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2018 North America Consumer Product Safety Summit – Part 2

2018 North America Consumer Product Safety Summit – Part 2

All right thanks everyone. I hope
everyone had a great lunch and are ready for the second half of our summit this
afternoon we are preparing to start for our third panel this afternoon which is
on high energy lithium-ion batteries the third panel is moderated by Katie
Greenwood director of risk assessment Bureau HC Ezzor is associated with high
injury high energy density batteries are common to all three jurisdictions this
panel will address how risks to consumers can be reduced and what steps
have already been taken by stakeholders in north america points of focus include
the industry’s product safety processes pre and post-market understanding and
eliminating failure modes and challenges in how stake
how can stakeholders and regulators work together to improve safety so our
panelists this afternoon are Charlie Monahan director regulatory compliance
Panasonic Don mais chief safety and quality officer from Samsung and Rick
Brenner president product safety Advisors LLC good afternoon
really privileged to be here this afternoon with my three distinguished
panelists I have to say it’s been absolutely fantastic organizing this
panel with these three and listening to them on the phone their wealth
experience on lithium-ion batteries I have learned a lot in the last several
weeks so I’m not going to take a lot of times in opening remarks but I think
their presentations are very interesting and I really want to get into them but
preventing harm is sort of the core of what we do as regulators and as industry
and working in the product safety area it’s the core of what we do and it’s the
heart of why we go to work every day as a regulator we find it incredibly
difficult to keep up with the changing landscape in product safety and more and
more of the products we’re regulating do have lithium-ion batteries in in them so
it’s becoming in tune with the changes in the
technology and making sure that we are aware of the product hazards associated
with these given the versatility of the lithium-ion batteries we’ve all seen the
videos on YouTube of products failing rather spectacularly and sometimes less
spectacularly as well these incidents come in to us as regulators and we then
have to assess the risks we test the products in our labs and we work with
industry to find solutions so how can we design safer products manufacturer safer
batteries and protect our consumers what is the role of standards in ensuring
battery safety so I’m really I’m gonna turn it over quite quickly to the first
panelist Charles Monahan as you know director of regulatory compliance at
Panasonic who’s well-known in the industry for his knowledge and
investment in battery safety and sustainability so Charlie okay good
afternoon everybody I’ve been asked to put together a little not knowing what
everybody’s our background is when regard to batteries I’ve been asked to
put together a little bit of battery 101 so please put up with me for the first
few minutes a single cell is a single cell of the building block for battery
packs every single cell has an anode a cathode a separator and and other
components hopefully safety components single cells are put together into
battery packs this here is a cordless tool pack and you’ll see that there’s
five cells so when you see your pad or your notebook or your phone each of them
inside these battery packs are made up of individual cells when you wire cells
together in series you increase the voltage when you wire them together in
parallel you increase the capacity and battery packs usually have cells in both
series and parallel to make the voltage you need and the capacitor
you need also hopefully your battery pack also has a battery management unit
the battery management unit is that intelligence on the circuit board that
controls overcharge over discharge counts cycles things like that it’s a
ways to help with the safety of the battery pack you have cylindrical
batteries where it’s wound material you’ve got prismatic where you basically
take a wound cell and you flatten it into a prismatic shape and then the less
when you have polymer cells and a polymer cell is not built in a round
format it’s built like a deck of cards you put anode cathode separator an old
cathode separator and you wire them together and they can come in absolutely
any shape and all of the new plot a lot of the new consumer products that are
super super thin are the polymer cells any battery is no stronger than its
weakest cell and no cell is stronger than its weakest component it’s very
important that when you build cells that the battery the cell manufacturers build
out of the top rate components and also build them extremely well I’ll touch of
that later on everybody talks about lithium-ion
there’s actually six different types of lithium-ion chemistry’s you’ve got the
lithium nickel cobalt aluminum this is the one found like in the Tesla you’ve
got a lithium cobalt oxide this is the original battery that Sony produced back
in 1990 it’s now like in the Apple iPhone and stuff you’ve got a little
with iam nickel manganese cobalt oxide and then you’ve got iron phosphate
lithium manganese oxide and then lithium titanate and again each of these have a
different they’re all called lithium ion batteries but they have different anode
different cathode materials and and they’re banned in a battery pack you
can’t mix them or you shouldn’t mix them together from
a safety point of view and one of the just a fact the 18 650 which a lot of
people have heard the name of is 18 millimeters wide 65 long this particular
cell comes in all six chemistry’s why is the lithium ion battery different from
past rechargeable batteries all of the batteries in the past the lead acid the
NiCad the nickel metal hydride the three rechargeable chemistry’s before
lithium-ion were all aqueous base they were all water based electrolyte the
lithium ion is the first rechargeable battery that is flammable these solvents
inside the electrolyte is flammable on top of that the energy density both
from a volumetric and weight basis is much higher than past chemistry’s so
again we have a lot of energy in a very small area mixed with a flammable
electrolyte and that’s basically you know you know in a nutshell what is
differently you know lithium ion than all the other rechargeables that came
before okay I have to thank Bosch this is probably the simplest picture I could
find on the web for how a battery works again every battery has a cathode
everybody every battery has an anode and every battery has a separator the
cathodes are made of some type of lithium metal oxide and and again it
varies six different ways most of the anodes or graphite carbon some type of
carbon graphite some of the companies are also now mixing in small amounts of
silicon but again there’s problems with that it’s a great material if we can get
it to work but silicon swells up during the cycling and so at this point we’re
working out technically how to get more and more of it mixed in into the anode
the separator is the material which separates the anode and the cathode
separators are now down to about 20 microns in thickness give you an idea a
human hair is between 17 and 180 microns so it’s a very very thin material this
is the material that allows ions to pass between the anode and the cathode in
addition every battery has a current collectors you have a a cathode current
collector which is made of copper foil and you have an an anode copper
collector which is made of aluminum these current collectors are about 1.5
microns and thickness these are extremely thin in a in a first-tier
high-end lithium-ion battery how do batteries work during the charge the
lithium ions move from the cathode which is the positive electrode to the anode
where they are stored this is where they attract an electrons because of their
charge they receive the they receive these from an external power source plug
it in the wall and that you know that power came from someplace wind solar
cold someplace and that’s how the battery is
charged during discharge the electrons migrate back toward the anode from the
anode to the cathode during this migration this is where we force the
electrons to go through the product that is powering this is where the energy
comes from during the discharge site again what the difference between
primary batteries and rechargeable batteries is that the chemical process
of charging and discharging can be repeated in a rechargeable battery in a
primary battery it’s a metal reduction reaction and once it’s done it’s done it
can’t be reversed rechargeable batteries it can be reversed again this is showing a typical
cylindrical battery again it’s got a cathode
it’s got an anode it’s got a separator and has got a collection collector plate
in there both on the anode and the cathode also a will build cell at least
from Panasonic’s point of view well build cells and you know companies like
Panasonic sanyo Samsung LG etc we also put safety devices in each one of our
cells we put in PTC’s these are positive temperature coefficient thermistors this
is a device that raises resistance in some when resistance increases due to
temperature it goes up to a whatever set level that we set as a specification
once the resistant gets high enough to a point it will start reducing the current
when it gets to whatever size would add at whatever level we specify for that
particular cell it will totally cut off the current for that cell this is a
one-time device once it trips and it doesn’t get reset another thing that
first tier manufacturers do in every cell is we put in C IDs or current
interrupted devices these are bi-metal devices that deform in such a way that
will cut off current if it gets above if the gas pressure built up inside the
cell from the high current gets above a certain level and again this is this
this is not mandated you know when you build cells but the first tier
manufacturers wouldn’t put a cell into the marketplace we don’t think we should
without a PTC and a CID at the cell level and obviously not everybody does
this thermal runaway this is what a lot of people hear here the third term
thermal runaway is when the internal cell reaction generates more heat than
the cell can dissipate this is just a definition from the I Triple E 16 and
1725 cells should only fail if they are either abused or poorly main poorly
manufactured the fact is there’s many ways to either abuse a cell or poorly
manufacture or sell some examples of abuse external heating external heating
can damage either the separator or the cathode overcharge can result in lithium
plating inside the cell lithium plating will cause dendrites that could Pierce
the separator also overcharge can result in electrolyte decomposition that would
lead to gas generation over discharge again could lead the lithium plating
again causing dendrite that could pierce the SEP separator that again and all of
these could cause internal shorts high current charging heat generation and
excess oxygen generation inside the cell any structural damage to the cell that
results in something being damaged you have one even one of the safety circuits
inside or just the the cell itself external short circuits external short
circuits can cause heat generation these are all examples of abuse that could
happen to her cell examples of poor men poor manufacturing metal contamination
we’re talking at the that the mice of the micron level extremely small not
hardly even not even visible to the human eye
metal amounts of metal so our factories and walk into one of these
state-of-the-art factories people were walking around basically you’ve seen
them like the Intel commercials and the bunny suits this is how how
state-of-the-art lithium-ion factories are run these days and and not everybody
in the world’s factories are all like that
having any type of damage to a misplaced insulation material inside the cell
either at missing it or not putting in the right place or having the insulation
of the wrong type or quality or just worn through during the cycling there’s
lots of ways that that insulation can be damaged over time any irregular
application of active material any type of rip or tear or wrinkle we’re talking
1.5 micron thick materials and then they have to be laid down and wrapped up
perfectly plate slitting make sure when you slip your place there’s no burrs or
imperfections I mean there’s lots of steps in the process that could go
horribly wrong you know from a quality point of view because the materials
you’re working with a very very fine again the idea is to get as much active
material as you can inside the cell pour welding wear a connector internal
connector inside a battery pack could fail or even a weld inside the cell
could fail this is why we do extensive testing on vibration and shock to make
sure that what whatever we’re building inside the cell is robust enough any of
