 My name is Will Cusey and I'm a member of the Small Business Ombudsman Team here at the US Consumer Product Safety Commission. Today, I'm going to be demystifying product safety and compliance. And I'm going to give you best practices and tips for how to make safe, compliant consumer products. Just a few housekeeping items before we get started. If you're watching live, please submit your questions through the GoToWebinar system and we'll answer them following the presentation. We're not going to be answering questions during the webinar, but we want to get your questions. We want you to feel free to ask them. This presentation is the start of a conversation about this topic and we want to get your questions and feedback. If you have them. Also, it's important to note that everyone who registered will receive a follow-up email with a recording of the presentation and a PDF handout of the slides. The PDF will also have clickable links. So as we're going through the presentation, you'll see lots of links. Those links will be clickable from the PDF document. They are not clickable from the video screen itself. You'll need to see them from the PDF. And you can also download, if you're watching live, the PDF from the Handouts tab within the GoToWebinar program. If you're watching a recording of this presentation, please send your questions to sboatcpsc.gov. You can also request a copy of these slides or any other slides from any of our recorded presentations. All you have to do is again send an email to sboatcpsc.gov with the date, the link or the title of the presentation. And we'll be happy to send those out to you. So what are we doing here today? Why did you join up with this presentation? What we hear oftentimes from small business owners, they're just starting out. They want to make a safe product. They want to do the right thing. They don't know where to start. They don't know what questions to ask. They don't know what they don't know. That can be a difficult position to be in. So we want to try to remove the unknown and at the very least help you, the small business owner, understand at the very least what you don't know. And hopefully more than that. Hopefully we can actually give you the answers that you need to make safe and compliant products. But the purpose of this presentation is designed to give you the knowledge of the questions that you want to ask and that you need to ask upfront when you're trying to make your designer product in order to make sure that it's safe and compliant. So what are those questions? What are those topics of discussion that we're going to go over and that you would want to be asking yourself during this process? The first question is what type of business am I? It might sound like an obvious question, but it's actually not necessarily the most obvious answer. So I'm going to go over some of the definitions from our primary statute, the consumer product safety act, and try to help you understand where you would be categorized, what type of business you would be falling into. So once we do that, we need to figure out what type of products you're making. What type of business product? Is it a general use product? Is it a children's toy? What type of product is it? You can't really move forward to understanding what requirements are in place until you understand how it's categorized at its base level. Question number three, how do I identify the labeling testing and certification requirements from that product? Most of CPSU's requirements fall broadly into the labeling testing and certification categories. How do you figure that out? What steps can you take to understand what those requirements are for your product? And continuing on here, what's the difference between compliance, proven compliance, and safety? Why do those concepts matter? Why should we think about those? I'm happy to go over those. And the last topic here, and this is really the goal. I think this should be the goal for everyone making a consumer product. How do I make the safest possible product? Okay, you're just starting out. What type of business are you? Manufacturer, importer, private labeler, distributor, retailer, freight forward or something else? How are these terms defined? How do I figure out where I fit in? When the CPSC writes or says a manufacturer must do X to comply with what type of business is CPSC referring to? That's not necessarily the immediately obvious answer. And CPSA, the Consumer Product Safety Act, this is our main statute for main law, if you will, that governs the majority of CPSC's activities. Manufacturers defined to include both manufacturers and importers. We're phrased a little bit differently. What we're really saying is, domestic manufacturers, individuals manufacturing domestically, or importers, or products that are manufactured internationally. So when we are writing out guidance on our website, we say the manufacturer must do X, Y, or Z. And we are including importers in that discussion. Importers are legally considered the manufacturer, if that is the applicable scenario. We're also including private labelers here. And if you look at section 14 of the Consumer Product Safety Act, section 14 includes private labelers as entities that are required to approve and certify compliance of their consumer product in GCC or CPC. And we'll talk about that a little more later. So we have our first kind of initial grouping. When we're talking about manufacturers doing X, Y, or Z, we're really talking about manufacturers, importers, and most of the time private labelers. We're talking about distributors and retailers. And distributors and retailers are selling the products. And distributors are not selling them to end consumers, they're selling them from maybe importers to retailers, and they're the in-between entity. And retailers send