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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

May 2012: 

Consumer Product Safety Commission: 

A More Active Role in Voluntary Standards Development Should Be 
Considered: 

GAO-12-582: 

GAO Highlights: 

Highlights of GAO-12-582 a report to congressional committees. 

Why GAO Did This Study: 

Growing numbers of recalls in 2007 and 2008, particularly of children’
s products, focused increased attention on CPSC. Consumer products can 
be subject to mandatory or voluntary standards, or both. Questions 
have been raised about the level of compliance with voluntary 
standards and CPSC’s ability to encourage compliance. The Consolidated 
Appropriations Act of 2012 directed GAO to analyze manufacturers’ 
compliance with voluntary industry standards. This report evaluates 
(1) what is known about the extent to which manufacturers comply with 
voluntary standards for consumer products, (2) CPSC’s authority and 
ability to require compliance with voluntary standards, and (3) the 
consequences for manufacturers that fail to comply with voluntary 
standards. 

To do this, GAO reviewed CPSC’s statutory and regulatory authorities 
to encourage compliance with voluntary standards; reviewed agency 
documents and literature on consumer product safety; analyzed data on 
CPSC corrective actions; and met with representatives from national 
consumer, industry, legal, and standard-setting organizations who have 
expertise in developing consumer product safety standards. 

What GAO Found: 

Although the Consumer Product Safety Commission (CPSC) enforces 
compliance with mandatory federal safety standards, it is also 
required by law to rely on voluntary safety standards when it 
determines that the standard adequately addresses the product hazard 
and is likely to have substantial compliance. Voluntary standards—
developed by industry, consumer, and government participants through a 
consensus process—cover many of the thousands of types of products in 
CPSC’s jurisdiction. Compliance with voluntary standards is not 
routinely tracked, but it is generally considered to be high by 
industry participants. Compliance with these standards also depends on 
industry and legal factors, such as retailer requirements to 
demonstrate proof of compliance with voluntary safety standards and 
risk of liability in product liability lawsuits. 

Because voluntary standards do not have the force of law, CPSC cannot 
compel compliance with them. However, noncompliance with a voluntary 
standard can inform a determination of a substantial product hazard by 
the CPSC that in turn can lead to CPSC enforcement actions. CPSC has 
exercised its expanded authority to place a product on the substantial 
product hazards list. Specifically, it designated drawstrings from 
children’s upper outerwear and hair dryers without a ground fault 
circuit interrupter as hazardous products, and Customs has seized 
violative items at ports. CPSC also participates in standard 
development activities with industry and consumer representatives and 
monitors select voluntary standards. CPSC attends standard development 
meetings, supplies hazard and injury data and analysis, and provides 
input on draft standards. However, CPSC’s regulation prohibits staff 
from voting on the final standards or from participating in any 
meeting that excludes other groups, such as media or consumers. CPSC’s 
rationale for limiting involvement in standards development activity 
is to maintain its independence—such as not appearing to endorse a 
specific standard. Office of Management and Budget guidance gives 
agencies discretion to determine their level of participation in 
standard setting activities, including full involvement in 
discussions, serving in leadership positions, and voting on standards. 
A January 2012 White House memorandum states that the federal 
government may need to be actively engaged in standards development 
and implementation, including playing an active role in standard 
setting and assuming leadership positions in Standard Development 
Organization committees. Committee participants GAO spoke to value CPSC’
s input but generally agreed that CPSC should participate earlier and 
take a more active role in standards development. These actions could 
enhance CPSC’s oversight, and may strengthen voluntary standards. 

Manufacturers that fail to comply with voluntary standards can face 
consequences when CPSC has determined that noncompliance poses a 
significant risk of injury or death to consumers. CPSC can take 
corrective action against the manufacturer, including recalls, or take 
longer term action to ban the hazardous product. CPSC has focused much 
of its surveillance and compliance work on imported products. For 
fiscal years 2008 through 2011, 80 percent of CPSC recalls have been 
of imported products that may be subject to voluntary standards, 
highlighting challenges CPSC faces in helping to ensure the safety of 
consumer products. 

What GAO Recommends: 

To strengthen the adequacy of voluntary standards, CPSC should review 
the policy for participating in voluntary standards development 
activities and determine the feasibility of assuming a more active, 
engaged role in developing voluntary standards. CPSC supported the 
recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-12-582]. For more 
information, contact Alicia Puente Cackley at (202) 512-8678 or 
cackleya@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Standards Development Process, Industry Certification, and Legal 
Factors Help Ensure Compliance with Voluntary Standards: 

While CPSC Cannot Legally Require Compliance with Voluntary Standards, 
Industry Monitoring and Participation in Standards Development Help 
Encourage Compliance: 

CPSC Can Impose Corrective Actions When Noncompliance with Voluntary 
Standards Presents a Substantial Product Hazard: 

CPSC Databases Do Not Identify Products with Voluntary Standards, but 
the Agency Collects Data That Could Help Identify Patterns of 
Noncompliance: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Comments from the Consumer Product Safety Commission: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Number of Voluntary Standards Monitored and Code Revisions 
Supported by CPSC Staff for fiscal years 2007 through 2012: 

Table 2: CPSC Recalls of Regulated and Unregulated Products for fiscal 
years 2007 through 2011: 

Table 3: CPSC Standards Activities and Recall Actions for Selected 
Products for fiscal years 2007 through 2011: 

Abbreviations: 

ANSI: American National Standards Institute: 

CPSA: Consumer Product Safety Act: 

CPSC: Consumer Product Safety Commission: 

CPSIA: Consumer Product Safety Improvement Act: 

NIST: National Institute of Standards and Technology: 

OMB: Office of Management and Budget: 

SDO: Standards Development Organization: 

UL: Underwriters Laboratories, Inc. 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

May 21, 2012: 

The Honorable Richard Durbin: 
Chairman: 
The Honorable Jerry Moran: 
Ranking Member: 
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
United States Senate: 

The Honorable Jo Ann Emerson: 
Chairwoman: 
The Honorable José E. Serrano: 
Ranking Member: 
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
House of Representatives: 

Growing numbers of recalls in 2007 and 2008, particularly of toys and 
other children's products, focused increased attention on the Consumer 
Product Safety Commission (CPSC). On August 14, 2008, the Consumer 
Product Safety Improvement Act (CPSIA) was enacted to reform CPSC and 
strengthen its authority to enforce consumer product safety standards. 
[Footnote 1] Many safety standards covering consumer products are 
known as voluntary standards, developed by industry, consumer, and 
government representatives through a consensus process. Questions have 
been raised about the level of compliance with voluntary standards and 
CPSC's ability to encourage compliance. 

Voluntary standards are generally determined by standard-setting 
organizations, with input from government representatives and industry 
groups, and are also referred to as "consensus standards." These 
voluntary standards do not have the force of law. Amendments in 1981 
to the Consumer Product Safety Act (CPSA)--CPSC's original authorizing 
legislation--directed CPSC to defer to voluntary standards rather than 
issue mandatory standards if it determines that the voluntary standard 
adequately addresses a potential product hazard and that there is 
likely to be substantial compliance with it.[Footnote 2] CPSC 
monitored or provided technical support for 174 new, revised, or 
reaffirmed voluntary standards from fiscal years 2007 through 2011, 
according to CPSC reports. 

In the Consolidated Appropriations Act, 2012 Congress directed us to 
analyze compliance with voluntary industry standards for consumer 
products overseen by CPSC.[Footnote 3] In this report, we evaluate (1) 
what is known about the extent to which manufacturers comply with 
voluntary standards for consumer products, including inexpensive 
imported products; (2) CPSC's authority and ability to require 
compliance with voluntary standards; (3) the consequences for 
manufacturers that fail to comply with voluntary standards; and (4) 
CPSC's efforts to identify patterns of noncompliance. 

To address these objectives, we reviewed CPSC's statutory and 
regulatory authority to encourage compliance with voluntary standards. 
We also reviewed CPSC's standard operating procedures, performance and 
accountability reports, budget documents, and our relevant prior 
reports. We met with cognizant CPSC officials to discuss their 
authorities and their ability to enforce them, including all of CPSC's 
current commissioners and the Chairman.[Footnote 4] Additionally, we 
obtained and analyzed data from CPSC's compliance databases to 
identify (1) the number of reported instances of noncompliance; (2) 
the number of times these instances led to a corrective action; (3) 
the numbers of corrective actions that resulted; (4) the number of 
product units recalled; and (5) the type of standard, if any, that 
covered the product. We assessed the reliability of these data by 
reviewing existing information about the data and the system that 
produced them, and interviewing agency officials knowledgeable about 
the data and related management controls. Based on this assessment, we 
determined the data to be sufficiently reliable for the purposes of 
this report. We interviewed the three standards development 
organizations that coordinate the development of more than 90 percent 
of voluntary standards developed with CPSC staff technical support. We 
obtained testimonial and documentary information from national 
consumer, industry, and legal organizations that have expertise in 
working on voluntary standards development for consumer products. See 
appendix I for additional information on our scope and methodology. 