these going wrong could lead to thermal runaway and again thermal runaway as a
heat buildup heat buildup leads to separator breakdown any type of
separator breakdown could lead to internal short-circuiting also he
buildup could lead to electrolyte breakdown that would also build up
flammable internal gases any type of breakdown could also lead to any type of
internal short-circuiting again anything anything that would lead somehow inside
the cell the negative and the positive touching would generate a hot spot that
hot spot with coarse pressure the pressure would cause he heat and the the
battery would ultimately vent systems approach to safety to assure
safe products what the cell manufacturers and the battery
manufacturers recommend is that the throughout the life of the cell that the
cell be maintained in a safe zone of voltage current and temperature its
entire life while short excursions outside the cells spec range are allowed
those excursions also have specifications how much it can be
outside and how long they can be you know microburst outside a range is okay
but again everything has to be within spec the cell the the cell is the power
source the little chemical factory that contains the flammable electrolyte the
next level is the battery pack the battery pack and again the cell contains
safety features the battery pack is the next level the battery pack communicates
with the cell and the host device the battery pack also should contain battery
managing unit that again controls over charge over discharge items like this
current temperature counting cycles there’s lots of different things that
the battery management unit should be looking at
you’ve got the host device whatever the piece of equipment is that needs to
actively communicate with the battery pack and the charger and the power
supply you’ve got the power supply that
converts ac/dc again this should be conditioning the power and also
communicating with the other devices you’ve got the end user the end user has
again all these different circles have a responsibility to help protect the cell
throughout his lifetime the next one is the end user the end user has the
responsibility if the if the product gives you a warning at hit Earth and the
last thing all of this is sitting in an environment the obviously the environment while we
we roughly know what the environment is there’s limits to how hot and how cold
and and what you should do to your equipment your battery pack and your
cell again to assure a safe cell and ie then a save battery over its life you
need a systems approach to safety everything should be working together
when you buy a piece of equipment the equipment the charger the cell the
battery should be sold as a unit the people who designed that should have all
worked together and communicated with each other to make sure they’re selling
or building a safe system and all of this is aimed at protecting the cell
over its life so you can’t have an incident let’s see the last thing I can
say about batteries is you’ve all seen in the last few years a lot of batteries
a lot a lot of batteries I read something the other day that between
2015 and 2020 the world’s capacity of lithium-ion will triple I can assure you
that after 2020 the forecast that we’re seeing is only straight-up if you think
there’s a lot of batteries out there now the amount of Giga factories like the
one Panasonic is building currently out in Nevada there’s plans for many many of
those all over the world and the number of cells and batteries are only going to
increase nobody wants to give up the portability of having their laptops and
their cell phones and their pets so it’s up to all of us to make sure that we we
get this right so we can continue to use batteries in the long run thank you that’ll work Thank You charlie
Thank You Katie for organizing this panel shade it it’s really hard to have
a robust discussion about lithium-ion battery safety without being reminded of
the Samsung Galaxy Note 7 smartphone recall from 2016 I’d like to discuss
some of the safety assurance and process improvements we’ve made since that time
today I’d also like to share with you my perspectives on the advantages in
pitfalls of analyzing incident data real re gum related to battery safety plus
the importance of ensuring the authenticity of branded lithium-ion
batteries and associated accessories now while I’ve only been in Samsung for a
few short months I know that Samsung’s commitment to safety goes beyond our own
products we recognize that our past challenges with lithium-ion batteries
battery safety can benefit all of those in the industry if we openly share our
lessons learned now you remember we may you may remember
that shortly after the Galaxy Note 7 was introduced in August of 2016 we received
reports of certain issues specifically overheating incidents with some of our
devices we quickly initiated a recall program in cooperation with government
agencies and our wireless and retail partners this recall program allowed
customers to exchange their original note 7 for a device using what Samsung
thought at the time to be a safe alternative battery as soon afterwards
however further reports of issues led us to a second recall which included the
replacement of the devices that we’d previously made available to consumers
ultimately we made the decision to halt Note 7 production and sales now in
response to this crisis we undertook two critical missions
first get the phones back from our customers and second to get to the
bottom of the problem so let’s start with a recall we moved quickly to notify
our consumers that they should stop using and return their devices
immediately and it’s fair to say that we adopted the stance of over communication
we offered a variety of innovative innovative options for returns and
compensation so a bounty per se to encourage customers to return their
devices promptly of course we did the things that are typical of recalls you
know such as point-of-sale posters and email messages and you know toll-free
numbers and even a dedicated website but Samsung also had the unique advantage of
being able to directly communicate with the customers because the device itself
became the communication tool to reach them more than 23 million text messages
and push notifications were sent to note 7 customers on the device itself
alerting them of the recall program we also worked with our wireless partners
to push firmware updates to limit battery capacity to make the devices
less convenient to use initially we reduce battery capacity by 60%
and then finally to 0% so the customers would return the returned their phones
the result was 97 percent of the note seventh were retrieved globally 99% in
the US a rate that experts tell us is unprecedented at least for any product
that is sold in the millions of units now at the same time that we were
working to retrieve as many of the devices as possible we are also working
with government officials and experts from three respected independent testing
and forensic laboratories to determine what caused the issue and how to prevent
those issues from occurring again now our extensive root cause investigation
examined every aspect of the note 7 note 7 device and took several months to
complete involved 700 engineers it wasn’t simple ultimately what we found
were two separate issues involving lithium-ion batteries
provided by two different suppliers the initial recall was prompted by incidents
with device containing the first suppliers batteries the recall was
expanded when incidents were identified with devices containing batteries from a
second battery supplier at the investigation determined that in the
case of supplier a the battery problem was one of a defective design and in the
case of supplier B it was a faulty weld what Charlie had mentioned during
production now together it was unforeseeable combination of
circumstances now even though the two note seven battery devices met industry
standards and certification requirements and we’ve had appropriate processes in
place from a safety and quality assurance standpoint these note 7
batteries note seven phones failed in practice we realize that time that we
had to innovate beyond industry standards not only in product but also
in process that’s why we move forward with a number of concrete actions to
raise the bar for our safety and quality assurance processes we started by
building a large scale test facility where we could replicate the incidents
and complete a detailed analysis we then implemented a new eight point battery
safety check which adds significant quality checks to each step in the
manufacturing process including the component level inline production and
post production tests the new process is one of enhancing testing on an increased
number of samples including these steps more durability testing including
overcharging tests nail puncture tests extreme temperature tests visual
inspection on every battery against enhanced acceptability criteria x-ray testing for any or abnormalities
charging and discharging test for 100 cycles a volatile organic compounds test
to ensure there is no leaking electrolyte a disassembly test to assess
overall quality and product integrity testing under foreseeable use and misuse
conditions to simulate what a consumer would do and finally an open current
voltage change test throughout the manufacturing process so in addition to
these extensive checks on batteries we also instituted a new Quality Assurance
process to cover every phase of the battery in the end the device
development now these multi-layer safety measures
are intended to help identify and address any potential safety
vulnerabilities they extend beyond current in current industry standards
and also beyond the root cause we identified with a note 7 to address
potential future safety risks now some examples of the measures and how we
apply are to that we apply to our new products as number 1 is improved safety
standards for the materials in the design of the battery in the device
hardware new requirements including structural elements to further protect
the device for example if it’s dropped and in device software improved
algorithms that control battery charging temperature current and duration the
same sort of safeguards that Charlie was mentioning we believe we’ve left no
stone unturned from our investigation to our blueprint for an industry-leading
safety and quality assurance process that goes beyond current industry
standards in order to avoid a recurrence of a note 7 type situation unlikely as
it may be now in addition to process improvements I just mentioned we’ve also
enhanced our data analytics capabilities to quickly detect emerging safety and
quality defects advanced or big data analytics can provide early warning
signals that companies didn’t get it on top of
problems quickly before they become a crisis advanced analytics pull
structured data from internal sources such as customer service or warranty
databases and marries it with external unstructured data sources such as social
media postings or e-commerce customer reviews using tools for web scraping and
voice to text translation and displaying analyzed information on a visual
dashboard one can easily spot emerging issues analyzing historical data can
indicate quality creep that might otherwise get unnoticed by let’s say
someone who traditionally relies on spreadsheets to analyze their data but
advanced analytics is not necessarily the panacea for identifying lithium-ion
battery safety problems social media is often full of exaggerated or fraudulent
safety claims the same goes for customer reviews on ecommerce sites which are
sometimes written by paid reviewers who don’t actually purchase the products
they review we’ve seen cases where unscrupulous consumers placed mobile
phones in a microwave oven and then claimed a safety defect news media
sometimes reports these incidents without knowing all the facts now my
point here is that information citing safety defects should be very verified
before action is taken speaking about fraudulent claims we’ve also seen a rise
in fraudulent testing we all know about the dieselgate scandal vehicle emission
scandal and you may have heard about the Japanese steel and aluminum suppliers
who falsified test data on the quality of their materials auditing testing
operations is an often forgotten and neglected part of the internal audit
process yet when testing is so important to ensure the safety of lithium-ion
batteries it’s important to make sure that tests
is valid it’s not only a matter of verifying the data itself but also
ensuring that the testing has been done by a qualified laboratory using trained
staff that follow appropriate test protocols with calibrated test equipment
there’s a lot to consider and worry about another instance of which product
safety can be jeopardized is during the repair service
unauthorized repair centers may not be using OEM parts replacement batteries in