selling, generally speaking, to the end consumer who's using the product. Are they responsible for proving and certifying compliance? They are not. They are not. But they are entitled to receive compliance-related information. That is CPC or GCC from the manufacturer, the importer, or the private labeler. So they're part of this process. They're selling the products. They own the products until they're sold again. They're not the ones ultimately responsible in most scenarios. It is the manufacturer, the importer, or the private labeler. But they are part of the process. What about third-party logistics providers or contract carriers, freight boarders? These entities are not manufacturers, distributors, retailers, importers, or private labelers. They're not receiving or transporting consumer products from one point to another. They're not part of this process, except in the sense that they are shipping and forwarding these products from one location to another. So you have three broad categories. You have the manufacturers, the importers, and the private labelers. Those are the entities primarily responsible for certifying and proving compliance. You have distributors and retailers who are selling those products. And you have logistics providers, freight boarders, carriers that are shipping and carrying products from one destination to another. These are the three broad categories of business types. These definitions can be found at 15 USC 2052. If you want to look up more information about the section 14 reference about certificates, that's 15 USC 2063. And those are available. If you put those into an internet search, they'll come right up for you. So moving along now that we've talked a little bit about what type of business someone might be and how they might be categorized. And depending on that categorization, what their obligations are. And we're really primarily focusing on the manufacturers, the importers and the private labelers during this presentation. Just so we're clear. So when we're talking about you. I owe you the you that we're going to be talking about going forward. The you are manufacturers, importers and private labelers. So once you've figured out, let's say you've figured out, okay, I'm an importer. I have to do these requirements. I need to make a safe and compliant product. How do I categorize my product? How do I even start thinking about it? And yes, one product can fit into multiple different defined product categories that is something that often happens. The first place you want to start is to identify whether it is a children's product or a general use product that is the biggest decision point that you will have for categorization. And it makes the biggest impact on what types of requirements are in place. You can, there's a very nice webpage we put together cpsc.gov forward slash children's products. That has this information. It's a lot of helpful guidance to help you understand how to make this determination. Now, while you are the entity ultimately responsible for making this determination, we're happy to help you do that. This is why we're here. This is why the small business ombudsman team exists. Send us an email to SBO at cpsc.gov with any questions you have. This is meant to be the start of a conversation. We want to continue to have that conversation with you following this presentation. So the best way to think about how to make the distinction between children's and general use products is to look at the definition for children's product. And this is reprinted from our statute, from that definitional statute citation that I just gave you. And children's product means a consumer product designed or intended primarily, that's the key word, primarily for children 12 years of age or younger. It doesn't mean a consumer product designed or intended for use by any child 12 years of age or younger. It means it's primarily intended for that audience. It would be something that has greater appeal to children under the ages of 12 and less appeal, diminishing appeal to individuals over the age of 12, 13 and older, if you will. So there are a few criteria that can help you make this decision. It's right in the definition and the criteria are quite helpful in helping you think about how to categorize. And the web page, the guidance page we link to goes into even further depth here. The first thing to think about is the statement of intent for how the product should be used by the manufacturer, the imported private labeler of the product. And that such statement is reasonable. You're not going to say pacifier is a general use product for individuals 13 years or older. That's not a reasonable statement. The next thing to think about is whether the product is represented in its advertising promotion and display as being appropriate for use by children 12 years of age or younger. Is it shown to be suitable for children 12 and under. But all that being said, there could be reasonable intent from the manufacturer there could be consistent marketing images and language. But how is the product commonly recognized point see how is the product commonly recognized by consumers. If a manufacturer intends the product to be used in one way, or a certain audience, and all of the marketing is consistent with that intent. But consumers are using it in a different way view the product as being suitable for use in a different way than that can change the determination. So it's really important after you start selling a product to try to keep up to speed as much as you can with comments and feedback from your consumers as to how they're using the product. You might have spent a lot of time thinking about an age grade and appropriate classification, and then it could turn out to be incorrect based just solely upon point C about how it's commonly recognized for use how