 Translators, it's a great honor to welcome you all back to the fourth biannual United States China consumer product Safety Summit. I'm Alex Phillip. I'm deputy director of the office of communications at CPSC a couple of housekeeping things In case of emergency the exits are on the left and on the right here to go out to the main lobby Lobby exit to the outside in case of emergency There's also an exit in the back and take the stairs down to the courtyard and Exit the building that way Yesterday provided a very interesting look at the improvements the remaining challenges and the potential for cooperation Between our countries in the area of consumer product safety Our speakers and our discussions were absolutely first rate, and I think you'll find this morning's program just as worthwhile Now at this point, I would like to reintroduce you to our leaders The other the two delegations that are here today CPSC chairman. I know as Tenenbaum AQs IQ vice-minister Sun Dunway Chairman vice-minister Would you mind standing for a moment? But thank you if you've been following the theme of the summit You will have noted an emphasis on globally accepted best practices Our panel this morning continues that theme with a discussion of global best practices tracking and traceability The ability for manufacturers consumers and regulators to know with certainty how to identify Hazardous product or component how to isolate it and how many there are and how? And how to have the facts on hand in a very rapid time frame this all depends on having some sort of effective tracking and Traceability system in place This is the topic of growing importance to all stakeholders and the subject of a pilot project within the International consumer product safety caucus the global consumer product regulatory group Andy Camaros will moderate our panel this morning Okay Andy is assistant executive director of compliance and has extensive experience in forcing federal regulations He worked for 19 years as federal prosecutor for the criminal Section of the tax division of the US Department of Justice Where he led a team of attorneys and agents in the investigation and prosecution of complex financial crimes Focusing primarily on tax fraud and mail and wire fraud schemes and he will introduce us to his panel And a good morning chairman vice-minister I Thought that before we got into the substance of our our panelists discussion. I provide a little bit of background on the tracking label and registration card Requirements to provide some context For their for their presentations section 103 of the consumer product safety improvement act is entitled tracking labels for Children's products it requires tracking labels to the extent practical on all children's products and their packaging sufficient to enable the manufacturer and ultimate purchaser to ascertain Certain source and production information The information that's expected to be On these tracking labels is the location and the data production Which can be the date the product was produced as well as the date of assembly cohort information such as lot batch run numbers And other information which Facilitates the ascertaining the source of the product Now this tracking label requirement applies to children's products, which are defined as a consumer product designed or intended primarily for children 12 years of age or younger The tracking label requirement became effective in August of 2009 and both manufacturers and importers are responsible for compliance with the tracking label requirement As I mentioned one purpose of this requirement is to assist the manufacturers in determining the origin of a defective product And the cause of the reef recall so that these products can be isolated and repaired or destroyed It's also expected that manufacturer location and date of production information on a tracking label will enhance The product identification and assist the consumer in determining whether a product they own has been the subject of a recall The section requires permanent Distinguishing marks, but doesn't specify what those marks are to look like that's pretty much left to the discretion Of the manufacturer and it's our view that manufacturers will use their best judgment In developing markings that best suit their business and their products Each manufacturer is expected to use reasonable judgment in deciding what information to include on the label and In determining reason wellness the CPSC Will look to the individual manufacturers Situation along with the practices of peer manufacturers Now the Commission recognizes that there are certain products that don't lend themselves Easily to the affixing of a tracking label or other mark For example, there are products that are just too small to accept a tracking label. There are products that are pieces of a board game or Or other Combination of products there are products for which the tracking label might do damage to the product itself Or might affect the aesthetics of the product in those instances We would consider labeling that's affixed to the packaging of that product as Compliant with section 103 of the statute Another requirement that addresses the issue of traceability is the registration cards That each manufacturer of a durable infant or toddler product must provide with the product manufacturers are required to Provide a postage Prepaid consumer registration form with each product that sold they need to keep records of the consumers who register their products And they have to permanently place the manufacturers name and contact information Model name and number and the date of manufacture on each of those products The CPSC expects that this rule Has and will greatly promote a higher rate of product registration and in turn provide better Notification for product owners thereby increasing the overall effectiveness of our recall process