particular can be substandard and unsafe they may not fit exactly or be
compatible with a product in which they’re they’re being installed the same
goes for accessories such as chargers and cables now that’s why we strongly
recommend that battery replacement service be conducted by authorized
repair shops by technicians that have the training the tools and the
diagnostic capabilities to get it right and make sure it’s safe counterfeiting is also a concern the
global counterfeit market is projected to reach one point nine trillion dollars
four years from now ecommerce provides the perfect venue for distributing
counterfeit products such as lithium-ion batteries now there are various levels
of counterfeiting there are trade dress infringement involving making the
product we look with the same colors the same fonts packaging but perhaps with a
slightly different name and an attempt to fool the consumer knock offs go one
step further they try to make the product look virtually identical to the
real McCoy sometimes counterfeit products are made at the same factory as
the genuine product but might use substandard components or materials or
weak quality use weak Quality Assurance standards
I call this backroom manufacturing in addition to counterfeit products there
are also counterfeit safety certifications ul has a special group
just dedicated to stop unauthorized use of their ul listed market now today it’s
important for companies to develop strategies anti counterfeiting
strategies to protect their brand supply chain
security is the first step traceability with blockchain technology can help
detect and prevent diversions there are also ways of placing unique markers on
products and its packaging such as electronic inks or crystal taggants to
make it easy to determine authenticity web scraping analytics can be used to
detect the sale of counterfeit products on e-commerce one of the most effective
methods to battle counterfeit products is by prepared by partnering with
government agencies we work with customs Border Patrol to identify counter
products that are trying to enter our stream of Commerce it’s a constant
battle but one that’s important for safety assurance now with the right
safety and quality assurance processes the market police and marketplace
safeguards we think that high-powered lithium-ion batteries will continue to
revolutionize the consumer products market in North North American
marketplace thank you thanks Don and Charles now we’ve had what lithium-ion
batteries are how they’re made the Samsung experience and how to do the
root cause analysis and the changes they made and the fraudulent and counterfeit
concerns and now we’ll hear from Rick Brenner who takes us as an importer and
the things that he has to look for when purchasing products with lithium-ion
batteries Thank You Katie and thanks to CPSC for
the invitation and the opportunity to speak to all of you my experience comes
from 20 years as an importer I headed a large consumer products company in the
promotional products industry and have spent hundreds of hours in factories
overseas overseeing quality and compliance as product safety and
compliance was one of my responsibilities you could subtitle my
presentation today my often frustrating search for a bright line
particularly related to lithium-ion what could I do
as an importer that would guarantee to the greatest possibility that the
product would be safe it’s an honor for me to be on this panel with Samsung and
Panasonic who I’m happy to say are not part of the problem that I’m going to
talk to you about they were the standard that we were
trying to find a way to achieve one disclaimer that my comments are mine
alone I learned this from watching lots of CPSC presentations they do not
represent the views of any organization of which I have had a leadership role so
I want to talk about the challenges faced by anybody who’s importing
products in particularly lithium ion products why it’s difficult and make
some suggestions of what could be done to make things better the short version
is we need stricter regulations and greater enforcement that’s the bottom
line that I’m going to be advocating today so for an importer a lot of our
work starts at this show last week about 4,000 exhibitors exhibited in Hong Kong
at the Hong Kong gifts and premium fare and tens of thousands of exhibitors many
from the US retailers distributors suppliers of all kinds that are
searching for the newest and latest the one key thing that you should know
related to lithium ion is that an enormous percentage of the products that
were displayed at this show are powered by lithium ion the number of experts in
lithium ion at this show is de minimis the number of lithium ion experts
were attendees at the show looking at these products is de minimis and therein
lies the problem Thank You charlie for your power for
your battery this is what I call a mobile power bank if you are running out
of charge and you’re at a baseball game and you you need to charge your phone
you can take one of these devices and plug your phone in and get a charge they
have become ubiquitous they certainly are ubiquitous in the promotional
products industry you can see here that some particular law firm is giving these
away promotional products by the way are generally given away for free companies
buy them to give the give away as a promotion but you would find these same
same products at retail as well whether you go into a bookstore whether you go
online to any of the familiar ecommerce sites you’ll find the same the same
products they’re ubiquitous everywhere this was my introduction to lithium ion
safety customer called up and said one of the people that we gave these away to
just called us and said that they put the thing down on their kitchen counter
heard it whistling turned around and fire was spewing out of one end of it as
a matter of fact you can see this particular product had never even been
plugged in and it burned up pretty quickly so you know the challenge is
obvious that that maybe if nobody had been home maybe the house would have
burned down maybe a kid could have been killed maybe the whole family could have
been killed so the question then that I had as the CEO and chief Safety Officer
the company is why did this secure why did this occur and what steps should we
take in sourcing this product to prevent this this happened right in the
beginning where we started handling these products because there was a point
in time probably was around 2011 when at that Hong
show everybody was showing these these power banks and they became extremely
popular so this was my first step I gathered my entire supply sourcing team
along with the company that we had bought the product from which was a
trading company along with the factory where the trading company had bought
that but the product from and went to you l’s facility in Guangzhou I believe
now of the people in this photograph but two guys with the lanyards around their
their neck are from ul they’re the only two guys in the whole picture that have
expertise in lithium-ion and even the guy who’s standing next to the guy with
the with with the with the with lanyard on he’s the owner of the factory where
this came from he’s not an expert either he bought components from somebody else
he’s an expert at assembling products and that’s another important thing to
know is a lot of the companies that are making these products are simply
assembling them and as Charlie said to me while we were talking after lunch
they might have been assembling something very different the week before
it’s probably a little bit cynical but not terribly so so this is what this
product looks like on the inside it’s exactly what Charlie was talking about
when he showed you the the 18 650 cell that pink part on on the right side of
this photograph that looks like a triple-a battery but it’s not a triple-a
battery it’s a lithium-ion cell the other important element of this
photograph is that little circuit board there that’s actually two circuit boards
plugged in together and that it is referred to amongst manufacturers of
these products as the battery management system and so I’m
gonna talk a lot about that manner battery management system the other
thing that you should notice is that that battery management system those
circuit boards are connected connected to the cell by wires that’s all done by
hand another significant things when you go into these two these factories and I
thought it was significant when Charlie was talking about the welds and the
problem with the welds these this is all this is all done by by handwork so let’s
talk about the components of a lithium-ion power bank this one pictured
here is similar to the one that I just showed you only this one has two cells
it also has a battery management system so the the cell could be an 18 650 cell
that’s the one that looks like the double A or triple a battery or it could
be a prismatic one which is the one that Charlie was talking about that gets
pressed flat typically used in products that either need larger capacity or
because of the shape it needs to have a different shape but it’s basically the
same thing so it’s got the circuitry the battery battery management system and
that’s a very very critical element because there are a number of functions
that battery management system serves as a second level of protection the first
level of protection is the cell that Samsung or Panasonic manufactures and
Charlie described into a detail the protections that are built into those
cells but if that fails the battery management system is supposed to take
effect and it’s particularly takes effect in the use of the product that is
once somebody plugs it in because if you look back at this photograph here if you
look closely at that at that circuit board you’ll see there’s two ports there
one port is the USB that you plug into to plug your phone in and the other one
is what you plug your charger in to charge the item so the
that that battery management system among other things is against plugging
in into the wrong charger for example or overcharging or wrong voltage so you’ve
got a housing you’ve got wire you got insulating materials those are the
various components so each one of those is a critical aspect of what could go
wrong so here is here the consideration cell selection Charlie talked about Tier
one manufacturers that’s a very important consideration in selecting
cells there is a lot of controversy as to whether there’s a significant
difference in the cells that certainly beyond my expertise to know all I know
is that the first tier manufacturers you have the assurance of knowing that
there’s a very strict quality control program in place so one of the things
when when I was in China was trying to ensure that Samsung batteries
notwithstanding the note seven difficulty that Samsung cells were used
in our products that alone was a challenge because unless you’re buying a
million dollars a week you can’t buy from Samsung so then you have to buy
from a distributor so I took that same group of people to the distributor to
say how can we how can you show my inspector here who’s going to inspect
every single ship and how can you show him how he can detect a counterfeit
battery because if if a power bank manufacturer can get an extra 50 or 50
cents or more for a battery because it says Samsung on it there’s a significant
incentive for him to put a pink wrapper around it and print Samsung on it how
could we tell if that was a if that was a counterfeit the circuit board design
that is a black box because most of the people that assemble these do not design
the circuit boards so to be assert assert of the design of the circuit
board you really have to send it to somebody like ul or
I’m independent consultant that can do an evaluation one of the reasons that I
am such a proponent of certification is that ul certification in a case of the
two O five six which is their new standard for power banks not only
includes a certification of the cell which most cells are certified to UL
1642 I believe the the to get the full two oh five six the actual battery
management system not only does that have to be certified but all the
components itself have to be certified so that’s why it’s so important for me
as an importer because at least it’s a third party looking over somebody’s
shoulder saying yes you do have a quality product other considerations
levels of protection the component selection on the board and as I said
third-party evaluation so testing and certification is a very challenging
thing to those of us who are not electrical engineers there’s lots of
numbers lots of standards organizations and lots of considerations the most
important one I want to talk to you about is at one in the upper left hand
corner because it’s the only one that is required and unfortunately in many cases
it’s the only one that’s done and that’s that UN 38.3 it’s a transportation