We conducted this performance audit from January 2012 to May 2012 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

CPSC was created in 1972 by the Consumer Product Safety Act to 
regulate certain consumer products and address those that pose an 
unreasonable risk of injury; assist consumers in using products 
safely; and promote research and investigation into product-related 
deaths, injuries, and illnesses.[Footnote 5] According to CPSC, this 
jurisdiction covers thousands of manufacturers and types of consumer 
products. CPSC does not have jurisdiction over some categories of 
products, including automobiles and other on-road vehicles, tires, 
boats, alcohol, tobacco, firearms, food, drugs, cosmetics, medical 
devices, and pesticides. Other federal agencies--the National Highway 
Traffic Safety Administration, U.S. Coast Guard, Department of 
Justice, Department of Agriculture, Food and Drug Administration, and 
Environmental Protection Agency--have jurisdiction over these products. 

CPSC has jurisdiction over thousands of types of consumer products and 
hazardous substances, many of which are subject to mandatory 
regulations or voluntary standards, or both.[Footnote 6] Mandatory 
standards are federal rules set by statute or regulation that define 
the requirements consumer products must meet. These standards 
establish performance and labeling criteria that products must meet 
before they are manufactured, imported, distributed, or sold in the 
United States. CPSC may set a mandatory standard when it determines 
that a voluntary standard would not eliminate or adequately reduce a 
risk of injury or finds that substantial compliance with a voluntary 
standard would be unlikely.[Footnote 7] The Commission also may impose 
a mandatory ban of a hazardous product when it determines that no 
feasible consumer product safety standard adequately would protect the 
public from an unreasonable risk of injury.[Footnote 8] In some cases, 
Congress has enacted a specific statutory requirement for CPSC to 
create a mandatory standard, or convert a voluntary standard to a 
mandatory standard. For instance, CPSIA mandated the conversion of 
voluntary standards for durable infant and toddler products, all-
terrain vehicles, and children's toys to mandatory standards.[Footnote 
9] Mandatory standards and bans are enforceable by CPSC, allowing the 
agency to stop imported products that do not meet federal requirements 
at ports and seek civil or criminal penalties for violations of the 
mandatory standards or bans. Approximately 200 products are currently 
regulated and subject to mandatory standards, including automated 
garage door openers, fireworks, and children's cribs. 

Many consumer products under CPSC's jurisdiction, including smoke 
alarms, candles, and portable generators, are subject to voluntary 
standards.[Footnote 10] More than 700 standards development 
organizations (SDO) develop most voluntary standards used in the 
United States, including safety standards. SDOs include private-sector 
professional and technical organizations, trade associations, and 
research and testing entities. According to CPSC, three SDOs--
Underwriters Laboratories, Inc. (UL); ASTM International; and the 
American National Standards Institute (ANSI)--coordinate the 
development of more than 90 percent of voluntary standards developed 
with CPSC staff technical support. Participants in the standards 
development process include representatives from government agencies, 
manufacturers, consumers, retailers, testing laboratories, technical 
experts, and other interested parties. In general, most SDOs operate 
by principles that govern the voluntary standards process, such as 
openness, balance, consideration of views and objections, consensus 
vote, and the right to appeal. The process of developing consensus 
standards is designed to be transparent, with written procedures 
covering each step. Participation in the standard development process 
is intended to be voluntary. Standards developed by an SDO are 
considered the property of the SDO. CPSC officials told us that once a 
standard is published and copyrighted, members of the public and 
government agencies generally must purchase them. 

The National Institute of Standards and Technology (NIST), the federal 
agency that coordinates standard activities, maintains a database of 
standards that have been incorporated by reference into federal 
regulations. NIST also has online search tools that members of the 
public may use to locate other standards--including voluntary 
standards not incorporated by reference into federal regulations--but 
according to agency officials, the agency does not collect or maintain 
voluntary standards. 

CPSC's voluntary standards activities are overseen by a Voluntary 
Standards Coordinator, appointed by the Commission's Executive 
Director. The coordinator is the senior agency official responsible 
for managing the Commission's voluntary standards program. One of the 
coordinator's main duties is to prepare and submit to the Commission a 
semiannual summary of staff's voluntary standards activities. Duties 
also include providing advice and recommendations for the development 
of new voluntary standards or the revision of existing voluntary 
standards, in conjunction with CPSC management. The coordinator also 
proposes policies and guidelines concerning voluntary standards 
activities, reviews associated public comments, and prepares 
recommended policies for approval by the Commission. The coordinator 
works with SDOs, and recommends and trains CPSC staff to serve as 
technical experts to those organizations. Further, the coordinator is 
the liaison to industry associations, other government agencies, and 
any other group interested in voluntary standards. 

CPSC's Office of Compliance and Field Operations, currently with 166 
staff, has primary responsibility for helping ensure compliance with 
product safety standards. Its activities include enforcing mandatory 
standards and reporting requirements, investigating product hazards, 
and determining corrective actions (such as recalls) for manufacturers 
not in compliance with safety standards.[Footnote 11] CPSC also has an 
Office of Import Surveillance and Inspection that coordinates 
enforcement efforts with U.S. Customs and Border Protection to help 
ensure import compliance with safety standards. CPSC has investigators 
stationed at some ports of entry to assist in surveillance activities. 
In a past report, we made recommendations to strengthen CPSC's ability 
to target unsafe consumer products, especially imported products. 
[Footnote 12] We recommended that CPSC work to educate foreign 
manufacturers about U.S. product safety standards and best practices, 
including the importance of complying with voluntary standards. CPSC 
concurred with our recommendation. The 2011-2016 Strategic Plan states 
that CPSC has been seeking to create and strengthen partnerships with 
domestic and international stakeholders, including foreign regulators 
and manufacturers, to improve product safety throughout the supply 
chain. Also, CPSC's Office of Education, Global Outreach, and Small 
Business Ombudsman has separately developed and issued plans for 
addressing consumer product safety on a country-specific and regional 
basis. 

Standards Development Process, Industry Certification, and Legal 
Factors Help Ensure Compliance with Voluntary Standards: 

Industry representatives and consumer groups we spoke to said that 
compliance with voluntary standards developed through the consensus 
process is generally considered to be high, although they do not track 
compliance. Some representatives and consumer groups said that it can 
reach 90 percent for some standards. However, consumer product safety 
experts suggested that standards for some products have lower 
compliance, especially commonly low-priced items, products primarily 
sold over the Internet or by nonconventional retailers, products made 
by a large number of manufacturers, or products primarily manufactured 
overseas. For instance, cigarette lighters manufactured overseas and 
sold at low prices in the United States have been found to be 
noncompliant with voluntary standards. 

Standards Developed through a Consensus Process with Open 
Participation Generally Gain High Compliance: 

Consumer product safety experts we spoke to generally said that 
industry prefers voluntary to mandatory standards. They noted the 
voluntary standard development process is faster than mandatory 
rulemaking, and allows the industry a greater level of input. 
According to CPSC, the time required for mandatory rulemaking varies 
depending on the complexity of the product or of the rule 
requirements, the severity of the hazard, and other agency priorities, 
among other factors.[Footnote 13] For example, a legal expert told us 
that a mandatory rulemaking for cigarette lighters took 10 years from 
the decision to take action to final rule. CPSC also has been 
considering a mandatory rule to address the risk of fire associated 
with ignitions of upholstered furniture since 1972. Generally, the 
flexible process for developing voluntary standards is considered to 
facilitate revisions to the standards. Working through SDOs, 
interested parties have been able to revise existing standards to 
respond in a timely manner to emerging hazards or risks. According to 
two legal experts, a disadvantage of mandatory standards is that 
revision or repeal can be difficult. One expert also told us that 
because mandatory standards set fixed requirements for product safety, 
the rules can stifle product development and innovation. 

Industry participants told us that advantages of the voluntary 
standards process include open participation and proceedings by 
consensus, which can help ensure compliance with the resulting 
standards. Other industry representatives said that they also invest 
considerable time and resources in writing standards, which raises the 
likelihood of compliance. 

Factors that affect compliance for some manufacturers include 
discerning and accessing applicable standards. Some consumer product 
safety experts told us that some small businesses and foreign 
manufacturers are not aware of applicable standards for their 
products. CPSC has responded by extending greater outreach to these 
businesses through the agency's Office of Education, Global Outreach, 
and Small Business Ombudsman. The office coordinates with, and 
provides education and outreach activities to, various domestic and 
international stakeholders, including manufacturers, retailers, 
resellers, small businesses, and foreign governments. Among its 
responsibilities, the office works with foreign governments and 
regulatory bodies to help them increase their capacity to develop 
voluntary and mandatory product safety standards and plans to develop 
information and guidance tailored specifically to small batch 
manufacturers. Staff from this office plan to update the CPSC web page 
to assist small businesses in learning about their obligations under 
CPSIA, by informing them about voluntary standards, and encouraging 
them to comply. CPSC also plans to conduct two extended training 
exchanges with foreign partners, including developing country 
officials, to increase foreign regulatory agencies' understanding of 
CPSC procedures and policies and help ensure that CPSC safety 
standards are met for U.S.-bound exports. 