We have convened a Distinguished panel today to discuss the CPSC's tracking label and traceability requirements. They'll be presenting the views of manufacturers and industry As well as those of consumer groups regarding the efficacy of these requirements and what can be done to possibly improve the labeling requirements and and the compliance with Those requirements our first presenter is Randall Gooden. He's recognized as a leading expert on product safety and product liability prevention He's taught product safety Recall readiness and product liability prevention seminars to thousands of manufacturers Executives around the world That we were talking earlier. He told me that Well, I still got five years on his passport. It's full. So he's been he's been he's been very busy Providing that kind of information to his clients. He's also authored several books focusing on reducing the risk of product liability Which have sold Thousands of copies worldwide. So Mr. Good well, good morning, everyone It's a real honor to be here and have this opportunity to speak with all of you especially our honorable Chinese delegation We're talking about about traceability and What we talked about yesterday and and what we're talking about today I wanted to show you a few slides here I do as it was as it was mentioned by Andrew Do teach seminars all around the world on this to two manufacturers And I just wanted to point out and this one here. This was this was sponsored by a CIQ branch in it was in held in Chengzhou and Because it was sponsored by the CIQ branch. We had over 200 manufacturers there for the seminar including 20 or 30 CIQ Inspectors were at the event so it enabled a lot of manufacturers to come in and learn what they needed to Learn regarding this and this one here was done in Shanghai and it was sponsored by the Shanghai Quality Association so But manufacturers all over the world Throughout the United States Europe everywhere are very interested in all of these topics product safety and how do you? reduce the number of Recalls and the problems corporations can face not only in recalls But the ultimate failure of your product when it actually injures Somebody causes property damage and you could even face a product liability lawsuit So we take it right to the end And and what we're focusing on and and yet and these are the areas that we try to address I try to address in all of the seminars all of these areas for the Manufacturing management team to be focused on in order to help prevent this this possibility But it all starts in a design review and Yesterday's topic and today's topic when we're talking about traceability When we need to be discussing this as part of the design review We're going to manufacture a new new product It conceivably is going to have new component parts They may have new suppliers and we need to be able to trace where these things are coming from and And monitor the movement of these component parts Subbook Contracted assemblies and stuff that are going into this a final product and and although this is being required by by the CPSIA for children's products This makes a lot of sense for anybody. You don't have to even be in consumer products You don't have to just be in children products or consumer products. I teach us to Industrial man product manufacturers commercial product manufacturers because this is recall readiness. This is all part of Learning at some later date that you have a problem with your product and being able to quickly Isolate which products are affected by the problem and so it makes really good sense for everybody to do it Even though CPSIA is just requesting that are requiring it for Children's products, but it should go well beyond that but it all starts at the design review stage How are we going to manufacture this product? What materials are we going to use? What component parts are we going to use what material what suppliers are we going to use and so in this? and We're looking at here's our design review team and and all of the things that the design review team the much larger team of Two teams in in in the original umbrella of design reviews This is the the regular design review team that's looking at all the Manufacturing issues of this new product that we're going to manufacture and what was talked about yesterday is handled by the Product safety team they're focused on the hazards smaller team looking at a product safety team being two to four people but the the for most manufacturing corporations The design review team consists of anything from 8 to 15 people in size depending upon the complexity of the product that you're manufacturing and Then in this stage When we're looking at the price and we're looking at the components We're looking at how we're going to manufacture this looking at the entire manufacturing process How are we going to? Incorporate traceability into this so that we know when materials flow through the operation That that that we're able to to to mark When they made it to the assembly line in which finished products have certain batches of Component parts that were received by certain suppliers on certain days Now one of the things when we're talking about the labeling one of the things that This is a label that I Put together and and and it and it what it's saying here is here's the name of the company Here's where the company is located and now it has this distinguishing mark on it that looks like a serial number and it and it functions just like a serial number, but in fact It's not really a serial number. It's a time stamp And so when the product is coming down the assembly line And it makes it to the end of the assembly line and the person who's there pushes a button on on the label maker And it and it stamps this time on it. So in this situation here That that stamp says that this thing was made on April 15th of 09 at 3 30 in the