number that we've tracked over time in like the last budget document that has year over year was recall effectiveness. Can we put this number next to that side by side and have it be an apples to apples or are we starting with a new measure? I would have to get back to you on on exactly sort of. Again, everything that went into that number versus how we're, we're planning on calculating this response for. For the measure under 1 point or 2.2, I would note. I mean, we are continuing to look for. Ways of being broader to examine just the correction rate, whether it be consumer interaction with. With messaging about recalls is 1 way of sort of thinking about it, but I think we'll have to get back to you. I think. Historically speaking, we have been measuring response rate and I think it has historically been called effectiveness. And so we're trying to be a little bit more precise about what we are capturing and a little more creative how we can better. Measure and account for what it is that we are doing when we conduct, we recalled 43 million units of consumer products last year. It's very hard to measure what happens in each of those instances. I think that'll make sense. And if we're being more precise and can still compare it across the timeline, that's a great idea to do. So. Works for me, I'm out of time again, still have some more questions. Thank you commissioner commissioner boil. Thank you, Mr. chair. I do not have any more questions. Commissioner Bianca, do you have more questions? I do not have any more questions. Thank you. Commissioner Feldman, do you have any questions? I do not defer back to commissioner Trump. Thank you. Mr. Trump, I appreciate the indulgence. So, Mr. would you see value in adding a key performance measure. For the percentage of recalled products for which consumers are entitled to a full refund or replacement. You mean as a standalone measure. I would be adding a new key performance measure. Potentially, but potentially not. I mean, I think the larger question is. Again, our goal is to get the dangerous products out of consumer stands. I think we'd want to. Be sure that measuring. Different pieces of the recall remedy repair recall replace repair. Paradigm helps us accomplish that goal. So, you know, off the top of our head, we need to go back and look. Because again, it's going to vary pretty dramatically a washing machine. It's going to be a lot more important. In terms of some of those determinations, then maybe a fidget spinner. So, you know, I think it's going to vary. So, I'm not sure that that's just a pure number in that way would would provide a lot of information. Okay, strategic objective 2.4 the percentage of overdue notification notices sent to firms within 10 days. Of determining the firm's monthly progress report is 30 calendar days overdue and this one is a new measure. I believe correct. Do we currently send notifications like this and at what rate? I would need to get back to you on a rate. We certainly do send. Do I'm reading? We do send overdue notifications. I think what's. What's now we're 2 things that are happening here. We are. Raising the emphasis on making sure that firms are. Are meeting their obligations under the. Under the monthly progress report requirement that they. Agreed to with us and we are. Wanting to do a better job of measuring how frequently we are doing that. But at this time, sort of our process is to make sure we are notifying when they miss. When they miss it, what we're trying to do here to your point is to accelerate that process and make sure that we are getting that information because that's another piece of. Valuable information available to consumers that. We want to make sure is out there in terms of how successful individual firms are living up to their obligations and a recall process. So, so on this 1, I mean, we've got monthly progress reports, but baked in on these timelines are. 30 days late and another 10 plus transmit time. So, over 40 days, 40 or more days before we're sending this letter. Which is more than a month on monthly progress reports. So, did we consider shorter timelines and can we consider shorter timelines before these triggers are kicked? Well, I'm not sure that. I agree with how you're counting the calendar days, right? So, they're not late. You know, we have to determine when they're late. So, you know, they have that that extra, they have that month to report going backwards. Remember, it's always a backwards looking metric. But the goal here is to make sure we regularly and promptly. Get these notifications out, because it's a real point of emphasis of making sure that we're acquiring this information and providing to the public as quickly as possible. And we can't do that. We don't have immediate access to what the firms are, are. Are receiving in terms of that recall response rate. So we need to get it from them and we're going to more regularly and. And I'm more timely fashion than we have previously make sure we get that information to them a letter to them on strategic objective 4.4. The 4th measure percentage of critical vulnerabilities addressed if us or. Uh, are addressed from us or within 3 business days. So, if us or declare something a critical vulnerability, that's, that's the highest level vulnerability. It's also public. And so, that's the day or if not before that day that bad actors can start trying to exploit a vulnerability and 3 days sounds pretty good, but there could be systems within