Some Retailers and Industry Associations Require Proof of Compliance 
with Voluntary Safety Standards to Sell Consumer Products: 

Although not legally mandated for voluntary standards, some retailers 
require a certification mark or other proof of compliance from 
manufacturers before they will agree to sell their product in stores. 
[Footnote 14] For instance, according to a legal expert, specialty 
retailers who sell gas fireplaces require proof of adherence to a new 
standard, which is being revised to address a safety hazard, for glass 
panels for the front of gas fireplaces. For many products, consumers 
and retailers expect that they meet a minimum safety standard, such as 
a voluntary standard. Some retailers conduct their own product safety 
programs, often certifying compliance with safety standards through 
testing at third-party labs, to better ensure the safety of products 
sold in their stores. 

In addition, some industry associations have programs to certify 
compliance with voluntary standards applicable to their members' 
products.[Footnote 15] Entities found not to be in compliance with 
applicable standards could lose the right to bear the association's 
certification mark. Industry associations that have certification 
programs include the furniture industry and children's products 
manufacturers. One furniture association provides hang tags to members 
who have paid to certify their conformance with the industry-developed 
standards, primarily addressing fire hazards. A group representing 
children's products manufacturers has implemented a lab testing and 
inspection process to certify members' compliance with applicable 
standards. Manufacturers contract with the industry group to receive 
certification that their products, such as cribs, strollers, and baby 
walkers, comply with standards. 

Certain Industries Prefer Mandatory Standards to Ensure a Level 
Playing Field and Preempt State Laws: 

Although industry representatives and legal experts we spoke to said 
that manufacturers largely prefer voluntary over mandatory standards, 
they also told us that certain industries have sought mandatory 
standards. Two reasons were cited for an industry's preference for 
mandatory standards: first, to level competition across an industry 
sector, especially where some manufacturers were not complying with 
the voluntary standard to which the rest of the industry agreed; and 
second, to preempt divergent state laws.[Footnote 16] The Lighter 
Association, a group representing cigarette lighter manufacturers, 
petitioned CPSC in 2001 to adopt the prevailing voluntary standard for 
lighters as a mandatory standard. The association cited widespread 
noncompliance with the voluntary standard, especially for lighters 
imported from China. Although CPSC has not as yet promulgated a 
general rule for mechanical requirements for cigarette lighter safety, 
it had adopted a regulation requiring child-resistant mechanisms for 
disposable lighters in 1994. A legal expert who has worked with the 
arts and creative materials industry told us that the industry sought 
to convert the industry's voluntary standard, developed with input 
from consumers and product users, to a mandatory standard to preempt 
differing laws in at least seven individual states. 

Risk of Potential Liability in Product Liability Lawsuits Helps Ensure 
Industry Compliance with Voluntary Safety Standards: 

Potential liability in product liability lawsuits for noncompliance 
with voluntary standards is another factor that affects compliance. 
Consumer product safety experts also told us that the risk of 
incurring reputational and financial costs associated with product 
liability lawsuits provides an incentive for manufacturers to comply 
with voluntary standards. Courts generally consider noncompliance with 
a voluntary standard as relevant evidence to establish a product 
defect or to prove a case of negligence. By the same token, if 
litigants can show compliance with applicable voluntary standards, the 
compliance may provide evidence of lack of a product defect or 
negligence. However, evidence of compliance usually is not sufficient 
on its own to negate liability.[Footnote 17] 

While CPSC Cannot Legally Require Compliance with Voluntary Standards, 
Industry Monitoring and Participation in Standards Development Help 
Encourage Compliance: 

CPSC cannot compel compliance with voluntary standards. However, 
according to CPSC officials, the agency has requested that U.S. 
Customs and Border Protection seize at the ports defective products 
that are subject to voluntary standards and that constitute a 
substantial product hazard. CPSC also participates in voluntary 
standard development activities, although their effectiveness is 
limited by constrained resources and a restrictive meetings policy. 
While consumer product safety experts value CPSC's input, they 
generally agree that earlier and more active participation could 
increase CPSC's efficiency and effectiveness in developing standards. 

Though Voluntary Standards Do Not Have the Force of Law, CPSC Is Using 
Expanded Legal Authority to Seize Defective Products: 

Since voluntary standards do not have the force of law, the Commission 
cannot compel compliance with them. Noncompliance with a voluntary 
standard, however, can inform a determination of a substantial product 
hazard by the CPSC. The CPSA defines a substantial product hazard as a 
failure to comply with an applicable consumer product safety rule, 
which creates a substantial risk of injury to the public; or a product 
defect, which (because of the pattern of defect, the number of 
defective products distributed in commerce, the severity of the risk, 
or otherwise) creates a substantial risk of injury to the public. 
[Footnote 18] If the CPSC finds that a product presents a substantial 
product hazard, it can lead to an enforcement action, such as a public 
notice or recall. Consequences for noncompliance with voluntary 
standards that amount to a substantial product hazard are discussed in 
the next section of this report. 

We found that CPSC does not routinely track broad product compliance 
with voluntary standards. Although they have internal guidance for 
monitoring compliance with voluntary standards, CPSC officials said 
that the agency has not conducted a formal program to test for product 
conformance with voluntary standards since 2002. The agency cited 
limited resources and competing priorities, including Congressional 
mandates and monitoring mandatory standards, as reasons for not doing 
so. According to CPSC officials, following the enactment of CPSIA in 
2008, the agency reallocated resources from voluntary standards 
activities towards meeting mandatory rulemaking deadlines required in 
the act. 

With the enactment of CPSIA in 2008, CPSC was granted expanded legal 
authority relative to certain voluntary standards under section 15(j) 
of the Consumer Product Safety Act to create a substantial product 
hazard list.[Footnote 19] It allows the Commission to issue a rule for 
any consumer product or class of products identifying certain 
characteristics whose presence or absence must be deemed a substantial 
product hazard. CPSC must determine that the characteristics are 
readily observable and that the hazard has been addressed by voluntary 
standards. CPSC must also determine that voluntary standards have been 
effective in reducing the risk of injury from the products and there 
is substantial compliance with the voluntary standards. When CPSC 
publishes a rule making such determinations, the products involved are 
subject to all of the enforcement consequences that apply to a 
substantial product hazard.[Footnote 20] Among other actions, the 
product must be refused admission into the United States. CPSC works 
cooperatively with Customs and Border Protection staff at ports of 
entry to detect and seize defective products. Agency officials stated 
that, to date, CPSC has twice exercised authority under section 15(j) 
to identify products containing substantial product hazards: 
children's upper outerwear containing drawstrings, because of risk of 
strangulation; and hand-supported hair dryers without integral 
immersion protection, due to risk of electric shock. 

We spoke with legal experts to discuss their views on the CPSC's 
expanded authority to declare substantial product hazards. Two legal 
experts told us that exercising the authority essentially converts a 
voluntary standard to a mandatory one without undergoing the 
established rulemaking procedures. According to one expert, the 
expanded authority gives the CPSC the ability to use the voluntary 
standards that were intended to address design and performance issues 
to create a mechanism for seizure of defective products at the ports, 
without putting the burden of proving a substantial product hazard on 
the CPSC. Another product safety expert also said that the expanded 
authority will not substantially enhance CPSC's enforcement capability 
because inspectors must have the ability to readily observe the hazard 
at the port of entry. Some hazards are not readily observable and 
require testing for compliance, such as lead content. CPSC told us 
that while the section 15(j) authority allows them to respond more 
quickly to substantial product hazards, not enough time has passed to 
assess the effect this authority will have on helping ensure 
compliance with voluntary standards. 

CPSC Participates in Standards Development Activities, but Its 
Effectiveness is Limited by Resource Constraints and a Restrictive 
Meetings Policy: 

CPSC staff participate in the voluntary standard development process 
by providing expert advice, technical assistance, and information 
based on data analyses of the numbers of and causes of deaths, 
injuries, or incidents associated with the product. According to CPSC, 
it supplies the standard-setting bodies with epidemiological and 
health science data, including extrapolated injury and death data from 
hospitals; death certificates associated with products causing the 
death where available; anecdotal data; and incident reports from 
SaferProducts.gov.[Footnote 21] CPSC officials said that support of 
voluntary standards development can be moderate or intensive. They 
told us that a moderate level of support would include reading the 
minutes of subcommittee meetings and monitoring the proceedings. More 
intensive support may consist of conducting and presenting CPSC 
research, performing lab tests, and writing draft language for the 
standard. 