afternoon and 35 seconds You're not going it functions just like a serial number because you're not going to have two products that have the same number on it How it's different than a serial number is if you put a serial number on a product Then you have to keep another set of records that that States when you use that serial number And when you applied it to a product in this situation, you don't have to do that in this situation It's telling you all of that, but it's not only telling you that it's telling If you find that the product That you manufactured and yet you've been Manufacturing for a number of days or even weeks if you were to find that the product that was made on April 15th of 09 Somewhere between noon and and three o'clock in the afternoon was defective for some reason whether it was a defective Shipment of incoming components or somebody in sub-assembly didn't do the job right and those are the ones we're identifying as being the the Materials that we need to recall You can do that on here and everybody can understand it the retailers can understand it the consumers that have it because all you Would be doing is telling them that the ones that we're specifically looking for are between 1,200 and 1530 and if you have one of those those are the ones that are subject to the recall and so it was just an idea but What we need to do it as manufacturers and again I go back to this doesn't this makes really good sense to do this To limit your exposure if you don't trace the products that you don't trace the component parts In any type of a product that's being manufactured then when you identify at some later date that you have a defective condition You're going to be facing having to recall all of the products because you have no way of distinguishing Which final products those defective components or those defective materials? Got into and you don't know and you can't distinguish those from the rest So it makes really good sense for all manufacturers to do this. So if we're monitoring When the raw materials came into our receiving dock and and say we're barcoding all Shipments of product batches of component parts that came in and we're scanning the barcoding labels And we're following the movement through the various departments Within a manufacturing corporation and then we know exactly what time those things hit the assembly line Then you go back to here's our person down here pushing the the the label maker button and hitting that time stamp as this is when this product was manufactured and so Therefore if we have all the traceability systems built into the manufacturing process We know exactly which ones we're looking for and we can identify him to everybody that's out there if you have one of these This is subject to the recall After that and and after we've manufactured a process then it becomes a an issue of monitoring and watching what's going on Out with the customers and the end users in the marketplace the the phone calls the customer complaints to customer service and to sales and such as to to bring into attention There there's not only some products that Failed and and they need to be replaced but understanding that that pain special attention to Things that failed and could lead to an accident or injury. They didn't at that time Lead to an accident or injury, but they could at a future date and how do you? Differentiate with your customer service people and anybody that's answering a phone anybody that has correspondence With outside parties, how do you differentiate between those situations that at a later day could be a very serious? problem with the product versus And and could lead to acts in our injury versus just a product that that quit working the way it was supposed to be working Go back to we talked yesterday made a mention about Toyota a key or Toyota Had stated the chairman of Toyota had stated when he talked to Congress here in Washington He says what the company failed to do was connect the dots He said the flags were there the people were saying that they're having problems with the cars with Unanticipated acceleration and it was happening out throughout North America and throughout Europe But was what was going on it was is that these calls were going to? the sales department for North America and to Europe and what they were doing was just taking care of those customers that were complaining about the cars Having up their cars having a problem and there and they were taking care of them in the sense that they're just saying bring the car Into local dealership won't take a look at and the key said the problem here Is is that the information never found its way back to Tokyo and to to the the engineering departments that they could I I I Identify this and and figure out what was happening here, and it didn't happen until we had our real crisis accident So the information and the people need to be trained and we need to be monitoring So that we catch these things and we identify real quickly if we have a potential problem with a product And then we are ready to recall that the corporation has the recall team in place Ready to spin into action Instantly and and working with the CPSC I'm stating what they're going to do and that they're all ready to do it The key thing is is to be addressing this this situation and this product that's out there Very rapidly and being in a ready position to do it, but it goes back to you can't identify Which product you're talking about unless you build traceability into the system? That's the best way to isolate We're not talking about all of the product unless we are talking about all the product, but we're not talking about all the product we're talking about an isolated Group of the product and here's how it's identified and here's what we're going to do and be able to spin into action in days or a week or two and get this product off of the