is it actually being used is very important. The last point here is our age determination guidelines we recently updated this last year, there's a link here when you get the PDF version can click this link and it'll bring you right to this document. This is an extremely helpful helpful document that goes over the use characteristics for different ages. For how those different age children in small increments granted as well for how those differently aged children would use an interact with a product. This can very much help you determine and figure out what an appropriate age grade is for your product. This is why we put this out. It's to help you understand how to effectively and accurately age grade your product. So if you're just starting out, if you have no idea what the appropriate age range is for a toy or a product. I recommend that you check out this guide spend some time combing through it. And see if that can help you figure this out. We're also happy to help right. We're also happy to help. We're always here to help. You're the one that has to make the final decision but we can help inform your decision. Absolutely. You don't think that you're on your own, trying to make these decisions. We're here to help you make those decisions, even though you're the ones ultimately making them. So what are some other types of categorizations what are other things that maybe I should be thinking about that I would say it's really important if you're making a children's product to figure out is it a toy. Or not a toy. Is it just a children's product or is it also a toy. These are generally products, primarily for play value that play value for playing or make believe situations of play. Here's a good example, a children's product. That's not a toy would be just a baby blanket, a swallow blanket. Maybe there's some ancillary play value there, but the product is primarily intended, not for play scenarios for laying on for warmth for comfort. Baby blanket would not be considered a toy in the overwhelmingly vast majority of situations. On the other hand, you have a stuffed teddy bear that stuff teddy bear. Absolutely would be intended for you starring play. And so that would be categorized as a children's toy, as well as a children's product. And the reason why I'm mentioning these categorization things at all is because depending on how it's categorized the requirements change. The children's toys have to meet additional requirements beyond what children's products have to meet. So a children's toy that is also a children's product has additional requirements than a product that is just a children's products like a blanket. There are also other ways to categorize the product that can add additional requirements or additional concerns. Durable infant or toddler products is a specific class of product it's it's specifically defined there's about 20 of these types of products. So everything from cribs and bassinets to sling carriers to gates and enclosures, there's a narrowly defined list we can help you figure out whether your product is in fact a durable infant or toddler product or not. And if it is it comes with additional requirements additional performance standards typically. Maybe you're making a child care article that's also a children's products. It's a product primarily intended for use by children under three that facilitates sleeping, eating, feeding or teething. And plasticized components of childcare articles would have to undergo phthalates testing. That's important to understand that. And there are of course lots of other categorizations art materials hazardous substances, depending on the categorization that can influence the requirements that exist for your product. So once we've identified the kind of business we are how it's categorized or maybe we have a general sense of how it's categorized but not maybe very specifically maybe we understand that we are an importer of children's products. But we're not sure what else we are. What else can we do to figure these things out. The regulatory robots is a program that we created. It is a tool that will ask you a series of questions. And at the end it will give you some customized guidance for the likely applicable requirements in place for your consumer products. This tool can help you narrow down your focus quite a bit quite considerably. You can help you identify additional categorization. It can help you identify the labeling the testing the certification requirements in place for your product. It is a great place to start. If you're not sure where to start. If you don't know what you don't know. Which is often where people are starting. Start at the robots. And that will greatly assist you in figuring these things out. So the robot is laid out in kind of three sections labeling requirements testing requirements and then certification. Labeling requirements it's important to take away for this slide is that it's important to know that labeling requirements could exist and that there are quite a few different types of labeling requirements depending on how the product is categorized. The robot will identify those for you. But you can also figure these things out for yourself. We recently published a new page this link will be clickable from the PDF document. We recently published a new page with some of the most commonly asked questions about label requirements number one being tracking labels most commonly asked about question. You have questions about any of these requirements this this presentation isn't really going into depth about what the requirements are. If you have questions about what those requirements are we are happy to answer them at SBO at CPSC.com please feel free to send us an email or if you're watching live you can send us a question through the system. The takeaway here again, it's important