Over the past year, we have worked closely with the Commission to implement this new law. We look forward to that continued close cooperation.
I would like to share with you four key lessons we have learned that should be considered as we move forward:
First, it takes time to phase in new product safety regulations. For our industry, it can take nearly a year for a single garment to travel the supply chain. New regulations must give industry enough time to adapt the supply chain so we can understand and clearly communicate changes to our industry.
Second, regulations should take effect prospectively, and only after there is clear and comprehensive regulatory guidance from the Commission. The retroactive application of regulations unfairly punishes businesses for making products in good faith, especially when they were made in compliance with a previous product safety standard.
Third, all product safety regulations should be designed to mitigate and protect against specific risks and be clearly supported by the data and facts. Understanding new safety regulations involves understanding how they will address the specific hazard. Without that, the standards seem arbitrary and that perception will undermine the standards' effectiveness and acceptance.
Finally, product safety standards that work best are those that are created through a transparent and predictable process. The product safety community involves a range of stakeholders, all of whom need to participate. If one group appears shut out, the final result may not be credible or accepted by all. This, in the long run, leads to a product safety regime that is not sustainable. Product safety should be based on fact, and not politics.
In conclusion, let me stress again how delighted we are to see five Commissioners sitting at this panel. We know that there are a number of challenges related to the CPSIA and to the on-going work of the Commission in other areas.
At the same time, we believe there are many opportunities for further collaboration, and we look forward to strengthening our partnership for the benefit of consumer product safety and public health.
American Apparel & Footwear Association
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