CPSC officials told us that in developing voluntary standards, CPSC 
interacts primarily with ASTM International for children, juvenile, 
toddler, and infant products; ANSI for products such as bicycles and 
garage door operators; and UL for electrical products. CPSC staff told 
us they have a representative who serves as a nonvoting member on the 
board at ANSI and on ANSI's accrediting council.[Footnote 22] 
According to ANSI representatives, CPSC staff participate in 
discussions related to accrediting and maintaining procedures for 
international standards. Representatives from UL told us that CPSC 
staff participate in UL's Consumer Advisory Council, which convenes at 
least once a year to discuss products and standards. 

According to CPSC officials, the agency has recommended 31 products 
for SDO standards review, development, or revision for fiscal years 
2007 through 2011. In fiscal year 2011, CPSC staff report that they 
provided technical support and contributed to the completion of work 
on 37 new, revised, or reaffirmed voluntary standards, while they 
provided technical support or monitored the development of 60 
voluntary safety standards. These standards addressed hazards 
associated with cradles and bassinets, children's play yards, portable 
generators, and garage door openers, among other products. According 
to CPSC's Operating Plan, the agency plans to monitor 68 voluntary 
standards in fiscal year 2012, including standards addressing tip-over 
hazards of kitchen ranges, cadmium levels in children's jewelry, 
strangulation risk posed by window blind cords, and sulfur emissions 
in drywall (see table 1). 

Table 1: Voluntary Standards and Code Revisions Supported by CPSC 
Staff for Fiscal Years 2007 through 2012: 

Number of standards/code revisions supported: 
2007: 66; 
2008: 74; 
2009: 39; 
2010: 61; 
2011: 60; 
2012 (planned): 68. 

Number of CPSC voluntary standard project managers[A]: 
2007: 26; 
2008: 25; 
2009: 22; 
2010: 30; 
2011: 29; 
2012 (planned): 24-27. 

Source: CPSC. 

[A] CPSC officials told us that employees may be involved with more 
than one voluntary standard and their level of involvement can vary 
significantly. The numbers reflect those employees who are project 
managers/contacts. They may be supported by other CPSC technical staff 
in specific areas such as engineering sciences, human factors, health 
sciences, and laboratory sciences. 

[End of table] 

CPSC officials told us that voluntary standards monitoring activity 
decreased substantially after the enactment of CPSIA because of 
reallocation of resources to meet the act's requirements. The number 
of standards selected for monitoring was at a 5-year low in fiscal 
year 2009; however, the number of voluntary standards selected for 
monitoring has increased in the past 3 fiscal years and is expected to 
continue at current levels in the near future. CPSC officials said 
that staff recommendations based on criteria, such as death and injury 
data, available resources, and exposure of vulnerable populations to 
hazards, guide the selection of standards to monitor. They told us 
that staff consider where participation in voluntary standard setting 
could help reduce unreasonable risk of injury posed by a product. 
Management considers and approves or rejects the staff recommendations 
based on Commission priorities and available resources. Staff approved 
recommendations are then sent to the Commission for final approval. 
According to CPSC's Operating Plan and Performance Budget, the agency 
plans one recommendation to voluntary standards or revisions to code 
organizations for fiscal year 2012. The Operating Plan also includes 
plans for two new data analysis or technical review activities on 
carbon monoxide alarms and enhanced smoke alarms. Additionally, 10 
activities related to nanotechnology in consumer products are planned 
for fiscal year 2012.[Footnote 23] These activities will identify the 
potential release of nanoparticles from selected consumer products and 
determine the potential health effects from such exposure, which may 
lead to CPSC participation in voluntary standards development, 
according to CPSC officials.[Footnote 24] 

CPSC officials said that the level of support provided by CPSC to 
standards development and monitoring is dependent on available 
resources. One CPSC staff member is assigned to each standard as a 
project manager responsible for monitoring committee activity and 
draft revisions. According to CPSC officials, the 68 standards to be 
monitored in fiscal year 2012 represent the limit the agency can 
handle given current resource and staff levels. For example, about 25 
staff are responsible for monitoring the activities related to these 
standards. Sixty-eight standards is a small fraction of standards 
developed for consumer products. For instance, ASTM International has 
developed more than 12,000 standards while UL maintained more than 
1,400 as of 2011. These standards cover many types of products, not 
exclusively consumer products. 

CPSC's relationship with SDOs is outlined in CPSC regulations. 
[Footnote 25] CPSC policy sets criteria for deciding on CPSC's 
involvement in voluntary standards activities. The criteria include: 

* the likelihood the voluntary standard will eliminate or adequately 
reduce the risk of injury addressed, 

* the likelihood that there will be substantial and timely compliance 
with the voluntary standard, 

* the likelihood that the voluntary standard will be developed within 
a reasonable period of time, 

* openness to all interested parties, 

* establishment of procedures to provide for meaningful participation 
in the development of standards by representatives of a variety of 
interested parties, and: 

* due process procedures. 

CPSC's regulation guides the extent and form of CPSC staff involvement 
in voluntary standards organizations. Staff may attend standards 
development meetings, take an active part in the discussions, and 
provide data and explanatory material, but CPSC's regulation prohibits 
staff from voting on the standards or from holding leadership 
positions in standards development committees. Except in extraordinary 
circumstances and with the approval of the Executive Director, they 
cannot become involved in standards development meetings that are not 
open to the public (including members of the media) for attendance and 
observation.[Footnote 26] This may include technical subcommittees 
largely comprised of industry representatives. The regulation also 
states that active involvement in standards development activity must 
not be done in a manner that might present an appearance of 
preferential treatment for one organization or group or put CPSC's 
impartiality at risk. 

CPSC has authority to revise its regulations pertaining to voluntary 
standards activities. The first regulation concerning involvement in 
standards development was issued in 1978, and revised in 1989 and 
again in 2006. According to CPSC, its regulation is similar to the 
Office of Management and Budget's (OMB) Circular No. A-119 (Revised), 
which provides guidance for agencies participating in voluntary 
consensus standards bodies.[Footnote 27] However, in our review of 
CPSC's regulation, we found the agency interpreted its level of 
participation more strictly than OMB guidance for such activities as 
voting on standards and taking leadership positions. CPSC's rationale 
for limiting involvement in standards development activity, as 
described in its regulation, is to maintain its independence--such as 
not appearing to endorse a specific standard. OMB guidance states that 
agency representatives should participate actively and on an equal 
basis with other members, including full involvement in discussions, 
technical debates, registering of opinions, and if selected, serving 
in leadership positions. According to OMB guidance, agency 
representatives may vote at each stage of the standards development 
process unless prohibited by law or their agencies. A January White 
House memorandum further outlines principles for federal government 
engagement in standards activities, especially where statute, 
regulation, or administration policy identifies a national priority. 
Specifically, it states that the federal government may need to be 
actively engaged or play a convening role to accelerate standards 
development in standard setting and implementation, including 
supporting leadership positions for federal agency staff in SDO 
committees. 

Consumer Product Safety Experts Value CPSC's Input, but Also Called 
For Earlier and More Active CPSC Participation: 

CPSC, consumer groups, and industry officials with whom we spoke 
generally viewed CPSC's participation in voluntary standards 
development activities favorably. Consumer groups and other consumer 
product safety experts told us that CPSIA has strengthened CPSC's 
authority, effectiveness, and level of influence at SDOs. They also 
told us that the industry now knows that if they do not develop an 
adequate voluntary standard, CPSC will make a mandatory standard for 
those products specified by CPSIA. According to consumer 
representatives who have participated in the process, the dynamic has 
changed: prior to CPSIA, CPSC's input was ignored or voted down. With 
their new authority, CPSC is more active and their input is 
incorporated a great deal more, resulting in stronger and more 
protective outcomes, especially for durable goods for infants. 
Consumer group representatives also told us that CPSC's involvement in 
standards development has been effective for helping ensure consumer 
participation, especially since the passage of CPSIA. In one instance, 
a consumer group had concerns about the standards development process 
for window blind cords because of what it thought was a lack of 
transparency, limited access to information, and lack of consideration 
of its views, after they were excluded from participating in a 
technical subcommittee. CPSC appealed directly to industry groups to 
open the process, and consumer groups eventually were allowed to 
participate in the window blinds standard development. 

CPSC officials told us that staff's effectiveness in standards 
development partially depends on their own persuasiveness and the 
direction given from top management. Management recommends and 
approves staff to participate in standards development activity based 
on their ability to listen, negotiation skills, analytical 
proficiency, and level of technical and scientific expertise. Staff 
also receive training from the Voluntary Standards Coordinator to 
prepare for SDO meetings. According to CPSC officials, staff selected 
to participate in standards development activities may seek further 
advice and training from the Voluntary Standards Coordinator and other 
colleagues as needed. 