standard it’s required or you can’t ship the product but it’s primarily focused
on mechanical aspects not electrical so while it’s heavily oriented to drop
tests and other mechanical tests of hazards that might occur during shipment
it doesn’t protect it doesn’t test anything about using the product in a
real life so I raise the question should a transportation standard drive lithium
ion safety testing strategy there are many companies mine included the one
that I ran that did far more than this but there
are many as I’m going to show you that don’t do more than this and it’s why I
advocate a stricter standard this is a experience I had as a consumer and it
just gives you an example of what the challenges are the battery on the left
side is a nikon battery for a camera that they have and it’s about a hundred
and eighty-five dollars a cameras retailer is not allowed to discount the
camera so the camera retailer says but will give you an extra battery when you
when you buy the product so the extra battery they gave is the one that was
pictured on the right side and as you notice maybe you can’t the nikon battery
is ul certified and it lists the certification number on the battery the
generic battery has no such certification so this particular
retailer that I bought this from has a website where you can enter comments so
I went online buy this product and I said I’m not certain what the safety
testing of this battery is but you probably should ask those questions
before you buy this okay the retailer refused to post that comment and so I
got into a rather protracted discussion with their corporate communications I’m
not talking about a small store I’m talking about a billion-dollar retailer
they refused to post my comment after three weeks they finally produced a
letter for me from the generic manufacturer saying it was tested to un
38.3 here are some other challenges that you have these are both solicitations
that I received lowest pricing ul certified battery so now you get into an
issue that is confusing because the cell you go back to the picture of the cell
the cells might be ul certified as I said to you all 1642 but that
doesn’t mean that the entire battery pack including the battery management
system is certified and that’s what’s really important yes of course it’s
important to have the cells certified but these imply these are these are ads
for battery packs and by the way the same exact situation is the case with
38.3 not only does the cell need to be certified to un 38.3 but the assembled
power bank has to be has to be certified and that’s a significant issue where
many times the documentation that’s produced for a power bank to 38.3 is
really what came from the cell manufacturer not a separate test by the
manufacturer and this was maybe the most disappointing situation of all to me by
the way I have particularly I have purposely not included the names of the
companies involved here because I don’t think that’s really important I think
what’s really important is that these issues exist
I suspect the companies involved that I’ve that I’m giving examples of are not
the only ones but as you can imagine having a power bank that exploded as as
the one that I showed you finding reliable solutions of the critical
element so when one of my supply chain people told me that they found a factory
that is making power banks from one of the most recognizable battery companies
in the world a name that they’re there’s not an individual in the US over 15
years of age who doesn’t know this name as a household name so when I heard this
I was ecstatic I thought we hit the mother lode and I went to the factory
and we negotiated an exclusive arrangement to distribute these power
banks then I started with the due diligence show me the documentation show
me the documentation and we kept hearing well the the company in the US the
the company that I’m not going to tell you their name did the testing and we’re
just waiting to get it from them long story short because because our
time is limited there was no testing absolutely no
testing there was 38.3 and in fact of one of the power banks the 38.3 test
that was shown to me was the 38.3 of a cell that was a chinese cell it wasn’t
it wasn’t a Samsung or a Panasonic or an LG it was it was from from some other
company and it was the 38.3 the even the battery power bank from this brand name
yet yet the power bank bore the name of the well-known company with no other
qualifier and I was livid about this so I wrote to the CEO of the fortune 50
company in the US that name it was on it and I was surprised that I actually got
an email back in ten minutes saying that I’m going to refer this to our people
and they’ll get back to you and that’s this email that you’re looking at here
and basically this email said that the CEO contacted me thank you for bringing
this to our attention this is a licensed product licensees test their own we
don’t have anything to do with it we trust they’ll do the right thing you
have any issues you can talk to our global head of licensing that was the
answer it was pretty shocking my last example is to talk about the pressures
that retailers have and importers have for price and how when people are
overzealous in wanting to make a sale how safety can go out the window I could
show you a hundred of these this particular one is significant because it
was in an RFP from a major league baseball team that wanted to give away
30 power thirty thousand power banks at the stadium and sent out an RFP to
distributors giving detailed specifications for what they were
looking for there are no safety specifications so don’t squint trying to
find them but what is significant is that the maximum budget was $3 now $3
end-user price would mean that we would have to buy that product as the importer
for about a buck and a half to sell it to the distributor who would then sell
it to the to the team so we not only refuse to participate but I begged the
distributor not to participate as well and he walked away but this goes on all
the time just because I said no somebody else is going to say yes and these can
be had but there isn’t going to be any safety testing so what can we do about
that so the first thing I want to do is congratulate CPSC for the initiative
this is a available on CPSC’s web site Doug Lee put this together thank you
Doug fantastic work this is this is all part of CPSC’s wonderful initiative on
lithium-ion batteries and the four steps that CPSC outlined improving standards
outreach to education collaborate with external partners that is that’s
fantastic but at the end of the day what we really
need is a holistic standard that requires anybody importing or selling
these products to have tested the entire thing because the battery management
system is such a critical part and there’s no there’s no requirement for
anybody to do that I threw out maybe use the 15j rule and others have told me now
it can’t really you can’t really use a 15j rule because it’s got to be an
observable characteristic and maybe that ul certification mark on the nikon
battery isn’t enough it’s over my head and beyond my paygrade
to know whether that’s true or not I know that we need to have a standard
that you can’t bring about a power bank or a battery pack into this country
unless the entire system is tested so thank you I appreciate it and
acknowledgments 2ul and energy assurance for their technical assistance thanks
Rick thanks to all my panelists Rick Donn and
Charlie those are three fascinating presentations sort of starting at the
beginning of the manufacturer of the cell and working all the way through the
process to the importers and distributors I know we are running out
of time but I’m hoping we can squeeze in time for a question or two yep
if anybody has questions this questions for Rick you mentioned on you and 38.3
that there was no electronic or electrical testing involved
my recollection on you and 38.3 is there’s actually three tests the
overcharge test t 7 the force discharged test t 8 and the external short T 5 are
you could you clarify what you were referring to then in in your comment
yeah my understanding and I would defer to to Charlie on this because he knows
way way more about this than I do but my understanding is that it doesn’t
test the entire system in use it doesn’t test the the system when you plug in a
charger yes it’s heavily oriented to meant to mechanical it does have some
electrical but it doesn’t test the entire system Charlie can you these are
truly and they were developed as transportation tests and the tests that
you mentioned do are are the correct ones you mentioned and there’s there’s
t1 through th but again they truly are limited for
transportation and and they serve a purpose for that that they’re definitely
not the only test you should be doing on cells and batteries Oh seeing nobody else that’ll and the
panel three thanks very much all right so we are ready for our final
panel today our fourth panel which is our stakeholders perspectives panel this
panel will be moderated by Richard O’Brien who is the director of the
Office of International Programs here at CPSC so regulatory cooperation should be
relevant and responsive to real world challenges a stakeholders panel will
provide prospective IDE perspectives on new trends products and hazards and what
can be done within the North America cooperation framework points that
they’re going to focus on this afternoon include cooperation and best practices
policy alignment is to end consumer messaging our panelists for this panel
are Augustine at ma independent consultant formerly with perfecto
Linda may acceso president and partner with the law firm Denton’s US LLP carol
Pollak nelson PhD and independent safety consultant and jean rider a principal at
exponent product safety consulting good afternoon everyone we are we are
the caboose on this train we will try to make it interesting for you and I thank
Rick for saying what I should already say which is none of the opinions that I
express necessarily reflect those of the Commission and I’m going to just go into
the question that you’re undoubtedly asking and that is why are we having
this panel here what’s the point of it we’re we have specifically planned a
panel to take into account the thoughts and views of a diverse group of
stakeholders and there must be some reason behind it so first of all maybe
the most obvious all three countries in this partnership are democracies and in
democracies we believe that people should have a voice and we try to build
in a way to listen to the voices of the stakeholders second reason is failure to
do that kind of puts governments in an echo chamber where we’re just talking
back and forth to each other and that’s not necessarily the most creative way to
solve problems and the third is I’m going to apply a little bit of
conditional logic here the third reason is if governments had all the answers
there would be no private sector and since there is a private sector it
follows therefore that government doesn’t have all the answers so those
are three reasons for having this panel this afternoon and I would just ask our
panelists as they talk to us to do one thing I mean to really be sure that you
do the following please be really clear during your
presentations when you’re making a point that you think the three
regulators the three agencies really need to take away today from all of the
other things that you say which are undoubtedly very useful but make sure
that we get the takeaways from you okay now I think we’re going to start with
Augustine and do you need access to the computer here okay so we will begin
thank you try to do all the presentation in
English those two practices if if not will be prepared without telephones so
well I thank the CPSC for the invitation today it’s my four summit and different
seats but it’s good news not only for me because I’m here I’m very glad to be
here in DC but to hear of the the summit continues it’s at least eight years in
the first summit and maybe two years prior to this first for me to plan the
the first summit so it’s a long time and that shows at least many goals have been
achieved so not only goals as Richards talking to
us for for the government also to the other stakeholders that’s the reason I
was interesting in coming here because I think it’s very good thing that three
agencies continue working together at it has been done their last year’s because
achievements have been important so so I’ll I’ll start my presentation with
it’s not the first slide it’s the name of the presentation but it’s also in
statement we are all consumers and is no one can deny that maybe you can go to
the meeting either with the authorities or in a voluntary standard and if we all
go to the final to defend our product it won’t take us to to any place we have
to go as consumers because having in mind and in the room in the other room
it can be an standard for for toys and you have small children and you like to
have a standard that protects your children for for any danger they can get