Market and be addressing it So that's the key thing is to use this and like I said This is a very good system to have and it's labeling in this following process To to incorporate traceability right up in the design review right when we're talking about this brand new product We're going to manufacture the new suppliers and the new component parts and build traceability into the system Regardless of what the price for but it has to be done naturally for the children's price But it should be done for all products to limit your exposure to potential accidents That's it. Thank you. Thank you, Mr. Gooden. Our next presenter is Nancy Cowells This cowels is the executive director of kids in danger, which is a nonprofit Organization dedicated to protecting children by improving children's product safety Prior to joining kids in danger Ms. Cowells served as the executive director for the coalition for consumer rights a Center for Public Interest Research and Education Ms. Cowells has more than 30 years experience in building and directing organizations Which investigate a wide variety of consumer issues? Ms. Cowells There we go Good morning. I am the director of kids in danger. We're a nonprofit organization that works on children's product safety Kids in danger was founded in 1998 by the parents of Danny Danny was killed in a recalled portable crib in childcare They found out after he died that the crib had been recalled five years before he died That he was the fifth child to die in that particular brand of crib and the 12th child to die in cribs with the same mechanism that had been patented and sold to other companies so Of the 1.5 million cribs that were made with this defect 1.2 are still today What is it now 14 years later still unaccounted for? and so Our concern is very real for those of you at CPSC who wonder why I keep calling and bugging you about things It's because I keep Danny's picture on my desk so that I remember the real price of unsafe products that we've talked a little bit about the tracking label requirement that is in the CPSIA the portion that is in the Product registration cards is actually that requirement is named after Danny and his The efforts of his parents to assure that what happened to him will not happen to other children We want to make sure that the information was not only on the packaging that could be used for shipping and for Manufacturers use but was actually on the product itself Because we all know with products that once they get into the home and sometimes even before The packaging is lost and put away and to be useful to consumers the information needs to be on the product itself So we very strongly believe that the improved tracking and traceability will improve safety Tracking labels and the product registration System that Andy talked about are very important to make sure that consumers learn about a recall when it takes place and Can actively participate in the recall because they know that the product they have is the one that either is involved in the recall or is not in addition Being able to trace components and of products as well as products also improve safety We have seen numerous recalls of children's products where one particular product will be recalled Only to be followed up sometimes months or even years later with products with the same component or same design That simply were not identified at the time of the initial recall This crib the the Greco branded simplicity crib is a good example of The real impact of not having a tracking label in 2005 Liam Johns in California a nine-month-old boy died in this simplicity branded or a Greco branded simplicity crib This the drop-side rail came undone. He was caught and strangled They made a report to CPSC the CPSC investigator had the model number From the crib went out looked at the crib, but could not identify any Greco crib with that model number So that was the end of the investigation. He felt it was a dead end left the crib where it was And did not go back to look at that particular crib until two years later when the Chicago Tribune started investigating deaths and simplicity products and Realized that in fact the model number was a simplicity number But there was not simplicity written anywhere on the crib There was no information at all that it was anything other than a Greco crib that somehow had a wrong model number on it So during that time You know not only did additional children die in simplicity cribs But millions more were made and put out into the consumer Into consumer use most of which are still in use today And they're still babies sleeping in these cribs that we know are dramatically unsafe So for consumers, what's the information that they need and why do they need tracking labels? The first I've talked about a little the crib that Danny died in was licensed with one brand but made by a different company. It's a it's a continuing Practice within the juvenile products industry as well as many other industries where the product The name that you see on the product is not the name of the company that made the product And so for consumers to be able to participate in recalls We need accurate identifying information on the product who the actual manufacturer was not just the licensed name That's on it in addition. Some companies have different brand names for their own products And again, it's confusing if you hear of a recall by one company When in fact that name does not appear to consumers anywhere on the product You're going to have people not paying attention to the recall and as I've mentioned with the simplicity Sometimes they're simply no labeling at all and it's almost impossible to find out if your product in that is Part of the recall or if you need to report a safety problem with it I've seen recalls For consumers to try and participate in where not only do they have to look in a particular