While consumer product safety experts we spoke to said that CPSC has 
good working relationships with the SDOs, some added that the agency 
could take a more active role in standards development activities. 
Voluntary standard committee participants told us that they value 
CPSC's contributions during standards development, one group 
especially valued its incident data and analysis, and another 
appreciated the agency's ability to help ensure an inclusive process. 
One industry official told us that they work collaboratively with 
CPSC; for example, they receive data from the CPSC in the process of 
developing voluntary standards for particular products. In one case, 
CPSC had identified, through its incident data, a laceration hazard 
resulting from a certain design of high chair with two hooks on the 
back. CPSC communicated this information to industry representatives, 
and it was incorporated into the voluntary standard process for the 
product. Another industry stakeholder told us that CPSC is viewed as a 
valuable partner in stronger standard development. By simply being 
present at voluntary standards development meetings, CPSC shows the 
industry that it is monitoring their activities. 

Other consumer product safety experts said that CPSC's participation 
in committees could be more active and its position on the draft 
standards better articulated. Because of limitations stemming from 
CPSC's regulation governing staff participation in standards 
development activity, the resulting standard may not fully reflect the 
CPSC staff input and the standard development process can be delayed. 
According to some consumer product safety experts, CPSC staff are 
restrained and act largely as observers at standard development 
committee meetings. Others said that, at times, CPSC staff does not 
challenge the adequacy of the standards. For example, although CPSC 
converted the voluntary standard for all-terrain vehicles to a 
mandatory standard in 2009, as required by CPSIA, in the view of some 
experts, all-terrain vehicles remain covered by a weak standard. In 
public statements regarding the all-terrain vehicle standard, one CPSC 
commissioner said that the recent update to the standard, while not 
diminishing the safety of the product, remains a low threshold for 
federal safety standards. Our analysis of CPSC public recall notices 
showed that there have been 36 recalls of all-terrain vehicles 
involving 15 companies for fiscal years 2007 through 2011.[Footnote 
28] Manufacturers have recalled all-terrain vehicles for reasons such 
as a risk of a crash caused by pieces of the main suspension breaking 
off and a risk of loss of vehicle control due to faulty speed 
controls. Recall notices do not indicate if the hazards posed by the 
product are covered by voluntary or mandatory standards. In 
discussions with consumer product safety experts, they said that if 
CPSC challenged the adequacy of the standards more frequently this 
would send a signal to industry that the agency was committed to 
obtaining a high level of safety in voluntary standards. 

Some industry representatives emphasized that they wanted CPSC's more 
active and earlier participation in standards development. They said 
that they would benefit from more information about CPSC's views on 
specific provisions of a standard, such as certain performance 
requirements, level of risk tolerance, or aspects of a product CPSC 
wanted changed. Some industry representatives said that if the 
agency's position on a standard were more apparent from the outset, 
the process would be faster and more efficient, which could result in 
stronger standards. One industry representative also noted that more 
active and earlier participation would allow CPSC to consider 
unforeseen business consequences of their proposed revisions to 
standards earlier in the process. For instance, according to this 
industry representative a revised standard for child bed rails was 
delayed by CPSC proposing costly revisions after the standard had 
already been approved by SDO participants.[Footnote 29] 

CPSC Can Impose Corrective Actions When Noncompliance with Voluntary 
Standards Presents a Substantial Product Hazard: 

Manufacturers can face consequences ranging from civil monetary 
penalties to the reputational and financial losses associated with 
corrective action if their products fail to comply with voluntary 
standards and if they present a substantial product hazard. Corrective 
actions include recalls, which encompass refunds, replacements, or 
repairs. CPSC may also sue to prevent distribution or sale of a 
product pending completion of a recall proceeding. Although voluntary 
standards do not have the force of law, manufacturers are legally 
required to report substantial product hazards to CPSC.[Footnote 30] 
Every manufacturer of a consumer product must inform the Commission if 
they obtain information that reasonably supports the conclusion that 
the product contains a defect that could create a substantial product 
hazard.[Footnote 31] Such a report may include information the 
manufacturer obtained about a product outside the United States if it 
is relevant to products sold or distributed in the United States. 
[Footnote 32] Manufacturers that knowingly fail to report potential 
substantial product hazards could be subject to civil or criminal 
penalties. In 2011, CPSC negotiated out-of-court settlements in which 
five companies agreed to pay $3.26 million in civil penalties related 
to their failure to report substantial product hazards to the agency. 

Although failure to meet a voluntary standard alone is not sufficient 
for CPSC to take action against a company--because voluntary standards 
are not enforceable by law--CPSC's analysis of the evidence of 
noncompliance and determination that the product could pose a 
substantial product hazard can lead to corrective action. According to 
CPSC's interpretive regulations, compliance or noncompliance with 
applicable voluntary standards may be a factor in determining whether 
a substantial product hazard exists.[Footnote 33] To determine if 
corrective action is needed, CPSC staff review incident reports on a 
daily basis and forward them to appropriate integrated teams for 
extensive analysis. CPSC integrated teams comprise subject matter 
experts such as engineers, human factors experts, health scientists, 
statisticians from the Office of Hazard Identification and Reduction, 
and compliance officers from the Office of Compliance. The teams then 
assess the reports for hazard type, whether the incident affected 
vulnerable populations, and the severity of injury. CPSC also collects 
data on injuries and deaths for products under its jurisdiction, and 
staff conduct investigations on specific injury cases to gain better 
knowledge of how the product was involved. Based on analysis of these 
data, the integrated teams decide if further action would be 
warranted, such as additional monitoring of the situation, an in-depth 
investigation, or a product safety assessment. In our discussions with 
CPSC officials, they told us that the agency decides on further 
actions based on other agency priorities, resources, and the level of 
risk that a product poses. Once CPSC has identified a hazardous 
product, the agency will take action to remove the product from the 
market. If a recall is necessary, CPSC staff negotiates with the 
responsible company to seek a voluntary recall, if appropriate. 

Manufacturers that report product defects propose a remedy that must 
be deemed acceptable to CPSC staff. This often involves the product's 
recall, which consists of the purchase price refund, repair, or 
replacement of the product. CPSC considers whether the plan adequately 
addresses the risk of injury presented by the product. For example, if 
the manufacturer's proposed solution was to repair its product, CPSC 
engineers would test the repair to determine if it addressed the 
hazard adequately. Similarly, if the proposed solution was a refund, 
CPSC officials would evaluate the refund process to determine if it 
would cause undue burden to the consumer. CPSC takes steps to ensure 
that recalled products are not reintroduced in the market through 
second-hand stores by monitoring the internet and through market 
surveillance programs. Table 2 contains information about CPSC's 
recall activities for fiscal years 2007 through 2011 for products 
covered by mandatory standards and those that are unregulated. 

Table 2: CPSC Recalls of Regulated and Unregulated Products for Fiscal 
Years 2007 through 2011: 

Fiscal year: 2011; 
Number of recalls of regulated products: 30; 
Number of recalls of unregulated products: 383. 

Fiscal year: 2010; 
Number of recalls of regulated products: 60; 
Number of recalls of unregulated products: 416. 

Fiscal year: 2009; 
Number of recalls of regulated products: 46; 
Number of recalls of unregulated products: 452. 

Fiscal year: 2008; 
Number of recalls of regulated products: 169; 
Number of recalls of unregulated products: 449. 

Fiscal year: 2007; 
Number of recalls of regulated products: 92; 
Number of recalls of unregulated products: 385. 

Total[A]: 
Number of recalls of regulated products: 397; 
Number of recalls of unregulated products: 2,085. 

Source: CPSC. 

[A] These recalls were tabulated from CPSC data for regulated and 
unregulated products. Unregulated products may include those covered 
by voluntary standards. According to CPSC officials, recalls of 
unregulated products are not necessarily associated with violations of 
voluntary standards; on some occasions the recall could be associated 
with issues in manufacturing or assembly of the product. 

[End of table] 

In our review of CPSC documents, the agency focused much of its 
surveillance and compliance work on imported products. According to 
CPSC, approximately 80 percent of recalls from 2008 through 2011 have 
been of imported products. The agency's Office of Import Surveillance 
and Inspection has primary responsibility for product surveillance at 
ports of entry in cooperation with other appropriate federal agencies. 
U.S. Customs and Border Protection notifies CPSC and other regulatory 
agencies with import safety responsibilities of the arrival of 
imported products and provides information about those products. CPSC 
identifies potentially unsafe products and requests that U.S. Customs 
and Border Protection set them aside for CPSC examination. Once 
samples are delivered to or taken by CPSC for examination, CPSC may 
detain the shipment pending further examination and testing, 
conditionally release the shipment to the importer's premises pending 
examination and testing, or release the shipment to the importer 
outright. Compliance investigators examine the sample to determine 
whether it (1) complies with the relevant mandatory standard or 
standards; (2) is accompanied by a certification of compliance with 
relevant product safety standard that is supported by testing, in some 
cases by a third party, (3) is or has been determined to be an 
imminently hazardous product; (4) has a product defect that presents a 
substantial product hazard; or (5) is produced by a manufacturer who 
failed to comply with CPSC inspection and recordkeeping requirements. 
[Footnote 34] According to a CPSC notice, from October 1, 2011, to 
December 1, 2011, officials identified about 240 noncompliant products 
at ports of entry, including defective hair dryers, lamps, and holiday 
lights. 