from the product having that in mind I start by numbering the stakeholders
that most of the voluntary or or regulations have on their tables
first of all of our manufacturers the importers the wholesalers of any size in
Mexico is very common we invite the Academy I’ll try to go through that why
do do we do that also the consumers NGOs individual groups as profit Co as
something no well it’s not do not make the regulations it’s usually used the
seat of consumer representation also in the developing standards in in Mexico so
it it’s not included in in that groups but is generally the seat they did for
the consumers is used by the profit the government in Mexican case is the
secretary of economy and other people that are interested in in the making of
the standard or any are interested in the in the product either this code in
discussion with authorities or in the standardization process is is how I see
each group could be a participating when when you have to give ideas of how to
make the the prote safer for the consumers
manufacturers I have had some examples of the importance of the participation
of the manufacturers in the the standard development or in the discussions with
the authority but after the panel with previous panel with lithium batteries it
comes even more important when Samsung was talking about the problem with the
with the tablet he talks also he invited 700 engineers to try to solve the
problem if we have a problem with a product at any point we don’t have
manufacturers in the country it could be very difficult to solve it in that
country because they are the experts in the product and they are the only ones
that can give the best ideas on how to solve the problem unsafety
I have been in several countries in Central American South America they
don’t have manufacturers of almost any product and I have been in meetings
where they are discussing the standard but I don’t know how they discuss the
standard without manufacturers I cannot imagine mainly they invite importers
most of the importers are are represented by law firms I did know very
well the loss but not the product so manufacturers we are here in the North
America summits where I think we are privileged to have manufacturers in both
in the three countries and and it’s when we go to either to make a standard or to
the discussion with the authorities we can invite the experts so so we have to
work with that and the manufacturers have to be open
consumer to give everything the hick the manufacturer can some of the items I
think we can expect for the manufacturer the incident data consumer feedback
flowers affected in quality control maybe they detect the problem and solve
it inside the manufacturer facility but sometimes to give away that information
would be very very useful for authorities because some other
manufacturers smaller manufacturers or importers could detect the the failure
even before it goes out to the to the market so that information I consider
it’s very important to give to the groups of this caution and could solve
problems even before the cure that is a purpose for any any standard or any
decision made by the authorities how to eliminate if they find out the product
has been it’s in the market and has a problem how they can correct it there
are proposals to correct them that will be easier for the consumer also would be
and are very necessary when when the risk is detected they also know
perfectly well how to use the equipment so they can train not only their people
a problem we have seen a place in Mexico and I am be much more convinced that is
very important to take if they did the previous panel that talk about the case
of lithium batteries and there were only two experts in ul in the whole ul to
test the batteries when you we have any of the authorities
can’t publish standard Andrea created the laboratory’s which Esper is the one
in charge to operate it that expert so sometimes the accreditation goes through
and gets to a laboratory with expert that are not really experts in the field
at least for for a product as big as Newton batteries are there were only two
people really really prepared to test instance if Mexico or Canada the UL
standard which which one will be training the experts in the country
that’s a very technical issue but that it’s a very very big issue in at least
in in Mexico it that’s enough for manufacturers importers well I said they
can I cannot have experts but even though they can recall some expert from
the manufacturer failure or in they do participate or they can participate
through distance through the internet so we can encourage importers I think to to
participate on that way they have incident at that consumer complaints
probe traceability it’s also very important because maybe the product is
not the problem but the the in seems to manufacturer they the plot will be very
important to know where it comes from maybe it’s very used in CPC to make that
travel ‘ti but for other countries is not so common to to get to that point of
knowing the the trance ability of products put the
last item is ingenious my free report I was asked by the CPC what I was talking
about it not ingenious in the in the nice sense is ingenious in the bad sense
and Mexico have seen many reporters or even the manufacturers on other
countries to sell product if you back you can buy a container but maybe have
the contrary near complies with the standard and the other part does not
comply with the standard the reason is they can reduce the cost by by doing
that and when they show us in the in the table for for certification bodies this
kind of knowledge the manufacturers have it’s it’s a big problem because we have
standard we have testings but when this importers with the knowledge or without
their knowledge they import that kind of product I I think they would be a very
important data to show the authorities or the standardization bodies about this
ingenious companies so so many as some other manufacturers can’t importers can
stop buying from from them marketers or traders I think is the same thing
the incidence data consumer complaints Proctor’s ability process for repairing
the recall sales data and consumer feedback so there are common things
between them the Academy well the camera me they have not only 700 engineers they
have thousands of engineers that can go to the standardization process with
authorities and help also a lot to develop a standard they don’t own
doesn’t charge anything for doing that so that’s
also a very good notice they know very well their laboratory equipment and
something very complicated in the standards or when the natori if has a
decision to make is the the mat in math mathematical
models and they’re very very good in that they have helped mexico to develop
voluntary or regulations a lot with that without help
that’s why and and i haven’t seen the academy in ASTM standards or rise over
UL standard so maybe would be interesting to consider an estate holder
also the they academy also consumers associations particulars or or even
trophic a site that they have also very good information about the the product
they have technical experts each of these as was as an important issue
Canada the United States and Mexico are the only consumer agencies at Casa
laboratory in all the Americas there are no other laboratories from here to from
Mexico to Tierra del Fuego Argentina so it’s very important to have the experts
of the laboratory working with the stakeholders with the standardization as
people or their authorities well as I said only it’s very important to to the
participation of the stakeholders of the laboratories the certification body
and standardization bodies because they they are they wanna use the standards
there there are the ones that make give you a certificate to import it or to
export the product so it would be very important and I haven’t Carroll of a lot
of this participating stakeholder and it’s very important to for them to
participate the Consumer Protection Agency has also a lot of information
that they could be in use in developing new standards are or the discussions for
for risk management the importance of cooperation what we’re looking for is
similar level of protection for all consumers and it could be also a benefit
for the for the all the other stakeholders principally for
manufacturers and and importers we have laboratories well the institution has
laboratory and similar proposals also have been made today and they can
achieve a lot of more things if we get them the information Richard told us to
take out something we like to take out from the from the from the agencies it’s
it’s it’s difficult to do that but principally I’ll try to think of working
together in the development of the standards that we are the agency ours
are not doing that for for Mexico’s if it is difficult but because they have
the experts but they don’t have the language for for many terms in
discussions and a ASTM or ul know so that that would be a very good effort
towards together in the standards develop okay thank you very much otters team and
Belinda is I think gonna speak next and I should just mention it’s interesting
that each one of our panelists either has a recent change of job or
concurrently does different jobs either way there’s a ton of experience up here
and it’s really beneficial so thank you before we talk about which which job I’m
going to talk from first would be useful to know how to advance the slides there
we go look I didn’t even have to advance the slides Wow perfect okay so thanks again and thank you very
much to CPSC Health Canada and perfetto for the invitation to speak today if you
were not here this morning then you didn’t hear me say that I am
here on behalf of two different stakeholder groups today very much on
purpose the first I guess you could just say is industry I’m a partner at
Denton’s us LLP we’re a law firm based around the world the the second group
that I’m here representing today it is my honor to to be here with you as
president of ik faso we are celebrating our 25th year this year again if you
were not here this morning then you also didn’t hear me introduce my my partner
in this in this endeavor I’d like everybody to acknowledge and recognize
mark chom who’s in the back of the room and he’s waving reluctantly yep
he’s known in these parts anyway but it’s very important for us to talk a
little bit about the perspectives and and and whether or not those
perspectives align in ways that we don’t already may not be conscious of but that
they’re already aligned so with that we’ll move on to the stakeholders that
are either here today or are represented here today by proxy or otherwise and so
if we look at the stakeholder cloud I’m looking at you and the audience and I’m
seeing you struggle I’m seeing you worry and that’s because that that’s
indicative of our challenge it’s indicative of our challenge to first and
foremost recognize the multitude of voices that must come
together in order to benefit everyone on the supply chain and so that we can talk
as stakeholders on how we might serve you the put the three principal agencies
that have invited us to be here today to assist you in your challenge so these
are a lot lots of points of view and and frankly I was telling rich at the break
maybe I should just go straight to BWI because a lot of the things I was going
to say today have already been touched on he threatened me and said no you’ll
go ahead and speak actually he didn’t say it quite like that but what what I
thought would be the most powerful is to highlight the two takeaways from each of
our principal speakers this morning that I was moved by because it shows the
thought alignment between the heads of these agencies and in my opinion
industry what industry believes once and is interested in as well as the beloved
it for so model that we’ll talk more about so first from acting chairman
Buerkle what we see in the North American summit and the resulting work
that has been done since 2011 and in particular this week is a stronger more
efficient and transparency that has never existed before among the three
agencies this is information that my industry colleagues want to know and
need to know next from federal attorney Sarah de science is the key and is the
foundation to a globalized world and finding areas for unification he also
shared with us that it the attitudes visions and paradigms of the three
agencies have changed so from an industry standpoint you can’t
not care about what is happening in unification and indeed once the process
matures to fruition we will find such efficiency whether that becomes
reporting whether that becomes compliance whether it multiple types of
reverse logistics borders the fact is is the more the agencies are aligned and
transparent the better off all will be even if some people go kicking and
screaming but that’s for a different topic we also had director Ian Nero point out maybe the most salient feature