our system that hold particularly sensitive person, identifiable information. Have we consider risk ranking our systems within that where we'd have to maybe address certain systems that have a critical vulnerability within 24 hours instead of those 3 days things that would particularly sensitive. Yeah, sure. So, while the goal is public, I'm not sure that we want to have this conversation public understand in the 2018 strategic plan. There was a strategic initiative to regularly publish electronic submissions of progress reports from recalling firms. And I don't think that appears in this strategic plan, but I asked about something like that before. And you told me that I might have just missed it. So, I wanted to see if it was somewhere else or if there was a reason it wasn't in here. I'm sorry, can you can because I was looking in this plan for it and you're saying it's not here. Well, I don't see it, but, but in the 2018 strategic plan, there was a strategic initiative and it was to quote, regularly publish. Electronic submissions of progress reports from recalling firms. Right, I think that is captured by the monthly progress report. I think that's what we're talking about. So, I think it's a reformatting. Of that with the increase on making sure we're getting information. More quickly slightly different. This, this is saying, we need to publish their actual progress reports. That was the 2018 goal. And I don't see that part reflected in the current I'm not sure. I'd have to get back to you. I think the goal of publishing monthly progress reports in a way that is usable. For consumers is also putting it in a single format and allowing consumers to compare 1 manufacturer's ability to undertake recalls in a way against others. But we can, we can take a look at exactly what changed there, but I also know the resources involved in. In publishing that sort of thing, I think our goal was to actually acquire the data to get it published in the monthly progress report, not to initially publish the actual. Piece of paper submitted or electronic data submitted from the manufacturer in part. Because then we might have to wrestle with confidential business information questions. So, I think that's again, the concept is captured in the NPRs, but we'll circle back. I will ask my final question of the day to everyone's relief, I imagine, but I think overall, if someone asked whether this agency is. Successful at protecting consumers, we all of course know the answer is yes, but, but I don't see where we've given ourselves a way of demonstrating that to the public. And the strategic planning process seems like the perfect vehicle for creating something like that something to measure our success. Setting quantifiable goals for the next 4 years and then to see how we've stacked up. So, if we could estimate the number of deaths averted by individual actions or injuries averted as well, wouldn't that show the public how successful we've been with the actions that we do that we do take. Well, it would it would certainly certainly be a something we'd be proud to share with the public. I think there would be. Extraordinary difficulty and sort of doing that in a way that factors in things like population growth. Economic changes specifically, attributing exactly where we are exactly, you know, how our action influenced a specific outcome and then there's always the concern about. A grandizing the agency just for the sake of a grandizing it, but, you know, I think certainly on behalf of the staff, anyway, we can sort of make sure that we are doing a good job of communicating the life saving work that happens here every day is something we we want to do. But I also think, you know, we're always sort of on to that next, what's that next hazard we can address and not wanting to sort of get into trying to pick 1 specific action equal 1 specific life saved. Uh, at some sort of macro level, I think is a difficult task. Um, but I know there there are think tanks out there to try to do it. So, we should look to previously published information on that. Why should and I think we should should include something along these lines in the strategic plan and going forward with with each rulemaking that we undertake. So. I appreciate it. I appreciate everyone's patience as I walk through this. So thank you and thank you for all the work that went into the document. Obviously, and to preparing for today. Thank you, commissioner, commissioner boiled. Do you have additional questions? Thank you, Mr. Chair. Thank you with that. I want to, unless I did any other commissioner have 1 on the round. Okay. I want to thank the staff for the support briefing. I want to thank the commissioners for the active participation. Obviously, this is a draft that the commission will look to consider in the coming weeks. As to what should be put out for the public comment. So, I have 2 weeks to be able to discuss that look to see what changes in the draft or appropriate and then seek public comment because I think that is extremely important step in this process. And then, once public comments are in, obviously, as Mr. Lee laid out, there is a process of some time for us before it's finalized and be able to put together strong strategic plan going forward. So, we will convene 2 weeks to vote on putting the plan out for public comment and I think again, staff and the commissioners for all their work in getting this right. That we are adjourned. Thank you. Thanks everybody.