Table 3 illustrates standards activities and recall actions for 
selected products for fiscal years 2007 through 2011. Some products 
are covered by both mandatory and voluntary standards, which may 
address different aspects of the product features. For example, all-
terrain vehicles, cribs, infant bath seats, infant walkers, and 
cigarette lighters are subject to both mandatory and voluntary 
standards. 

Table 3: CPSC Standards Activities and Recall Actions for Selected 
Products for Fiscal Years 2007 through 2011: 

Product: All-terrain vehicles; 
CPSC standards activities as of 2011[A]: Mandatory standard, amended 
November 2008; effective date: April 2009; 
Voluntary standard last revised December 2010; 
CPSC is completing rulemaking, per P.L. 112-28, and will monitor 
product through planned field enforcement programs; 
Corrective actions, 2007-2011: 36 recalls involving 15 companies. 

Product: Candles; 
CPSC standards activities as of 2011[A]: Six ASTM International 
voluntary standards relating to candles and candle products. Last 
revision for three standards, 2009; last revision for two standards, 
2007; last revision for one standard, 2005; CPSC continues to work 
with ASTM International in developing standards for candle products; 
Corrective actions, 2007-2011: 45 recalls involving 35 companies. 

Product: Cribs; 
CPSC standards activities as of 2011[A]: Mandatory standards, December 
2010 (last update); effective date June 28, 2011; 
Voluntary standards last revised 2011; CPSC issued final rules 
regarding crib standards and will continue to monitor this product 
area; 
Corrective actions, 2007-2011: 56 recalls involving 37 companies. 

Product: Extension cords (power cords); 
CPSC standards activities as of 2011[A]: Voluntary standard related to 
cord sets and flexible cords and cables, October 2008; 
Corrective actions, 2007-2011: 5 recalls involving 5 companies. 

Product: Infant bath seats; 
CPSC standards activities as of 2011[A]: Mandatory standard, 2010 
(last update); Voluntary standard last revised 2011; CPSC issued final 
rule in 2010 and will continue to monitor this product through planned 
field enforcement programs; 
Corrective actions, 2007-2011: No corrective actions[B]. 

Product: Infant walkers; 
CPSC standards activities as of 2011[A]: Mandatory standard, 2010; 
Voluntary standard, last revised June 2011; CPSC issued final rule in 
2010 and will continue to monitor this product through planned field 
enforcement programs; 
Corrective actions, 2007-2011: 3 recalls involving 3 companies. 

Product: Cigarette lighters; 
CPSC standards activities as of 2011[A]: Mandatory standard for child 
resistance, 1994; Advance Notice of Proposed Rulemaking for mechanical 
malfunction, 2008 (no decision on proceeding); Voluntary standard for 
mechanical malfunction, most recent edition of voluntary standard is 
2010; Utility lighters voluntary standard 2010; 
Corrective actions, 2007-2011: 3 recalls involving 3 companies. 

Product: Portable generators; 
CPSC standards activities as of 2011[A]: Advance Notice of Proposed 
Rulemaking, 2006; Voluntary standard, last revised 2011; CPSC is 
conducting technical work related to carbon monoxide emissions from 
portable generators; 
Corrective actions, 2007-2011: 5 recalls involving 5 companies[C]. 

Product: Space/electric heaters; 
CPSC standards activities as of 2011[A]: Voluntary standard, July 2007; 
CPSC staff is participating in voluntary standard activities for 
portable and fixed-position electric heaters under UL Standards 
Technical Panel 1042 to address fires associated with electric heaters; 
Corrective actions, 2007-2011: 13 recalls involving 11 companies. 

Product: Window blinds; 
CPSC standards activities as of 2011[A]: Voluntary standard, March 
2009; CPSC is participating in voluntary standard activities to 
address strangulation hazards associated with cords on window covering 
products manufactured under the existing standards; 
Corrective actions, 2007-2011: 41 recalls involving 38 companies. 

Source: GAO analysis of data from SaferProducts.gov. 

Note: Some of these recalls included items sold at discount stores, 
retail liquidators, or dollar stores, but often this information may 
not be known unless that specific store initiates the recall. 

[A] CPSC continues to participate in standards activities for these 
products. Through April 2012, there have been updates to standards for 
some of these products. 

[B] CPSC issued a Safety Alert involving one company. 

[C] There are no recalls involving generators and a carbon monoxide 
hazard, which is the focus of current CPSC standards work. 

[End of table] 

CPSC Databases Do Not Identify Products with Voluntary Standards, but 
the Agency Collects Data That Could Help Identify Patterns of 
Noncompliance: 

CPSC has no tracking mechanism specific to voluntary standards in its 
compliance database, but the agency can identify patterns of 
noncompliance and address safety hazards. CPSC tracks reports of 
noncompliance with mandatory standards and identifies potential 
product hazards. CPSC has two internal databases for tracking 
noncompliance one for regulated products (products subject to 
mandatory standards) and the other for products that could pose a 
substantial product hazard (either unregulated products or products 
subject to voluntary standards).[Footnote 35] In discussions with CPSC 
officials, they told us that there is no field in the databases to 
indicate whether a product is covered by one of the thousands of 
existing voluntary standards. However, they noted that they have 
internal policies for tracking compliance with voluntary standards. 
According to agency officials, CPSC's policy states that when staff 
has determined that noncompliance with voluntary standards amounting 
to a substantial product hazard has occurred, staff should create a 
file with a case number to track this issue. The case number is an 
internal tracking number that does not correspond to the unique 
identifier assigned by SDOs and cannot be linked to a voluntary 
standard.[Footnote 36] However, agency officials said that if CPSC 
finds that the product poses a substantial product hazard and staff 
determine that the voluntary standard is inadequate or that no 
standard exists, they refer the case to the voluntary standards 
coordinator to address through standard setting activities. 

CPSC's compliance databases for both the regulated products and 
substantial hazard (section 15) products are case management systems. 
According to CPSC officials, more than 50,000 distinct firm names are 
in the databases. CPSC can classify incidents by manufacturer, 
retailer, distributer, and country of origin. In some cases a foreign 
company may have a U.S. agent or representative, making it difficult 
for CPSC's database to discern whether the reporting company is 
foreign or domestic. In addition, CPSC assigns more than 800 different 
product and product category codes to help track case files. CPSC's 
case files track information about the firm, the product, the type of 
noncompliance, and other relevant information. The agency also tracks 
correspondence with the manufacturer, distributor, retailers, and 
public about the case, as well as the corrective action implemented to 
address the noncompliance. 

Agency officials said that the databases have the capacity to track 26 
hazards in 8 hazard categories, including fire hazards for fabrics, 
materials, and electric appliances; mechanical hazards in children's, 
household, and sports and recreation products (involving choking, 
strangulation, and other injury hazards); electrocution; and chemical 
hazards. Staff use data from the compliance databases to identify 
types of product defects such as those associated with design, 
construction, and packaging of a product, or absence of warning labels 
or instructions. They also track the number of defective products in 
the market and assess the severity of risk of defects and likelihood 
of injury. 

In addition to tracking trends from compliance data, agency staff, 
including the Hazard Analysis Division, perform a range of statistical 
analyses across reported incident data to identify patterns of 
noncompliance. CPSC staff said they analyze compliance in terms of the 
product rather than the manufacturer. Incident data comes from various 
sources, including retailers; manufacturers; public safety 
professionals; health care professionals; death certificates; news 
reports; state and local governments; and incident reports submitted 
by consumers through CPSC's website, SaferProducts.gov. CPSC staff 
identify potential emerging patterns, produce estimates of injuries 
and quantify the frequency of fatalities based on emergency room data, 
test for injury trends over time, and characterize hazard patterns. 
Analysts evaluate these data on a daily basis and report increased 
frequency of reports for a given product or manufacturer to 
appropriate teams in the agency. Officials said that on a weekly 
basis, analysts apply algorithms across reports to characterize the 
frequency by product code. They generate statistics comparing the 
number of reports received in the week for particular products to the 
number received for the same product over a 20-week period. CPSC 
officials then use the data to determine which incidents should be 
investigated and report on their findings to internal teams. For 
example CPSC has identified instances of appliance tipovers and issued 
press releases with information to consumers to raise awareness of 
tipover hazards. To address this, the agency plans to participate in 
standard revision activity to address kitchen range tipovers. 

