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© - Copyright Bureau Veritas

CPSIA - Reasonable Test Program (RTP)

April 28th, 2011

Ben Lau

2Bureau Veritas Presentation April, 2011© - Copyright Bureau Veritas

You will learn

► What is a Reasonable Testing Program?

► Who will be affected?

► How to prepare for this?


What is Reasonable Testing Program?


History

► Element of CPSIA

► Proposed rule “16 CFR 1107 “Testing and Labeling pertaining to

Product Certification” – May 2010

Extensive comments made on proposed ruled

► Final rule – coming soon (expected in mid of this summer, Jul /

Aug, 2011)

► Final rule effective date – typically 180 days after enactment

Products that apply must comply after this date

Manufactured on or after


What is a Reasonable Testing Program (RTP)?

► Under the Consumer Product Safety Improvement Act (CPSIA), it will be mandatory for manufacturers to have in place a “Reasonable Testing Program” for all products that require certification.

► This means that a formalized program of good manufacturing processes as described in 16 CFR 1107 will be required.

► General use products are required to be certified under the “Reasonable Testing Program”

► Children’s products must be certified by a “Children’s Product Testing Program” (CPTP).


CPSIA Requirement for Certification of Products

► Non-Children’s Products

Section 102 of CPSIA required a General Conformity Certificate (GCC) for all consumer products, not intended for children, subject to a rule ban or standard.

That certificate must be based on testing of a product in accordance with a reasonable testing program

► Children’s Products

Children’s Products require 3rd party testing at CPSC approved accredited test lab for all applicable requirements

To certify a children’s product a compliant certification program or children’s product testing program must be followed


Elements of a RTP (Non–Children's Product)

►Product specification

►Certificate testing

►Product testing plan

►Remedial action plan

►Record keeping


RTP - Product specification

► A description of the consumer product and lists the applicable rules, bans, standards or regulations to which the product is subject.

► The product specification may include, but is not limited to, a color photograph or illustration, model names or numbers, a detailed bill of materials, a parts listing, raw material selection and sourcing requirements.

► Each manufacturing site must have a separate product specification.


RTP - Certificate testing

► Conduct certification tests before issuing a GCC

► Samples must be identical to the final product

► Submit a sufficient number of samples to provide a high degree of assurance in representing the final product.

► High degree of assurance means an evidence-based demonstration of consistent performance of a product regarding compliance based on knowledge of a product and its manufacture.

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RTP - Product testing plan

► A production testing plan describes what tests must be performed and the frequency at which those tests must be performed to provide a high degree of assurance

► A description of the production testing plan, including, but not limited to:

a description of the tests to be conducted or the measurements to be taken

the intervals at which the tests or measurements will be made

the number of samples tested, and

the basis for determining that such tests provide a high degree of assurance of compliance if they are not the tests prescribed in the applicable rule, ban, standard, or regulation

► Each manufacturing site must have a separate production testing plan

► The production testing interval selected must be short enough to ensurehigh degree of assurance


RTP - Remedial action plan

► A remedial action plan describes the steps to be taken whenever samples fail to comply with a requirement

► A remedial action plan must contain procedures the manufacturer must follow to investigate and address failing test results.

► Manufacturers must take remedial action after any failing test result

► Any remedial action that results in a material change to a product’s design, parts, suppliers of parts, or manufacturing process requires a new product specification for that product.

► Before a product covered by the new product specification can be certified as compliant, a manufacturer must have passing certification test results for the applicable rules, bans, standards, or regulation


RTP - Remedial action plan (Con’t)

► Remedial action can include, but is not limited to:

Changes to the manufacturing process, the equipment used to manufacture the product, the product’s materials, or design;

Reworking the product produced;

Other actions deemed appropriate by the manufacturer, in the exercise of due care, to assure compliant products.


RTP - Record Keeping

► A manufacturer of a non-children’s product must maintain the following records:

Records of the general conformity certificate for each product;

Records of each product specification;

Records of each certification test

Records of the production testing plan requirement

Records of all remedial actions taken

► A manufacturer must maintain the records specified in this subpart at the location within the United States

► The manufacturer must make these records available, either in hard copy or electronically, for inspection by the CPSC upon request.

► Maintain records for as long as the product is in production or imported by the manufacturer plus five years.

► All records must be available in the English language.


Elements of a Children’s Product Testing Program

►Certificate testing – 3rd party testing required

►Periodic testing plan

►Random sampling

►Material change tracking

►Records of undue influence

►Remedial action plan

►Record keeping


Who will be affected?



► For the retailer:

Retailers who are identified as the importers of record, or who are selling a product under a private label, will need to implement the RTP or CPTP requirements for all products that require certification.

► For the importer / importer of record:

As the importer of record, you are required to ensure the products that require certification be compliant to RTP/CPTP. While you may be unable to implement all elements of the programs yourself, you are responsible to check that your products have been properly certified by the appropriate parties.



► For the domestic manufacturer or domestic brand:

If your products require certification, you are responsible to implement the requirements of a RTP / CPTP and certify your products accordingly.

► For the non-domestic manufacturer:

If you are not the importer of record, the RTP/CPTP requirements are not directly applicable to you but you may still need to implement some elements. For example, only the factory is capable of tracking their material changes in production and an importer who is responsible to comply with the requirement would need that step to be taken by the factory.


How to prepare for this new regulation?


FAQ

► http://www.bureauveritas.com/wps/wcm/connect/bv_com/Group/Home/About-Us/Our-Business/Our-Business-Consumer-roducts/Resources/Frequently+Asked+Questions/RTP_FAQ

http://www.bureauveritas.com/wps/wcm/connect/bv_com/Group/Home/About-Us/Our-Business/Our-Business-Consumer-roducts/Resources/Frequently+Asked+Questions/RTP_FAQ












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