to know that labeling requirements could exist. And that when you're thinking about how to comply how to make a safe product. That is an item that needs to be considered testing okay. You've figured out you've done the robots, you've identified testing requirements for your stuffed teddy bear. You understand that it's a toy that it's a children's product that you're the importer that you're the one responsible for certifying compliance for ensuring a safe product. What now, what do you do now. A couple of things you can do. You can go to work slash certify CPSC.gov slash certify. Lots of helpful information on that page about all of the various testing requirements and what you can do to educate yourself on these testing requirements. Common question we also get is where do I find a lab to do the testing where, where can I go. What are my obligations in that regard. When making a children's product in the vast majority of situations you have that testing has to be conducted as CPSC accepted laboratory. We have a comprehensive lists available at CPSC.gov slash lab search. And that's a clickable link will be a clickable link. And all of the CPSC accepted laboratories from all around the world are in here and you can filter your search by testing scope by country. There are all kinds of things to get a narrowly tailored lists specifically for you and your needs for general use products. You could actually use in a lot of scenarios, you could actually use the lab search page to find a CPSC accepted laboratory to do that testing for you and there are crossover requirements like for mattresses or for rugs, where you can find a lab that can do that testing and it's, and it's documented. There are other situations, such as for lighters. Other requirements that are never considered children's products where you wouldn't be able to use the lab search page to identify a specific laboratory, but you could still use it and reach out to labs and just ask. If they do this testing, could they do this testing for cigarette lighters, for example. If you don't need to use a CPSC accepted laboratory, if you're making a general use products. You could do this testing in house there are some testing standards that are not overly complex that don't require a lot of sophisticated equipment that could be done in house as long as it's done correctly and documented well. You could also use an external facility that's not CPSC accepted maybe you have a relationship with the local university and they have a small testing lab and they have some capabilities to do some testing. That's also possible to as long as they can fulfill the obligations of the standard so generally these products a little more flexibility on how and where these products are tested children's products almost always have to be at a CPSC accepted facility, but generally these products. We also recommend for generally these products to think about a reasonable testing program. Not necessarily mandatory, but it's something you can put in place to try to remove some of the day to day thought process and just have a plan in place and a process in place to carry out your testing and compliance duties to ensure a safe product. What about certification so labeling we got testing. What about certification. So, for children's products, all children's products need and all manufacturers of children's products need to produce a children's product certificate, but important point here, not all requirements for children's products need to be certified in a children's product certificate. There's a specific list this list is on our website, you can find it by going to CPSC dot go forward slash CPC. We're going to CPSC dot go forward slash certify those links will help you get to this page specific lists of which requirements need to end up in a CPC which need to be certified and they're pretty tested. There are some requirements that do not need third party testing and certification chief among them would be labeling requirements. Specifically a tracking label tracking label requirements do not need to be tested or certified at their party laboratory that do not need to appear in your children's product certificate. So it's important to understand which requirements need to be in your CPC and which requirements don't need to be in your CPC. This is important that it's done correctly, and we have the tools available on our website already to help you understand how to do this. So that's the other part of this presentation that I think that's important to mention. This information is out there. A lot of this information we have already produced for you might just have trouble figuring out where to go where to find this information. I want to find it to give yourself the knowledge. So part of this presentation is, is we're trying to organize some of these resources in a way and present them to you. Where it's more intuitive to find and identify the key areas to look at. And so that's, that's probably what we're trying to do here for generally use products. Only general use products subject to, again, the specific list that we published on our website is longer than this. This is just a screenshot. Only generally use products subject to a specific list of requirements that we've identified have to be certified in a GCC. It's not on that list. It doesn't need a GCC. I cannot say that any planar. Not every general use product needs a GCC. Not every general use product with mandatory requirements under CPSU jurisdiction needs a GCC either. So it could be a situation where you're importing ceiling fans, ceiling fans do not have mandatory standards that you're not having specific mandatory standards with the CPSU other than reporting requirements. So those products would not need a GCC because there are, there's no applicable standard. Additionally, something