Letter on Recent Revisions to CAP Monthly Progress Reporting

The undersigned organizations express concern with recent revisions to the standard monthly progress reporting form1 for use in reporting progress toward completing the commitments made by firms in connection with Corrective Action Plans (“CAPs”) related to voluntary product recalls. Though we appreciate efforts by the U.S. Consumer Product Safety Commission (“Commission” or “CPSC”) and its staff to streamline the form, the revised form and new obligations that are being demanded by staff and included in new CAP acceptance letters from staff raise serious policy and legal concerns.