place for where the brand name is and what Shape the brand name is because that might indicate a time difference They have to look obviously for the serial number a model number and in addition maybe some other Identifying features such as a different color part on it from the ones that were made later and were safe That's really a lot to ask of a consumer when in one place you can have the information they need And I love the data idea by the way. I think that's a great idea so that you can easily show parents Where to get the information and how to participate in the recall? So we've talked I've talked a lot about recalls That's obviously a very important issue to us because we know how ineffective recalls aren't anything that makes them more effective Makes more people participate in them is very important and our primary goal in making sure that tracking information is Easily accessible on products, but it goes both ways too We have a new consumer database here in the United States where consumers can make complaints We've heard concerns from companies that there's not accurate information that the model number is sometimes left off or that they Misidentify the manufacturer having a tracking label will take care of that problem and make sure that that information on the on the product In the database is as accurate as possible Also when they're reporting problems to the manufacturer if they can make sure they're talking to they're both talking about the same product They can get the appropriate replacement parts so that they don't end up putting on a part That doesn't adequately fit the product that they use so for safety for consumers We think that in a way to clearly identify the manufacturer of the product the time What lot it was in is crucial for safety in the event that something goes wrong with the product in addition, I think we we've already talked about this if you're putting that if one company is putting the Same component into numerous manufacturers products and something goes the matter with that component We don't want just one manufacturer to catch it and fix it. We want to make sure that wherever that component is used We can look at those products And the flip side of that is true if you're using multiple suppliers for a part in your one manufacturer You know you want to make sure that you're able to identify which suppliers part is causing the problem and need to be replaced Also tracking labels will allow regulators to more accurately track products in corrective action So we can have a better count of how many products have been Recalled have been parents have participated in the recall. We've gotten those products out of consumer use Otherwise, we're just kind of dealing with nebulous numbers where we think maybe that product isn't still in use But we really don't have accurate information And I think it's already been mentioned that it also helps manufacturers to lessen the impact of a recall because you only have to Recall the products that are affected not the broad group that kind of look like them so that you want to make sure you get all of them And finally we think that there as been mentioned this requirement is only on children's products We think obviously it would have a huge impact on other products as well to improve the recall effectiveness We think that there's additional ways that manufacturers can use that information the product registration system was was mentioned again that That requirement is named after Danny. We take it very seriously We think that the onus should be on the companies to make sure parents learn of recalls one way to do that is to better Promote and encourage participation in product registration, and I think there's ways that tracking labels can be done Can be used to do that. Thank you Thank You Nancy. Our next presenter is mark of vanco mr. Vancoe is the executive vice president of quality assurance at Durell Durell juvenile group a leading manufacturer of juvenile products Pride prior to working for Durell Mark worked in for ACTS testing labs where he managed their technical testing services for a wide range of products He is a recognized expert in risk management quality systems development quality assurance quality control Technical testing services and regulatory standards development of mark of vancoe He's coming. Oh, there we go This is you here Well, it's a good thing the engineers are back from yesterday Good morning, it's certainly a privilege to be here to be able to present to our distinguished Chinese guests me how mom and for the people in the south chose on and But it's really a privilege You know today's presentation talking about the best practices and tracking and labeling Certainly our panel members of Andy and Randall and ants have covered a lot of this scope today So briefly I want to cover some of the things they talked about some other things they didn't talk about So be talking about what products are regulated, you know, what is required Andy talked about it We're the labels required to be the purpose of tracking labels How are tracking labels connected to traceability and I'll be giving you some examples of different types of labels That are on products that we use and finally why is it important to have tracking labels? Certainly Andy talk about the products covered children's products for children 12 years of age and younger You need to have the manufacturers name address contact information Data manufacturer and then some sort of batch coding or a serial number or a lot coding Andy talked about where it should be well should be on the product and on the package So why are tracking labels important to manufacturers? Well as a best practice The tracking label provides traceability if there's a quality issue such as a recall But furthermore if you look at tracking labels, they build the foundation in Concept for a comprehensive