like generally use our supplies, maybe some paints or some paint brushes. Things that might be subject to the art materials requirements under the FHSA. Those would also not have to be certified. They're not on this list. You can see. Well, this is only part of it, but it's not on this list. If you go and look at it, our materials do not appear. mandatory standard mandatory requirements for our materials are in place. They do not need to be certified in a GCC. So when you're going through the robot and you're, and you're making a general use product. Everyone gets the general certificate of conformity section, but the one of the very first links is to check this list to see if your product is on it. You don't need it. If it is on it, you do need it. It's that simple for general use products. Okay, so we thought about what type of business we are. How to categorize our product. I want to find and identify the requirements to understand that requirements are generally grouped into three main categories labeling testing and certification, and that we can check to see if there are any labeling testing or certification requirements in place for our product by using the robot and other sources on CPSC. So now we're going to spend some time talking about the differences between compliance, proving compliance, and safety, and how those different concepts intersect with each other. The differences between those and why it's important for you, the manufacturer, the importer or the private label are to understand the differences between those concepts. People get messed up sometimes on those and we want to try to give you that knowledge so you can make informed decisions so you can avoid unnecessary testing that does not add any safety value, but still ensure that you have a high degree of compliance and safety for your product. So sometimes some requirements mandate their party testing to prove compliance, but not all. Sometimes a product only has to comply with the requirements, but not prove compliance. And sometimes something could be fully compliant, but still have safety defects where the CPSC has to take action, corrective action, or conduct a recall. So it's important to think about your product, not just from the sense of complying or proving compliance, but also the idea of making a safe product, trying to make a safe product. Okay, so what do we mean compliance is just the idea of meeting an applicable CPSC requirements. And proving compliance is demonstrating through testing or other means that the product or component part of the product meets the applicable CPSC requirement. So let's go over a couple of examples to help illustrate this because these are kind of abstract terms, and especially if you're new to safety and compliance and this whole topic in general. Your, your, your eyes might start the glaze over a little bit. So let's try to un-glaze the eyes a bit and focus them in on a couple of examples that are very relatable. So the CPSC has requirements for sharp points and sharp edges for children's products intended for use by children under eight years of age. Those are found at 16 CFR, 1500.48 and 1500.49. These are requirements that mandatory compliance for applicable products, but they are not requirements that mandate proof or testing to prove compliance. So let's think about it this way. If you have that baby blanket again, simple plain baby blanket, not a toy, just a regular children's product. Very simple, just a piece of fabric, essentially. Does that baby blanket have any sharp points or sharp edges? No, it does not. And it is very obvious that it does not. So sending it to be tested for sharp points and sharp edges would not add any safety value here. You would not tell you anything that you didn't already know. You might already know that you comply with the sharp points and sharp edges requirements because your baby blanket does not have any sharp points or sharp edges not even close. Another good example is labeling, tracking labels. Again, tracking labels, not something that you have to prove compliance with. You don't have to get a laboratory to prove that your tracking label is compliant. That is not a requirement here, not at all. Tracking labels are something that can be visually determined to be compliant. You don't need a laboratory to visually tell you that something is compliant. If you can look at the requirement, look at your label and figure out yourself that it's compliant. But what about, okay, so what about in scenarios when you're fully compliant and you're proving compliance with all of the requirements you have to prove compliance. So when you're making a baby onesie, three month old baby onesie, it's got a screen printed image on the front. It's got painted snaps. What are the requirements here right off the top of my head I can tell you clothing flammability potentially depending on what type of fabric it's made of the snaps will have to be tested for lead the paint on the snaps will have to be tested for a different size and the screen printed image depending on how it's used, and whether it's creating a surface coding or absorbing into the textile surface, you might need additional lead and paint testing there as well. But what you would not need is you would not need to test the snaps and the product as a whole for small parts hazards. The situation exempts clothing and 16 CFR 1501.3 from testing for small parts. But that doesn't mean it's still not a concern. And the CPSC has taken action previously there are documented recalls or the CPSC has recalled onesies where the snaps have become liberated this is moving beyond just the regulatory requirements statutory requirements and thinking about the safety of the product as a whole. So this could be a situation where if you had your baby onesie and you did the lead testing