In a previous report we addressed CPSC work resulting from 
identification of certain hazard patterns. We reported that during the 
1980s, the data CPSC collected on injuries and fatalities related to 
all-terrain vehicles, especially among children, led it to file a 
lawsuit alleging that the vehicles were an imminently hazardous 
product. CPSC and manufacturers eventually settled the lawsuit through 
a consent decree in which manufacturers and distributors agreed to 
implement certain safety measures and stop selling certain vehicles 
considered dangerous for young children.[Footnote 37] In its fiscal 
year 2012 Operating Plan and Performance Budget, CPSC also noted that 
it plans to update safety publications addressing children's hazards, 
fire and electrical hazards, mechanical hazards, sports and 
recreational hazards, and chemical and combustion hazards. 

Conclusions: 

Voluntary standards establish safety guidelines for many of the 
thousands of consumer products in CPSC's jurisdiction. CPSC is 
required by law to rely on these standards, developed through 
consensus by industry, consumer, and government participants, when the 
standards are adequate to address the risk of harm and substantial 
compliance with them is likely. Because of the substantial prevalence 
of voluntary standards for consumer products, CPSC's early and active 
participation in standards development activity is critical to 
establishing adequacy of the standard. If CPSC finds that a 
manufacturer does not comply with a voluntary standard and it creates 
a substantial product hazard, the agency can seek a corrective action, 
such as a recall; however, CPSC does not have the authority to compel 
compliance with voluntary standards as such. For fiscal years 2008 
through 2011, 80 percent of recalls have been of imported products 
that may be subject to voluntary standards, highlighting challenges 
CPSC faces in helping to ensure the safety of consumer products. CPSC 
has taken steps to ensure compliance by (1) performing industry 
surveillance through analysis of incident and other data, (2) 
participating in standards development activities, and (3) monitoring 
selected voluntary standards. Although CPSC regularly participates in 
standard development activity to the extent possible, consumer product 
safety experts we spoke to generally agreed that earlier and more 
active CPSC participation could increase its efficiency and 
effectiveness in developing standards. Our review also found that CPSC 
regulations concerning meetings policies and allowable conduct for 
CPSC staff participating in standards development activity are 
generally more restrictive than the existing general government policy 
on such participation. While OMB guidance gives agencies discretion to 
determine their level of participation in standard setting activities, 
CPSC has chosen to limit participation to maintain impartiality and 
avoid appearance of endorsing a specific voluntary standard. Further, 
a recent White House memorandum on national standards policy states 
that where statute, regulation, or administration policy identifies a 
national priority, the federal government may need to be actively 
engaged or play a convening role to accelerate standards development 
and implementation. Changing regulations to enable staff to more 
actively participate, especially when working with technical 
committees for which CPSC has expertise and permitting CPSC staff to 
vote on the standard, could result in stronger voluntary standards 
without compromising CPSC's independence. Without more active 
participation from CPSC, standards emerging from standards development 
organizations risk being less stringent and may be inadequate to 
protect the public from hazards. 

Recommendation for Executive Action: 

To strengthen the adequacy of voluntary standards, we recommend that 
the Chairman of CPSC direct agency staff to review the policy for 
participating in voluntary standards development activities and 
determine the feasibility of assuming a more active, engaged role in 
developing voluntary standards. 

Agency Comments and Our Evaluation: 

We provided a draft of this report to CPSC for comment. In their 
written comments, reproduced in appendix II, CPSC supported our 
recommendation and wrote that staff would review agency policies and 
determine the feasibility of changes to the policies. CPSC staff also 
provided technical comments that were incorporated, as appropriate. 

We are sending copies of this report to interested congressional 
committees and the Chairman and commissioners of CPSC. In addition, 
the report will be available at no charge on GAO's website at 
[hyperlink http://www.gao.gov]. 

If you or your staff members have any questions about this report, 
please contact me at (202) 512-8678 or cackleya@gao.gov. Contact 
points for our Offices of Congressional Relations and Public Affairs 
may be found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix III. 

Signed by: 

Alicia Puente Cackley: 
Director, Financial Markets and Community Investment: 

[End of section] 

Appendix I: Scope and Methodology: 

To evaluate the extent to which manufacturers comply with voluntary 
standards for consumer products, we interviewed officials from the 
Consumer Product Safety Commission (CPSC) and national consumer, 
industry, standard-setting, and legal organizations that have 
expertise in working on voluntary standards development for consumer 
products. We reviewed internal CPSC operating procedures and learned 
about the agency's outreach programs to educate the public about 
safety standards. We reviewed statutory authorities and procedures for 
establishing voluntary standards. We interviewed the three standards 
development organizations that coordinate the development of more than 
90 percent of voluntary standards developed with CPSC staff technical 
support to learn about how standards and certification programs are 
developed. 

To evaluate CPSC's authority and ability to encourage compliance with 
voluntary standards, we reviewed CPSC's statutory and regulatory 
authority related to voluntary standards. We also reviewed CPSC 
standard operating procedures, performance and accountability reports, 
and budget documents to obtain information about CPSC's work plans 
with respect to voluntary standards. We met with cognizant CPSC 
officials, including all of CPSC's current commissioners and the 
Chairman, to discuss their authorities and ability to enforce them. We 
reviewed relevant laws, regulations, and our prior reports on CPSC's 
authorities. We interviewed legal experts in the consumer product 
safety field regarding CPSC's authorities. We conducted a literature 
search for information regarding CPSC's effectiveness in getting 
manufacturers to comply with voluntary standards. We attended a 
conference on the adequacy of voluntary standards sponsored by the 
Consumer Federation of America and a conference by the International 
Consumer Product Safety and Health Organization on trends in 
international consumer product safety. 

To evaluate the consequences for manufacturers that fail to comply 
with voluntary standards, we reviewed documents from CPSC officials 
and obtained and reviewed publicly available data on recalls and other 
corrective actions. We obtained and analyzed data collected by CPSC 
through SaferProducts.gov regarding product safety incident reports 
and corrective actions assigned to manufacturers whose products did 
not comply with voluntary standards. We assessed the reliability of 
these data by (1) reviewing existing information about the data and 
the system that produced them and (2) interviewing agency officials 
knowledgeable about the data and related management controls. We found 
the data to be reliable for the purposes of determining the number and 
trends of product safety incident reports and corrective actions. We 
interviewed CPSC officials, legal experts, and consumer and industry 
participants to learn of possible corrective actions that could be 
imposed on firms that fail to comply with voluntary standards. 
Further, we conducted a legal literature search for information about 
CPSC's authorities to determine consequences for manufacturers who 
fail to comply with voluntary standards. 

To evaluate CPSC's efforts to identify patterns of noncompliance with 
voluntary standards, we interviewed CPSC officials about their data 
collection methods and internal processes for analyzing incident data 
and tracking patterns. We obtained and reviewed data from CPSC's 
compliance databases to identify (1) the number of reported instances 
of noncompliance; (2) the number of times these instances led to a 
corrective action; (3) the numbers of corrective actions that 
resulted; (4) the number of product units recalled; and (5) the type 
of standard, if any, that covered the product. We assessed the 
reliability of these data by (1) reviewing existing information about 
the data and the system that produced them and (2) interviewing agency 
officials knowledgeable about the data and related management 
controls. Based on this assessment, we determined the data to be 
sufficiently reliable for the purposes of this report. 

We conducted this performance audit from January 2012 to May 2012 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Comments from the Consumer Product Safety Commission: 

U.S. Consumer Product Safety Commission: 
4330 East West Highway: 
Bethesda, MD 20814: 

CPSC Hotline: 1-800-638-CPSC (2772): 
CPSC's Web Site: [hyperlink, http://www.cpsc.gov] 

May 16, 2012: 

Ms. Alicia Puente Cackley: 
Director, Financial Markers and Community Investment: 
U.S. Government Accountability Office: 
411 G Street, NW: 
Washington, DC 20548: 

Dear Ms. Cackley: 

The U.S. Consumer Product Safety Commission (CPSC) appreciates the 
opportunity to review and provide comments on the draft U.S. Government
Accountability Office report "A More Active Role in Voluntary 
Standards Development Should Be Considered." 

The draft report provides a comprehensive review of the CPSC's 
voluntary standards program and we appreciate the breadth of the 
review. We support the recommendation that the CPSC Chairman "direct 
agency staff to review the policy for participating in voluntary 
standards development activities and determine the feasibility of 
assuming a more active, engaged role in developing voluntary 
standards." CPSC staff will review agency policies and determine the 
feasibility of changes to the policies, such as staff voting on 
standards and holding leadership positions on voluntary standards 
committees. 

Thank you again for providing us with the opportunity to comment on 
the draft report. 

Sincerely, 

Signed by: 

Inez M. Tenenbaum: 
Chairman: 

Signed by: 

Robert S. Adler:
Vice Chairman: 

Signed by: 

Nancy A. Nord: 
Commissioner:  

Signed by: 

Anne M. Northup
Commissioner: 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Alicia Puente Cackley, (202) 512-8678 or cackleya@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, Debra Johnson, Assistant 
Director; Nina E. Horowitz; DuEwa Kamara; Angela Messenger; Barbara 
Roesmann; Jessica Sandler; Andrew Stavisky; and Henry Wray made major 
contributions to this report. 