traceability system. You've heard our panel members talking about traceability Well for a manufacturer. It's very critical to have a comprehensive Traceability system it can trace products through distribution centers through retailers You can trace product and all its components you can trace the product its suppliers its Subcontractors you can get down to the component level and also you can track back the materials For this presentation, I kind of took a different Approach to it. I'm going to use a lot of pictures Certainly your final product in this case here. We have a master carton We have two inner products that go on each individual goes on the shelf But on our master carton this two-pack we have the model number out there We have a purchase order and often purchase orders are tied back to manufacturing lots the start of that traceability system We have your date code another identification information on the package itself You have the required information who made it. Oh We have something different here We put our 800 number for the consumers because it's all about the consumers being able to contact the manufacturer if they have a concern about their product So on our packaging we put our 800 number We also put Our web page So they can also contact us through the internet now These are not required, but certainly for us. They're a best practice. They're very optional But they're a best practice and everybody should consider using them The other parts of the label obviously what is required Here it is again other packaging information the model number the date code The manufacturer where it was made We also put on our products not only the date code, but we have a supplier code Our suppliers are coded so we know exactly which manufacturer made this I don't know if it comes out very well on the screen here, but here's a molded part We actually mold in identifications into our major components that are made of plastic All the required information is there once again We put in our supplier codes in this case here It's a cavity number for further identification of the traceability system Your tooling engineers can get creative about markings on products here You see a surface a step down step up to the surface The tooling engineers can get really creative about really getting the right information on that product to help the consumers I showed you a date wheel before very common in the industry common in consumer products atoy industry juvenile industry Certainly this product here just for educational purposes product was made in May of 2011 Date wheels come in all kinds of configuration sizes some are manual very common in China and some are automatic Because if you start looking at the surface area of your product you can get creative about information for traceability Here we actually have a number on the mold that is tied right back to the engineering drawing in the engineering specification for that component Kind of unique way of starting your traceability system We have a batch code and once again traceability down to which cavity because you need to know if you have a problem You might have a two cavity mold You may have a four cavity mold or if you're making a lot of small components You could have a 24 or 32 cavity mold You need to have an understanding where that problem is coming from often here Comments about small components small products and how you can put markings on them here at this components about the size of a golf ball and You can see the different surface area not a lot of surface area But we're able to put in our vendor codes We want to get back to it to understand who our Subcontractors are and who our vendors are and the cabinet they're using But talking a lot about plastics and markings on plastic. Well, here's a stamp on aluminum. Okay, you can stamp steel But one of the things we don't typically do is we don't stamp steel because when you stamp it You actually damage the plating when you damage the plating that area becomes a really very susceptible to rust other types of Materials here on fabric. We have a lot code a date code Also on fabric you can put small labels into the seams or you can use things like This caro label. We've put the model number on it on the back of it We've put the date code on there that was selling Randall talked about UPC and bar coding We use bar coding on certain labels certainly here You see all the mandatory required information But as a bar coding system you can get very very elaborate and what you're trying to track You can be tracking purchase order manufacturing date supplier Component you can even track in this case here the manufacturer of this label We do bar coding on site But the real key to using bar coding is if you have a product that has 10 major Components to it and each one has a bar code You can go into the final assembly stage and scan each one of the bar codes into a final bar code Excuse me and then to a final bar code That gives a history of the product We actually have scanning systems that are manual We have automatic scanners for our certain bar coatings because you have certain mandatory labels out there and Our systems are set up that if the final stage of bar coding is Not completed with a scanner the product can't move down the assembly line from there. It stops so we use it as also a Assurance for what we're trying to accomplish and make sure we have the mandatory labels there today's technology You can actually and you see it on some very expensive products out there. They have small computer chips And that computer chip basically collects all of the data about that product Almost to a point of a serial number, but in those computer chips That becomes a very small database of traceability You've heard people talking about product registration cards Obviously, it's another type of marking on there to help consumers contact us