February 25, 2005

CPSC Announces 'Working Model' for Section 15 Reporting

Arnold & Porter Advisory

Section 15(b) of the Consumer Product Safety Act (CPSA) requires manufacturers, importers and retailers to notify the U.S. Consumer Product Safety Commission (CPSC) "immediately" upon receiving information that "reasonably supports the conclusion" that a product (a) "contains a defect which could create a substantial product hazard," or (b) "creates an unreasonable risk of serious injury or death." Currently, companies are at risk of civil penalties of up to $1.8 million if CPSC questions decisions not to notify the agency of a potential safety issue (even if made in good faith) or the timing of such notification.


Eric A. Rubel
Eric A. Rubel
Senior Counsel
Washington, DC
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