[End of section] 

Footnotes: 

[1] Pub. L. No. 110-314, 122 Stat. 3016 (2008). 

[2] Consumer Product Safety Amendments of 1981, Pub. L. No. 97-35, 
title XII-A, 95 Stat. 357, 703 (1981), amending 15 U.S.C. §§ 2056 and 
2058. 

[3] Consolidated Appropriations Act, 2012, Division C - Financial 
Services and General Government Appropriations Act, 2012, Title V, 
Pub. L. No. 112-74, § 504, 125 Stat. 786, 908 (2011). 

[4] The Consumer Product Safety Act established CPSC as an independent 
regulatory commission. The act provides for the appointment by the 
President of five commissioners for staggered 7-year terms. One of 
these commissioners is designated the Chairman, who directs all the 
executive and administrative functions of the agency. See generally 15 
U.S.C. § 2053. As of May 2012, CPSC was led by four commissioners. 

[5] Pub. L. No. 92-573, 86 Stat. 1207 (1972), codified, as amended, at 
15 U.S.C. §§ 2051-2089. In addition to enacting the CPSC's organic 
authorities, the Consumer Product Safety Act transferred to CPSC 
enforcement authority under four existing statutes: the Flammable 
Fabrics Act, 15 U.S.C. §§ 1191-1204, the Federal Hazardous Substances 
Act, 15 U.S.C. §§ 1261-1278, the Poison Prevention Packaging Act, 15 
U.S.C. §§ 1471-1477, and the Refrigerator Safety Act, 15 U.S.C. §§ 
1211-1214. CPSC has also subsequently been charged with administering 
other safety statutes such as the Virginia Graeme Baker Pool and Spa 
Safety Act, 15 U.S.C. §§ 8001-8008, and the Children's Gasoline Burn 
Prevention Act, 15 U.S.C. § 2056note. These statutes confer various 
regulatory and enforcement powers on CPSC with respect to the 
specialized areas that they cover, including in some cases authority 
to prescribe safety standards as well as labeling and packaging 
requirements. 

[6] CPSC officials said that certain products are covered by both 
mandatory and voluntary standards. In these cases, certain features of 
a product may be covered by a mandatory standard, while other features 
are subject to a voluntary standard. For example, safety features for 
bicycle brakes, frames, pedals, and tires are stipulated by a 
mandatory safety standard, while specifications for serial numbers to 
facilitate recalls and identification of stolen property fall under a 
voluntary standard. 

[7] 15 U.S.C. § 2056. 

[8] 15 U.S.C. § 2057. 

[9] 15 U.S.C. §§ 2056a, 2056b, and 2089. 

[10] According to CPSC, prior to the passage of CPSIA, the ratio of 
voluntary standards to mandatory standards was 10 to 1. 

[11] The Office of Compliance and Field Operations conducted formal 
voluntary standards compliance programs until 2002, when it 
transferred the function to CPSC's Office of Hazard Identification and 
Reduction. 

[12] See GAO, Consumer Safety: Better Information and Planning Would 
Strengthen CPSC's Oversight of Imported Products, [hyperlink, 
http://www.gao.gov/products/GAO-09-803] (Washington, D.C.: Aug. 14, 
2009). 

[13] Interested parties generally have 60 days to comment on an 
Advance Notice of Proposed Rulemaking (ANPR) and 75 days to comment on 
a Notice of Proposed Rulemaking. CPSIA contains some provisions 
designed to shorten the timeframe for rulemaking, such as making an 
ANPR optional, though it may be issued when the CPSC deems it a 
necessary part of rulemaking. 

[14] A certification mark is used on the goods and services to provide 
a visible guarantee that those goods and services meet standards set 
by the owner of the certification mark. UL, owner of one of the most 
commonly-seen certification marks, certifies that consumer products 
comply with safety standards. 

[15] Provisions of CPSIA impose certification requirements for 
imported products that are subject to mandatory safety rules under 
statutes enforced by CPSC as well as third-party lab testing for 
products subject to children's product safety rules. 15 U.S.C. § 2063. 

[16] Mandatory safety standards under the CPSA generally preempt state 
and local standards dealing with the same product risks unless they 
are identical to the federal requirements. See 15 U.S.C. § 2075. 

[17] Compliance or noncompliance with mandatory governmental standards 
likewise is relevant in product liability litigation and generally 
carries even greater weight than a voluntary standard. 

[18] 15 U.S.C. § 2064(a). Product safety rules for this purpose 
include mandatory safety standards and product bans under CPSA as well 
as similar standards and bans under other laws enforced by CPSC. 

[19] 15 U.S.C. § 2064(j), added by section 223(a) of the Consumer 
Product Safety Improvement Act of 2008, Public Law 110-314, 122 Stat. 
3068. 

[20] Section 15(j) provides that rules issued under that authority are 
subject to judicial review in the same manner as mandatory safety 
rules. Such rules may be affirmed only if CPSC's determinations are 
supported by substantial evidence. 15 U.S.C. § 2060(c). 

[21] SaferProducts.gov is a database maintained by CPSC. Through a web 
portal, consumers and others meeting statutory requirements may submit 
reports of harm or the risk of harm from products and can search for 
information on products reported to be unsafe that they own or may be 
considering for purchase. See 15 U.S.C. § 2055a. 

[22] ANSI's role in standards development differs from that of SDOs. 
ANSI serves as administrator and coordinator of the U.S. private 
sector, voluntary standardization system. ANSI also accredits U.S. 
standards developers using criteria based on international 
requirements. SDOs accredited by ANSI include ASTM International, UL, 
and the National Fire Protection Association. 

[23] Nanotechnology relies on the ability to design, manipulate, and 
manufacture materials at the nanoscale. Nanoscale refers to materials 
on the order of one billionth of a meter. 

[24] In the area of human health, scientists believe some 
characteristics of nanoscale particles could produce both positive and 
negative consequences. For example, nanoscale silver is highly 
effective as an antibacterial agent. However, some scientists believe 
that carbon nanotubes exhibit properties similar to asbestos fibers 
and may become lodged in organs harming humans and animals. 

[25] 16 C.F.R Part 1031. 

[26] UL and ASTM International told us that they maintain an ANSI-
accredited voluntary standards development process, which includes 
openness to any interested party. 

[27] Office of Management and Budget, Federal Participation in the 
Development and Use of Voluntary Consensus Standards and in Conformity 
Assessment Activities, Circular A-119 (revised). (Washington, DC: 
February 10, 1998.) 

[28] CPSIA has mandated the conversion of standards for all-terrain 
vehicles from voluntary to mandatory. 15 U.S.C. § 2089. 

[29] The standard was approved by SDO participants in October 2010. 
CPSC proposed changes in January 2011 to address a hazard. In April 
2011, a draft standard identical to CPSC recommendations received 
negative votes from other participants and discussions continued to 
address the disagreement. The standard that was finalized in February 
2012 reflected all points of view. 

[30] Manufacturers must also notify the Commission immediately if they 
obtain information which reasonably supports the conclusion that a 
product distributed in commerce (1) fails to comply with a voluntary 
standard upon which the Commission has relied under the CPSA, (2) 
fails to meet a consumer product safety standard or banning regulation 
under the CPSA or another law enforced by the Commission, or (3) 
creates an unreasonable risk of serious injury or death. 15 U.S.C. § 
2064(b). 

[31] 15 U.S.C. § 2064(b). 

[32] 16 C.F.R. § 1115.12(f). 

[33] 16 C.F.R. § 1115.6. 

[34] An imminently hazardous consumer product presents imminent and 
unreasonable risk of death, serious illness, or severe personal 
injury. 15 U.S.C § 2061(a). CPSC states that it has not used its 
authority to refuse admission of an imminently hazardous consumer 
product because it requires filing an action in U.S. District Court, 
which is a resource-intensive process. Instead, CPSC states that it 
works cooperatively with the manufacturer to remove the product from 
the market, which can include seizure and detention of products at the 
port by Customs and Border Protection, if necessary. 

[35] Section 15(a)(2) of the CPSA, 15 U.S.C. § 2064(a)(2) provides 
that a product not covered by a mandatory rule presents a substantial 
product hazard if it has a defect which, because of various factors, 
creates a substantial risk of injury to the public. 

[36] CPSIA directed CPSC to upgrade and improve its information 
technology systems. Pub. L. No. 110-314, § 212(b), 122 Stat. 3052. In 
its March 2012 Operating Plan and Performance Budget, CPSC indicated 
that it has been creating a single data source to help provide 
linkages across CPSC data systems. 

[37] GAO, All-terrain Vehicles: How They Are Used, Crashes, and Sales 
of Adult-Sized Vehicles for Children's Use, [hyperlink, 
http://www.gao.gov/products/GAO-10-418] (Washington, D.C.: Apr. 8, 
2010). 

[End of section] 

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