and for us to contact the consumers if there is a recall as a best practice and Quality systems you really need to have traceability You know you you heard our panel members talk about traceability Well, sometimes in this simplified version of traceability and trying to explain it to non-technical people You know certainly traceability and things of that sort becomes technical But when you try to explain it to non-technical people if you think of a tree the trunk of a tree and as you go up the tree you have Large branches that go into small branches that go into twigs Traceability works the same way if you think of a trunk of the tree as a final product and you go up the tree You go into your final assembly you can go into the branches into the component assembly Randall showed you that Manufacturing picture up there a lot of components go into and a lot of activities go into manufacturing a product So if you think about in simple simplified terms going up the tree into the small branches into the subcontractors You can really get to the twigs when you get to the twigs you actually get to gee here are my components here my materials Here's my inks here my labels. Here's my packaging material. You can track all the way back into it How does it help a manufacturer? If you have a quality issue One of the things you can do is reduce your cost of quality No pun intended you do a root cause analysis Okay, so you do a root cause analysis and you basically are able to track through and trace that Product and trace back into the component tree of that product Ultimately it does reduce your cost of quality So why is it important to have tracking labels? Well, obviously to assist us the manufacturers and locating the affected units In case of a quality issue or recall As a best practice it becomes the tracking label becomes the foundation for traceability That allows us to narrow down that issue Narrow it down to a certain date a supplier a manufacturer a batch a component a material Minimizes number of units out there Reducent the cost of quality But really the most really important piece of information about that tracking label is about the consumers Tracking labels that are permanent molded in stamped in permanent labels. Don't get lost Consumers can contact us and we want consumers to contact us We want consumers to contact us through our 800 number or a web page Consumer feedback is critical to our business When they call in if they can give us more tracking information helps us identify the problem faster Helps us identify root cause faster So we really treasure consumer feedback ultimately Gives us continuous improvement for the product. Thank you. Thank you mark at this at this point in time. I'd like to Open up the discussion to questions from the audience I've got a couple of myself that I can start with This one is for Miss Cowles currently under the statute manufacturers have a significant amount of Flexibility when it comes to the information that has to be contained on on tracking labels In your view should should the CPSC standardize the content and appearance of tracking labels and and and what we why or why not I Think that the statute spells out the basic information that needs to be there And I think that that is probably enough standardization. I mean unless something changes. We actually think that the tracking labels Can be used not only for getting That specific information But unlike the product registration cards which have to be very standardized so that consumers don't think they're marketing materials You have more leeway with the tracking label We'd like to see things like barcodes that the consumers could use or QR codes that they could use with their smartphones That would automatically take them to the registration page So they bring your product home snap a picture with their phone that takes them right to the page where they can fill out the product registration Or you know, I think that mark has given some excellent examples of additional information That's useful useful to consumers any way that they can reach you more easily Identify the very specific product. They have more easily It's going to keep their keep them safer and make sure that you can improve your product faster Do a recall faster if you do need to do that Thank you. We have a question from the audience. Yes. Thank you mark knocks I'm with TV Rhineland a third-party test lab. My question is for mr. Gooden he mentioned of unique and I think a very good idea of actually time and date Stamping products as they go through the system and possibly also components. My question is twofold one Do you have some resources you could point manufacturers to? for manufacturers of such types of label printers and Question two is how small can those labels be to your knowledge currently? Thank you Well two things. No, I don't have I didn't want to be promoting certain label making Machine makers and stuff and so I don't have the sources It's a simple enough concept The the as I would envision it the the role of labels would be going through the machine would already have printed on it The manufacturer's name and a location and it's just a time stamp that that hits and then the person peels it off and sticks it on and the size of it Even the type of material that it would be Would then be different with different sizes of products and different types of products So if you have you know, you could have outdoor products. You could have products that are in windows You can you can have small products and larger products And so the size of the label, you know, I don't think that there's a size that that I'd say that it has to be but in all labels even warning labels You run into the issue of is there surface for it to be applied how much surface space do you have and so How big of a label do you need to have it? It's pretty simple in size. So it doesn't