of all and that is technology has delivered for us a borderless society so
even though our nation-states necessarily have limitations no one’s
saying they don’t Jeff Barrett did a great job
earlier today explaining that the fact is the consumers also pointed out by
federal attorney Sarah de consumers are going to have the last say in any event
it’s the consumers in this word cloud that are the most important of all and
it goes way beyond just making sure we keep one baby safer it goes clearly to
the point of making sure that industry stakeholders understand ways they can
improve their goodwill ways that they can increase their own loyalty with
their customers in other words it’s extremely cyclical it’s very logical you’ll also note that I don’t have this
is tricky in case anybody’s trying to catch me but this is fun it was so in
the bottom right hand corner of your screen is not included in the
stakeholder grouping and it’s not for the purpose of exclusion on the contrary
it’s because speaking now with my xso hat on episode seeks to facilitate as
its mission more than ever before a platform as a neutral as a neutral that
facilitates the conversation for each of the stakeholders that you see in the
stakeholder cloud so next let’s move on to stakeholder alignment I do better
with visual I just do better I’ve seen a lot of the mathematical
calculations and about as far as I go with true mathematics really is Venn
diagrams so I’m a big fan of Bend diagrams that that I understand so the
resulting and resoundingly successful progress from this summit already
reflects huge strides and alignment but I think unless we realize the two
bookends on either side of products are absolutely the the takeaways that the
three agencies can focus on heavily innovation on the left side and
collaboration on the right side serving as the bookends for the products we
often talk about consumer product safety frankly the products are merely a
symptom the safer the product that means the better the innovation and
collaboration pieces are working how well the products are doing is a symptom
of how the other features are operating and so I believe strongly and I think I
might be mixing up my hats the industry hat and the episode happened that’s okay
late in the day I believe that products are a symptom of
unified safety unified safety that’s the larger encompassing circle in the Venn
diagram so unified safety takes into account innovation we are indeed in the
exponential age there is one thing and one thing only
that we can count on and that is that the speed of change will continue to
increase that is the only certainty we can all take to the bank
recognizing that a group very informal a group of folks around the world decided
that it might not be a bad idea to think about an innovative products process
standard because we thought that somehow or other that might actually help the
three agencies in their work down the line because trying to keep up with the
regulatory constraints and oftentimes handcuffs with which you must work
whether that be budgets whether that be timing whether that be self reporting
structures doesn’t really matter we got the idea that maybe just maybe there was
a way to advance safety by creating an innovative products process standard so
now we’re for sure switching to the episode out right now advanced the idea
with my friend Jean writer who will speak next or after Carol on this topic
I also picked the brains of guys like George borlase Jeff Barrett and multiple
people around the world to see how they might feel about exploring this and so
as a result we’re gonna have a task force an independent task force meeting
at the Seattle Echo so on Monday afternoon and we’re not sure where it
will go from there but what we do know is that we are committed to finding a
way to serve everybody in the stakeholder cloud that was in my first
slide and then finally to wrap it up rich said that’s shareholder or sorry
shareholder stakeholder takeaways were important and this is like probably the
scariest part of my day I’m gonna fly home to San Francisco tonight and I’m
probably gonna obsess for the next six hours
whether or not this was a smart move or not but anyway here goes
normally I share the contents of this slide with industry in an effort to help
industry stakeholders shift their paradigms about working with agencies
today though I am offering my my own personal little long-standing rules of
the road in an in in efforts that hopefully and share them with you as
agencies and stakeholders and with the hard work you’re doing it maybe just
maybe some of the things that I share with industry will help you and so the
first one is it’s always about the science it just always is whether its
financial science or economic science or human factors science engineering
science and maybe I should have put in their governmental science it is always
about the science and if anybody ever says to the contrary that’s just not
accurate number two the US fast track model Wow Wow wouldn’t it be amazing if
we had a fast-track model that that we could come to all three of you and do a
fast track recall with all three of you with one portal I realized that like I
said I will obsess the whole ride to San Francisco whether or not this was this
really stupid thing to say and I’ll never be invited back again but I just
Richard asked me to please just say what I felt so I’m doing it that would be
amazing industry remains daunted by the challenge of different timing different
compliance staff frankly different outcomes different remedies different
requirements for reverse logistics and if there if we could if there were a way
to apply just conceptually a fast-track model for all three I think that that
that would take us a long ways toward unified
safety my next point is that there’s always a solution anybody who works with
me knows that that that an unqualified no is not the way to proceed with me
ever gonna need a reason and what do I mean by that I mean in order for us to
be thoughtful if we accept that that just because we don’t know a solution
today there isn’t one how do we put a man on the moon in other words there’s
always a solution so the rule that I follow is if I’m stuck
i reaiiy go leave it leave it and come back and read it again cold the next
morning in that regard the application to this day and to you is that you know
to make the plan for the very next summit probably already is on the
calendar but the fact that you’ve already achieved such amazing strides
from my perspective means that manat fully solved today it will be on the
fourth point is the ik faso model i’m obviously a little biased but i feel
like the fact that that that we are in an inclusive and non polarized
conversation today is the very essence of the episode model and you you know
some this is a little trite i feel like i might be a little bit bumper stickers
on this one but you know Madani we’re not smiling right if we’re screaming
we’re not talking we’re not having a conversation so if we’re in the
conversation our chances for getting to that solution increase exponentially and
then finally i can’t even believe I’m putting this on a slide in front of the
people that I normally say I’m talking about you it’s Belinda’s triple a rule
the last thing you want to do manufacturer importer client is have the
agency surprised so if we shift our paradigm to how
can we take a look at section 15 be in a new way that’s the u.s. section 14 in
Canada and it for me for proof echo it winds up being a phone call to the
people I know it perfec oh but if if if we can make sure that we’re approaching
the self-reporting nature of our structure with with with the the triple
a rule and that is avoiding surprise we will avoid things that that if I were
talking to my industry clients will avoid things like civil penalties here
the the and I don’t want to come off pejorative or or in any way critical but
the more you all are synergized amongst each other and nobody finds themselves
surprised about a direction that that one of the agencies is taking then it
may not may not have value at all but I do know that it works in industry and
and so I that that’s it for me I want to thank you again I also can’t help myself
in inviting you to Seattle for episodes next regional meeting that’s June 19th
and then Brussels November 12th and 13th and our annual meeting is back in the
District of Columbia next February so hope to see you again very soon thank
you very much Belinda and thank you for speaking freely you’re among friends
here you can do that Carol speak freely okay first I just want to say thanks for
including me in today’s proceedings the US Canada and Mexico are to be lauded
for coming together to work together on product safety this is undoubtedly going
to benefit consumers in all three countries I’m a human factor
psychologist and I specialize in consumer product safety and I realize
that a lot of people don’t know what human factors is it’s an odd discipline
so I’m just going to take a second to tell you about it if you don’t mind
human factors is a discipline that seeks to understand and enhance the
interaction between people and the things that they use and the spaces that
they use them in so within that definition I’m very focused just on
consumer product safety so I look at the interaction between consumers and the
products that they use when I’m looking into a product the key question that I’m
asking myself is how is the consumer going to use the product and that
includes forseeable who are the forseeable users including sometimes
unintended users sometimes we have adult products that children are using another
question I ask is what are the uses that we can anticipate with the product and
this includes unintended uses sometimes called alternative uses or misuse and in
cases where there is misuse I wanted there we go okay I want to know I’m
sorry I’m pressing too hard I guess okay I’ll just talk I want to know what
are the reasons for the misuse and how reasonable is that misuse we have to
answer the question about the reasonableness of the misuse because
ultimately I want to decide what’s the recommendation is it that we need to
change the product change the instructions change something else maybe
not change anything so we’ve got to understand all these factors about the
the use of the product so as you saw from my next slide I will be talking a
bit about voluntary standards but before I do I just want to say since we’re
talking about stakeholders I represent a lot of different stakeholder groups I
guess sometimes I really work with all stakeholders so sometimes I am working
with consumers I work with consumers when I petition the CPSC I’ve petitioned
on a number of different products that I was concerned about everything from
window coverings with the cords that can cause strangulation to gas fireplaces
with the excessively hot glass fronts bunk beds even bunk beds which have had
mandatory and voluntary standards for decades one of the key elements of that
standard was that there were not allowed to be spaces in the head and footboard
that could present a head and neck entrapment that could lead to
strangulation however that same provision was not extended to the side
ladder that in it where it intersects with the bunk bed so even though there
was only maybe one death every 18 months those deaths were entirely preventable
so it’s only one death every 18 months unless it’s your child and especially
when it’s something that we knew about the hazard pattern and we already know
how to prevent it so those are just some examples and I also work as an expert
witness and litigation on behalf of plaintiffs so you might be thinking I
work you know as a consumer advocate and I don’t I also work just as much with
manufacturers I work as a consultant to industry and I try to go through these
very factors that we’ve discussed which is how is someone going to use the
product and the reason I want to know this is because we want to talk I want
to talk honestly with the manufacturer about whether or not anticipated uses
might lead to injuries or deaths and if they do is it possible that you might
need to change product design possibly the instructions
or perhaps it’s the way that the product is marketed so I work with all the
different stakeholders I work with government agencies as well testing
laboratories but regardless of who I’m working with I always have the same goal
and that is to enhance consumer product safety and so one of the most important
ways that I can think of I’m real I have to apologize because when I press a
button different things happen so I hope I’ll get to my slide the right button
right okay okay here we go so one of the most important ways that I
work that I think we can all work towards the benefit of the safety of
consumer products is through our work and participation in voluntary standards
voluntary standards as my colleague said brings together all stakeholders
manufacturers retailers sorry there we go consumers and consumer advocates
