Comments on Reasonable Testing Programs
The Retail Industry Leaders Association (RILA) appreciates this opportunity to provide comments on the Consumer Product Safety Commission’s (CSPC) guidance that has been issued on the tenets of a reasonable testing program, as permitted by Section 14 of the Consumer Product Safety Improvement Act (CPSIA). RILA is encouraged by the CPSC’s information gathering process that has been laid out in the public notices, including the CPSC-sponsored workshops on December 10-11, 2009. RILA believes that it is critical for the successful implementation of the CPSIA that the CPSC establish a framework for reasonable testing programs that is workable and flexible. We welcome the CPSC’s recognition that a one-sizefits-all approach will not work for reasonable testing programs.