have to be too big I'd like to add a few comments to that Just so The audience knows a good label supplier Can give you all types of sizes the labels for a time stamp on a label. We actually on a number of our manufacturing lines We have computers and systems right there So they're actually printing out the entire label right on this only line that gives you the ability to have instantaneous dating and timing on it from a Date coding point of view and molding you can have automatic minute timers That are put in there. However date coding instrumentation can tend to be very expensive especially automatic day coders Okay, so but you can have day code Instrumentation out there for minute the day the hour can they want a multitude of different options out there Think we have another question from the audience Good morning and weeks with underwriters laboratories, so I must confess my question is gonna be more as a consumer and a recent mother of a 13-month-old It's interesting to hear about the tracking labels and how Different information appears on different parts of the product the packaging the product the components what sort of education or communication Do manufacturers or CPSC or other stakeholders? How do you help educate consumers about that information and? How to to leverage it? When needed You know, I think about the purchase of a product and what information is on the packaging versus the product and Not parent lot of parents not retaining packaging what might have vital information, so I'll just start real quick, and I will say that the information on the tracking label Other than the idea I just had about the or gave about the product registration is actually information the consumers should not need So that information until there's a problem with the product either that they need to call someone to report Or it's been recalled. It's there for that purpose. So You know, but in terms of you know, it's a concern that we do have that that information instruction books or Warning labels that are only in the instructions are on the packaging are you can just assume that parents are not keeping that Packaging sometimes parents might not even see that packaging if they get a gift and someone's already taken it out of the packaging to give It to them set it up, you know, you give a new mother a Playyard or something and at the shower and they've already taken out the box and set it up for kind of as a surprise And so I think that the more information that's available either on the product itself Or Attached to the product in some way just like with cribs We have the requirement that that instruction information all that information have a way to permanently stay with the product So depending on the size of your product. That's another thing to look for I think that you know We often I think it was given in the talk yesterday rely on consumer education for safety and it's really way down the list if you're relying on Consumers being extremely well educated about everything that's on your product for safety You're going to end up having problems and so it's you know These are for this is information for when there is a problem And shouldn't be what you're relying on to keep the consumers safe from the product to start with I might add to that the And what you're really getting down to is adequate warnings In my circle I talked about product liability prevention one of the largest causes of product liability Lawsuits our lack of adequate warnings and instructions on the product As Nancy had just mentioned you don't have the manuals anymore can be any consumer product And we're once you understood how the thing works out goes the manual so the warnings can't be there The the safety warning and hazardous warnings And as much instruction as possible should be right on the product be labeled on the product But you but manufacturers have a duty to warn and and so the warning and the conspicuous And so the warning has to be on a product not contained in some manual someplace And so that's the that in the safety hierarchy that was Mentioned yesterday. That's the duty of the manufacturers to make sure that that's there and it's right there Where the hazard could take place or the danger the potential danger they could be exposed to takes place I'm going to take the moderators prerogative and ask the final question of the panel At this at the CPSC we find a significant number of violative products that come into the ports also don't have Don't have tracking labels like to ask mr. Ivanko If he has any insight as to the reasons why we're not seeing Tracking labels on a significant number of the the products that we're sampling at the ports and if he has any Suggestions as to what can be done to address that problem Well, hopefully it's not our product But I think what it comes down to is we go to great lengths to educate our suppliers on their requirements We do Symposiums with our suppliers in China to educate them on new requirements I think a lot of it has to do with are you purchasing overseas goods That are finished products or you're actually doing some designing and manufacturing over there where you have control We control a lot of our information most of our information through engineering products product specifications So we specify the information has to be on the product and has to be on the package But I would encourage more education of the vendors over there the subcontractors certainly smaller Chinese vendors do not are not aware of a lot of the regulations out there, and I think that's an opportunity Thank you. I think this has been a very informative presentation regarding issues surrounding tracking labels and traceability and and best practices and The benefits of traceability from both the consumer and the manufacturer's standpoint, and I'd like to again thank our panelists for their Insights, thank you