Recall Effectiveness ICPHSO Symposium 2010 Recall Effectiveness ICPHSO Symposium This presentation has not been reviewed or approved by the Commission and may not reflect its views

Voluntary Recalls by Fiscal Year 2 FY million FY million FY million FY million

Factors Affecting Correction Rates Product sale price Product sale price Average useful life and time in distribution Average useful life and time in distribution Level of consumer notification Level of consumer notification Nature and severity of hazard Nature and severity of hazard 3

PR Date UnitsSoldRate 8/15/ million 4/04-7/0652% 8/24/ million 10/03-7/0653% 9/28/06168,5002/05-9/0674% 10/23/069/05-10/0660% 10/23/069/04-10/0629% 10/23/066/05-10/0624% 10/23/0612/04-10/0616% 4/25/0727,0005/04-11/068% 4

Million Unit Recalls Studied 25 cases involving >1 million products Studied 25 cases involving >1 million products Finding: price and hazard type are both important but hazard type was more important Finding: price and hazard type are both important but hazard type was more important Best response rates involved fire hazards Best response rates involved fire hazards Expensive product and fire hazard = >20% Expensive product and fire hazard = >20% Reported injury rate declined after recall even when response rate was poor Reported injury rate declined after recall even when response rate was poor 5

Injury Rate Measures After a recall, it is quite common for consumers to report additional incidents occurring before the recall; it is relatively rare for consumers to report incidents occurring after the recall After a recall, it is quite common for consumers to report additional incidents occurring before the recall; it is relatively rare for consumers to report incidents occurring after the recall Goal of recalls is to reduce injuries Goal of recalls is to reduce injuries 6

Blair Robes April 2009 recalled 162,000 robes April 2009 recalled 162,000 robes By June 2009, learned of six deaths, all occurring before the recall; recall was re-announced By June 2009, learned of six deaths, all occurring before the recall; recall was re-announced By October 2009, learned of three more deaths, all occurring before the original recall; recall was re-announced and expanded to cover other chenille garments By October 2009, learned of three more deaths, all occurring before the original recall; recall was re-announced and expanded to cover other chenille garments 7

Product Registration Cards CPSIA section 104(d) Final rule published December 29, 2009 effective June 28, 2010 for twelve categories of durable nursery products named in CPSIA, December 29, 2010 for six additional categories of products recently identified Final rule published December 29, 2009 effective June 28, 2010 for twelve categories of durable nursery products named in CPSIA, December 29, 2010 for six additional categories of products recently identified For products made in the USA: the manufacturer is responsible for compliance For products made in the USA: the manufacturer is responsible for compliance For imported products: the importer is responsible for compliance For imported products: the importer is responsible for compliance 8

Internet Surveillance 9

Questions? John Gibson Mullan Director, Office of Compliance 10

Million Unit Recalls Studied 25 cases involving >1 million products Studied 25 cases involving >1 million products Only 3 had response rate >20% Only 3 had response rate >20% All had price >$200 and fire hazard All had price >$200 and fire hazard 1 more had response rate >10% 1 more had response rate >10% Fire hazard Fire hazard 4 more had response rate >5% 4 more had response rate >5% 3 were fire hazard; one was radial arm saw 3 were fire hazard; one was radial arm saw 1 fire hazard had poor response rate 1 fire hazard had poor response rate Battery charger for $25 drill Battery charger for $25 drill 11