scientists and testing laboratories and people like you who are in this room I’m
sorry I have no control of this but people like you in this room from the
different agencies from perfecto Health Canada and the CPSC and the objective of
voluntary standards as you know is to promote product safety and that’s done
through the development of performance requirements as well as requirements
sometimes for the instructions and warnings that might accompany that
product one example of a voluntary standard that has benefited tremendously
from the involvement of my colleagues in CPSC and Health Canada as well as other
stakeholders is the subcommittee for liquid laundry packets for which I serve
as the co-chair along with my colleague Rick Hackman from Procter & Gamble the
liquid laundry packets voluntary standard brought together all
stakeholders including regulate regulatory staff the involvement of
agency staff was essential to developing a standard that we hope will lead to a
significant reduction in poisonings associated with liquid laundry packets
I’m going to tell you a little but about the standard really quickly
because I think it’s important to hear what resulted from this collaboration
the standard includes design requirements that are aimed at reducing
both the attractiveness and access attractiveness of the laundry packets
and also access to those laundry packets and this is this requirement includes
things like number one requiring the use of an aversive agent like a bittering
agent on the exterior soluble packaging number two it requires that the
packaging has to be opaque or it has to otherwise visibly mask the contents that
we think are attractive to children and the third thing most importantly is that
the packaging has to be difficult for children to access now this last factor
is defined in a number of different ways which allow manufacturers a menu of
options to select from in order to figure out how they will achieve
packaging that is difficult for children to access so one of the options for
example is manufacturers can individually wrap the laundry packets
and have like a little hidden tear not that would be difficult for little
children to pick up on and also to open another option is they can design the
exterior packaging in a way that exceeds the dexterity and manipulative
capabilities of young children and yet a third option that they have is to design
the exterior packaging in a way that’s difficult for young children that
exceeds the cognitive and intellectual capabilities of young children so this
creative approach that we came up with this sort of multifaceted approach was
due to the contributions and the involvement of all stakeholders and in
particular we had a lot of stakeholder involvement from Health Canada and from
CPSC furthermore beyond drafting this initial standard it is the continued
involvement of all the stakeholders including the regulatory staff it’s
important for answering this next question that we’re dealing with and
it’s a difficult question and that is where do we set the threshold for when
we say the standard is being successful at what point do we say we’re doing a
good enough job this is important and it’s leading to a lot of controversy and
debate with all of the stakeholders around the table healthy debate but this
is important because if the standard is not adequate if it’s not doing what it
needs to do we will go back to the table and we will incorporate additional
performance requirements into the standard because ultimately our goal is
to make the product less of a risk to children another standard that is
benefited tremendously from regulatory staff involvement is the ANSI standard
for window coverings for which I serve on an oversight steering committee the
work on this standard has been challenging to say the least the vocal
support of my colleagues from CPSC and Health Canada led to the most the
development of the most stringent voluntary standard for window blind
coverings which I am pleased to say will finally eliminate hazardous accessible
cords from most but not all window covering products without a doubt the
support of every stakeholder in the room including regulatory staff was essential
to developing this most this most comparatively speaking stringent
standard I also want to say that I appreciate having the opportunity to
comment on Health Canada’s mandatory regulation which is moving to eliminate
hazardous accessible cords from all window covering products while it would
be ideal for our standards to be fully harmonized it is not possible due to
differences in the laws between our countries despite these differences I
believe I know we have drawn strength from our shared effort and I believe
that the new ANSI standard as well as or I should say certainly with the Health
Canada mandatory standard that hopefully will be published in the next 12 months
that these standards are going to benefit the consumers from all the
countries in North America and the reason I say this and I might be just a
little bit optimistic but I’m really hoping the reason that I say this is
because I do hope that manufacturers will decide that it’s economically more
prudent to import one set one type of product that meets just one global
standard rather than products meeting different standards
into into the different countries sorry I don’t have control over the final
standard that I want to talk about are products that are in the standards that
are intended for the pertain to products intended for infants sleep you may have
noticed that there are a lot of infant sleep products on the market we’ve got
cribs bassinets play yards but we also have other products like baby boxes in
bed sleepers bed side sleepers etc many of these products facilitate in-room
sharing where the parent is going to share the same room as the pay as the
bet baby shares the same room but not the same bed as the parent this is
important it’s what it the aap American Academy of Pediatrics advises for at
least the six first six months of life to reduce the risk of SIDS other
products are intended to be used in a separate sleep surface these are
products that are in bed sleepers that provide a separate sleep surface and a
perimeter barrier around the exterior and that’s important because there’s a
risk of asphyxiation due to overlaying if the baby is in the bed and on the
same metal surface as the adult all of the products in the market today
that relate to infant sleep are responsive to the needs of parents as a
human factor psychologist understanding consumers perceive needs is essential to
understanding behavior and why consumers elect to use certain products why they
feel that they need to use certain products voluntary standards for infant
sleep related products are developed with the objective of allowing the
product to exist in order to satisfy the needs of parents while at the same time
developing performance standards that will reduce hopefully reduce potential
hazards this week actually last night I just returned from voluntary standards
meetings at the ASTM headquarters in west conshohocken for the juvenile
products I the presence of CPSC and health canada technical staff at these
meetings was invaluable as staff contributes to our understanding of the
hazard patterns and that informs what we put in the performance requirements for
the standards in closing i’d like to reiterate how important it is that we
have the participation of regulatory staff from all three countries our other
stakeholders hope to see regulators at the table
their input is sought and it is highly respected I am very thankful to CPSC and
Health Canada staff and I hoped for their participation and I hope to work
with our esteemed colleagues from perfetto in these voluntary standards as
well thank you that’s my final slide Thank You Carol Jeanne irani thank you
rich and I want to thank CPSC Health Canada perfecto and the summit safety
summit organizers for inviting me to participate here today before I start on
my presentation I’d like to build a little bit on the conversations that
we’ve had about standards particularly the conversation that Berlinda brought
up in terms of an innovation product process standard the concept is is that
the we don’t know what the future innovative products are going to look
like we have no way of knowing when they’re going to appear on the
marketplace or in somebody’s imagination but we do know that there are processes
by which you can insert safety into or design safety into any product that’s
available whether it’s virtual reality which we hadn’t seen for four would be
four or four or five years ago or it’s hoverboards or any other product we know
there’s a process by which we can insert safety so the objective of this team
that we’re building that ik foresaw is to start to look at who wants to
participate and how we would organize ourselves and what the scope would be
the intent of doing it at it for so is because it for so is the one place where
all industry gets together if you go to you know think about safety organization
SDOs you know standards organizations they tend to they tend to organize
themselves around products or around industries
but innovation is not an industry innovation you know covers all
industries so we need a place a location where we can bring in stakeholders from
all sources all product areas all product concepts in all industries in
order to build this this process standard and I certainly hope that the
regulators will participate with us and if you think about some of the
challenges that I’ll call them sellers have is when an innovation product comes
on the market and there’s no standard they can’t they have nothing to ask the
the inventors or the producers or the manufacturers did you test that did you
certify that there’s nothing out there for them to say did you do that because
there aren’t no one knew about the product it could take years to build a
standard for that product but if we had a process standard then in fact we would
have something that we can hand them and say did you follow this process and to
insert to design safety into your product before you bring it to the
market so it could serve a very valuable I believe this standard could serve a
very valuable purpose across of the entire marketplace so I hope that you’ll
support us as we try to work our way through building this I also want to
thank rich for explaining why we’re here and what we’re supposed to be doing
today what I really want to talk about today or what I intended to talk about
today is tolerable product risk and that’s something that we haven’t you
know talked about or touched on at all today as far as I know right and we all
know about this recent incident you know a motor and airplane you know engine
flew apart and someone was killed and within hours of this incident we heard
from safety professionals we heard from regulatory agencies this is a freak
actress accident the public should not worry okay
now what does that say okay it says that some risk is tolerable the public should
not worry okay in fact that was one fatality out of a
hundred million flights or so estimated hundred million flights for a March 2009
until now but if you went back to January 2009 it was actually 50
fatalities out of about a hundred million flights so in one case you’re
talking about one in a hundred million in another case you’re talking about
five out of ten million so there’s a range of tolerability in society what
society will accept in terms of you know risk now before you talk about risk you
have to talk about the risk equation the risk equation is so simple it’s actually
complicated it is the product of exposure and hazard and what it tells
you immediately is that if you have a little exposure and a little hazard
you’re gonna have a big risk and that’s just how it works when we’re in the
consumer products industry our goal is to have a huge exposure we don’t want to
sell tens of products we want to sell millions of products so exposure is very
high in our consumer products industry now it is very efficient to manage risk
by managing hazard and I noted this morning and this afternoon how often the
word hazards was mentioned but not the word risk and we want to eliminate
hazard we want to control hazard we want to manage hazards there’s two problems
the first problem is is you never can drive hazard to approximate zero if you
could you could eliminate risk but it doesn’t work that way
there’s always will be some level of hazard in
product so there always will be some level of risk in the product product
category so what we have to do is we have to really understand what is an
unreasonable risk or what is a tolerable risk from our products and I think this
can help drive a number of changes in terms of how we approach you know the
safety of products in terms of how we approach the energy that it takes to
recall products that may not be unreasonably risky right it can help