and the flammability testing you have your tracking label you produce your CPC. You're fully compliant CPSC requirements there's no issue from a compliance standpoint. But you might want to be in a situation where you're doing a little bit of extra testing to make sure those snaps are securely fastened. They're not becoming liberated and they're not becoming small choking hazards. And so the big takeaway here is that there are situations when there are compliance requirements where you don't need to waste money on doing additional testing. And then on the other hand there are situations when there are not any compliance requirements in place but you might want to think about doing some testing anyways. So the snap example is a great example for where manufacturers and porters and private labelers can do a little bit above and beyond to ensure a little bit more safety and have a higher degree of assurance that their products are safe and compliant. So on this subject. This is kind of a nice segue into our last topic about best practices for safety. How do I make the safest possible product. Well you want to practice safety by design you want to manufacture products and be thinking about the safety of the product compliance requirements for the product at the design stage. Identify the potential risks. Consider foreseeable misuse of the product. You need to try to eliminate or at least mitigate those risks and those hazards in your final version. It's really important and I highlighted and misuse a little bit in a different color because it's very important. Not just to think about foreseeable use of the product, but foreseeable misuse. Consumers misuse your product in a way that is dangerous in a way that maybe is killing or severely injuring consumers. And if they're misusing the product in the same exact way that could be a situation where there is a product defect, a pattern of defect where the same scenario happens over and over that creates a dangerous scenario for consumers. And that is the type of discussion that is the type of thought process that you want to be having in the design stage, especially when we're talking about products for children for babies for other vulnerable populations. Very important to be thinking about this at an early stage. If you want to build safety into your supply chain, don't assume that your supplier, that your contract manufacturer that your business partners overseas, understand the requirements, they might be in your situation to they might not know what they don't know. The question that they know, even if they think that they know, even if they've told you that they know, they might not actually know the full picture. Maybe they understand that a toy standard exists, and STMF 963 is standard that children's toys sold in the US have to meet, but there are other things to consider beyond STMF 963. There are other requirements, tracking labels, certificate, lead and thaliage testing, those are not showing up in the toy standard, but they would still be required for the vast majority of children's toys. So one thing you can do is send them the robot, send them the regulatory robot. It's available in seven languages, including both traditional and simplified Chinese, as well as Vietnamese, Indonesian, Korean, Spanish. It's available in lots of different languages. All of the requirements are available and I would say most of those languages, some of them are not fully translated but the Chinese, Spanish, Korean languages are fully translated. And so send them the robot, help them understand the requirements in their native language. That will help them understand how to make a safe and compliant product for the US market. You might want to also consider having outside firm do quality control or quality assessment audits during the production. This is your first time working with a supplier. They can promise the moon, and they could give you golden samples that look and perform great during testing and then your actual products are less safe, have lesser quality, have inconsistencies. That could be dangerous or just hurt your brand too. And there are considerations beyond pure safety, and I understand that, but I would make the argument that making safe products is good for business. Avoiding costly recalls, avoiding costly reproductions that can cost you valuable time. And that is to think about as well. Even though my main concern here at the CPSC is the safety aspect. You want to be knowledgeable and aware of the regulatory environment review and closely monitor your consumer feedback monitor recalls there's a lot of ways to do that. You can sign up with the CPSC small business ombudsman to get our newsletter updates. You can go to report slash email, and you can get those emails, we send them out monthly, and it has all kinds of information from commissioner commission activity, new rules and regulations coming into effect. New training opportunities, other highlights and important information. It's a great way to stay up to date. You can also go to federal register dot gov. Find the CPSC page that are organized by agency, or any other agency you're interested in following maybe the FDA, maybe the FTC, other agencies, all every federal agency is represented there. And you can sign up for alerts that will send to your email when new federal register notices are published and federal register notices involve things such as new or proposed rules. Commission activity commission hearings. The types of vitally important information about what the commission is doing. And activity, how that affects how that commission activity affects you and your product in your compliance and safety obligations. It's also important to understand your legal responsibility to report. And I alluded to this a little bit earlier, the CPSU duck of four slash reporting will explain more depth about when you might mean to report this applies to all consumer products under CPSC restrictions. So all children's products and generally these products broadly fall under this category. And it's your obligation to report in certain scenarios, such as when your product could create a substantial risk of injury or an unreasonably hazardous or dangerous situation. It's really important to be prepared to think about the worst case scenario, we don't really like to think about the worst case scenario right who wants to think about that. But that's important because it can help you act quickly. To minimize risk to to more efficiently recall a product that is potentially dangerous. And so there are some ISO standards here. It could be helpful for you, you have to pay for them is you're not free. But even just the titles of these standards can be helpful. The titles of these standards can give you some ideas for the types of things you want to be doing you want to have a recall safety plan in place, you want to have be thinking about reverse logistics if you need to conduct a recall. You want to be thinking about how to manage your compliance from every step of the way. You want to be thinking about producing the safest consumer product possible. One thing you can also do here is to use lot or batch controls, not just so children's products have to do this and tracking the requirement. Generally, his products should people that are making generally his products should think about this too, because if there's a problem if there's a defect if there's even just a quality assurance or quality control issue. You can identify this more quickly and react more quickly to fix the problem, and you can minimize the affected number of products to narrowly focus on the product and the batch of products that have the problem that have the issue. I can't say it enough, I try to tell everyone I talked to to document everything you do document the work you do document your efforts that you've put into trying to make safe and compliant consumer products. Write memos to yourself I always encourage people to write memos themselves about things that they have done things that they are going to do decisions that they made sometimes you have to make a hard decision. There's a judgment call about how a product can be categorized what the age ranges, what the applicable audiences that can be difficult and tricky to figure this out. I often encourage people to write a memo about that decision process. Why did you make the decision what happened, what information did you look at when you were making this determination document that save it in your file with your testing information your CPCs or GCCs. And if there are any problems and safety related information in one place, and if there are any problems, you can demonstrate that you have shown a willingness to understand and try to do the right thing to try to make safe and compliant consumer products. So document everything you can save these things in a folder. That can, and helpfully avoid dangerous situations, risky situations, recalls other things that you don't, you don't want to be dealing with. And I'll just leave you here with the idea to challenge yourself to manufacture the safest possible consumer product. Again, I mentioned this a little bit earlier. Safe products are good for business, because if you're making a safe product if you're making compliant and safe product. You're dealing with injuries and deaths from your use of your product as horrible as that would be for consumers that are going through that from a business side you're also not having to deal with that. There's really a benefit to thinking very seriously about making safe products. In some way you can do that. You might want to seek outside perspectives to assist you in appraising the safety of your product you might want an objective party to give you an analysis of the safety of your product. There's some kind of human factors, or analysis that can help identify potential pitfalls for you things that you can do ways you can engineer out the safety hazards and make your product safer. But it's also just the safety culture of your company, generally, you're the head of your company or you're in a position of authority in your company. And then straightening to the rest of your employees that you are making safe products that you value making safe products. That's important. That is what we're trying to do here. We're trying to not just make a compliant product. We're giving you the tools to understand how to make compliant products. We're also giving you the tools to try to understand how to make a safe product or as safe a product as possible. It's an unattainable goal to truly reach 100% safe product, but it's the seeking out of that goal that's important is striving to produce that safe product. That's very important. Thank you everyone for watching. Thank you for joining. My name again is will QZ. I'm on the small business ombudsman team here at the CPSC. My direct contact info. It's also our SBO email address and our SBO phone line. You have questions and you think a phone call is better. Please feel free to give us a call. If we don't answer, leave us a voicemail and we will return that call to you. You can find all of these webinars. We save all of them and record all of them for YouTube or YouTube channel. And this is a clickable link. You can also just go to youtube.com forward slash us CPSC that lands you on our CPSC YouTube channel. Again, you can sign up for newsletter alerts from this CPSC small business ombudsman. And here again is the link to the regulatory robot. It is business dot CPSC dot gov forward slash robots. Thank you again for joining. Please let us know at any time if you have additional questions. We are here to help.