change how we think about things in many cases now we hear about recall fatigue
there are so many recalls nobody cares anymore
there’s so many recalls of gee I’ve been using this product for years and
nothing’s wrong with it so I’m not going to recall I’m not going to turn it in
I’m not going to change it well you should think about what scope we really
wanted to have when we talk about tolerable risk so risk is a probability
it’s really a probability of the likelihood of an occurrence and the
likely consequence if it occurs so it’s two parts is it going to happen and if
it does happen if somebody got hurt is there going to be extensive property
damage right so it’s really two parts what’s the likelihood of it happening
and what’s the likely consequence if the likelihood of it happening is really
high but the consequence is really low donessa low risk so I want to deal with
this question of hazards okay hazard does not equal risk and I want although
most of you probably touched one of these today this little bottle cap right
now if a child chokes on this bottle cap they’re probably going to die this is
extremely hazardous if you choked on this bottle cap and I
hope you don’t right you might die I mean this is an extremely hazardous
shape in size but the reality is children don’t choke on
because of the way it’s used because the product said it’s on it’s how you use
the product acting chairman and Buerkle just put it right back on their cap on
it honor but honor bottle just like that just as she did that right so we don’t
have it’s not attractive to children it’s generally not available to young
children it’s generally not separated from the bottle even when we dispose of
the bottle it doesn’t represent an unreasonable risk if you look at the
data of the billions of these caps that are in the marketplace versus the injury
level it’s shockingly low shockingly low so it does not represent an unreasonable
low risk so when I want to think about tolerable risk and I would I guess one
of my takeaways by the way I have to remember what rich destructions were and
that is that hazard does not equal risk that’s one take away but when I think
about tolerable risk I like to put it into this format so first is I don’t
know that I can actually use a pointer I don’t know if I can
is that working no son okay so first is you know there’s the severity and we can
start with with fatalities and work our way all the way down to complaints okay
we start from the top and work our way down right and then there’s the
likelihood of occurrence and what I tried to do was put this in the format
of one in a hundred million that goes back to the one fatality in a hundred
million from the exploding airplane engine to one in ten million one in a
million and then it all the way down to one in 10,000 okay so and then what I
did is I just used my arbitrary sense of what is tolerable from 35 years
of studying this right so I arbitrary sense of what I think is
tolerable what society tolerates then I use something else
oops I’ll go back went too far I took a product that is in ninety-eight percent
of a hundred and thirty million households in the United States
and I went through the available data on fatalities hospitalizations and treated
and released injuries and on property damage for the years 2012 through the
years 2016 in the United States and that’s where that category of product
stands and it’s interesting because unlike blinds courts or other products
no one is saying the standards for this for this product is B I’m not gonna tell
you what the product is but I’m saying the standard for this product needs to
change everybody seems to be quite acceptable that this is a reasonable
standard for this particular product and it’s in some 120 plus million homes and
used mostly daily right so then I took it looked at a product that has been
recalled and I plotted that data it’s the same category okay
but that product was a voluntary no recall and I sit back and I say hmm was
that really necessary because that product is an order of magnitude safer
from real data than the category that it sits in so when I think about this I
think is this how should we think about tolerable risk and then asking the
question how should we be thinking about what’s tolerable and what’s not
tolerable and if we if if this particular category is not tolerable
then let’s change the standard right but if this particular category is tolerable
isn’t acceptable and it’s not an unreasonable level of risk what is
acceptable then let’s not beat up on products right that are less hazardous
less risky so there’s my final thoughts and
that’s what I’d like to leave you and thank you very much thank you Jane I did
take some notes and I do have I have the list of the items that seem to be the
ones that the panelists would like the government representatives in the room
to pay attention to among others but these are the ones that you called out will get a double star next to the first
one and that is work together the three agencies work together with standards
development organizations both all three governments that was mentioned several
times another one was that I have to read my writing okay another one was
that through the use of transparency and science we can move efficiency forward
another one was that there may be value in developing an innovative product
process standard and although you weren’t explicit either Belynda or Jean
I think you were implying that the technical staffs from the agencies could
be active in that work that’s correct okay we could we could send it an
engraved invitation if that would be helpful
I’m I wouldn’t want to comment on whether that would be helpful as I said
it’s a free country so yeah go ahead and follow through as you see fit and it’s
always about the science that was another one
and I think that came up a couple of times and then finally hazard does not
equal risk and I we just saw a graphic illustration on that particular point we
we got done actually we got it early believe it or not on this panel we are
going to have more than just time for just one or two quick questions
we have by my watch we have 14 minutes so we have time for a little bit of chat
a little discussion so is there anyone out there who would like to either make
a comment to this panel or ask a question or prompt a response from our
panelists we have microphones if you hold up your hand someone will bring you
a mic I just have a question but the this team you want to put together it
for so is this gonna be open to anybody let’s participate testing agencies and
is this at the meeting or is it something outside the meeting and so it
is public information if you go to WWF s org select the Northwest Regional
meeting click on schedule and look at Monday afternoon at 4:00 o’clock I will
expect to see you there it is absolutely public everyone is welcome no matter question I get it we all get it okay last chance
I think happy hour started already yeah I think that’s it right well I would
really want to thank the panelists for being here did you have a were you
trying to make a comment oh okay indeed it is okay well I want to say
thank you very much I know we’re still gonna hear from the chairman but I
wanted to just mention that as as the head of the office responsible for
putting this together that I am incredibly proud of the people who work
in my office it’s not just one person that put time into this it’s a team
effort and it’s not just our team either it was constant work by teams in Ottawa
well actually not just Ottawa in several places in Canada actually because
they’re not all together in one city but teams in Mexico and in Canada who worked
together with our team to make it happen and if I didn’t say it before I’ll say
it again I really really am proud of the work that they did it’s just amazing so
that’s all for our panel and I’m Brittany are you gonna jump in now thank
you so as we as we prepare to wrap up for
today we’re going to have one last set of
closing remarks so if our three principals would like to
take the dance we’ll have closing remarks from acting
chairman a Marie Buerkle little attorney there doe as well as Robert De Niro as
as our final wrap-up and closing remarks I’m not sure where to begin what an
impressive day that was put together here so many people to think but I will
start with by thanking all of those who agreed to participate in the various
panels as I said this morning your engagement and your willingness to share
your expertise and your insights really is a key to our success and moving along
the concept of product safety you know since I’ve been at the agency for five
years I talk about collaboration every time I open my mouth if you’ve heard me
you’re probably tired of hearing it but I firmly believe that we can accomplish
safety in a way when we’re all at the table and we’ll all we’re all sharing
our safety and our expertise and as rich said we the government don’t have all
the answers we just don’t we don’t have the
resources we don’t have any of what we need to get to have all the answers and
so that’s why your your input and your expertise with all of us is so key to
our success and I sincerely thank all of those who took the time to travel here
than to spend their day here to understand product safety and to hear
from our three countries as I said earlier today we’re building on solid
accomplishments the joint statement that will be published right after we
conclude the summit will be an accurate reflection of our accomplishments
accomplishments as well as the ambitious work we intend to undertake and setting
forth for our three agencies I truly believe that all consumers and we are
all consumers I thought that that was such a great way to start the
presentation we are all consumers and if we think about it that way I think
that’s breaking down some of the silos and rather than yelling back and forth
at each other we’re really trying to solve the problem but I believe that all
consumers and stakeholders are better served by the product safety cooperation
among our three governments I would be remiss and I will say it again just
about the excellent panel discussions we’ve had here today
and again I want to thank all of the participants for being here finally as I
said this morning these events just don’t happen they take a tremendous
amount of work and commitment by all three of our staffs the staffs this
morning we recognized all three of the staffs but this afternoon I want to in
particular thank Tilghman Bernal where is she children has worked tirelessly
for so many weeks to put these last two days together and her work has not gone
unnoticed and certainly the success of these two days and our summit was
reflective of all of the work she has done as I joked with her yesterday said
you probably put less time into planning your wedding and it’s these these events
are a tremendous amount of work and she deserves such a tremendous amount of
credit and as rich said earlier the International Group in our agency is
small and so when one undertakes a project everyone undertakes a project
and so you saw the entire team here over the past two days helping to make today
and yesterday work so well and I appreciate what they have done so so
very much again so I will I think at this point turn it over to Robert thank
you and good afternoon again everyone and thank you again for being here and
spending today with us truly impressed with such a constructive and informative
summit first off I know folks are probably getting a bit tired of hearing
all the thanks but on behalf of Health Canada I did want to express our sincere
gratitude to you and Marie and your staff your amazing team for being such
great hosts and putting on such such an impressive event you have not only been
a gracious host but you’ve been so generous in welcoming us not only as
colleagues but as true friends and I have no doubt that I I speak for my
colleagues at profile as well so it’s truly been an impressive day the
presentations were quite informative and I think it did give us an opportunity to
share and to showcase some of the great work
that we’ve been doing trilaterally through the summit’s and I’ll speak to
that in just a few moments no doubt the presentations on e-commerce were very
informative as well as the panel this afternoon on high energy high lithium
lithium ion batteries particularly enjoyed the last panel on stakeholders
and and obviously how when an important role they play and how we can continue
to improve our work as regulators and collaborating and coordinating our
efforts with our broad range of stakeholders
I left the Consumer Product Safety Bureau in 2011 and I had spent a good
number of years in the area of a consumer product safety before leaving
in 2011 and I can tell you that the amount of cross jurisdictional
cooperation and collaboration has taken place since I’ve left is is honestly
outstanding it’s astonishing when I was in Consumer Product Safety I think the
international office here at the CPSC was made up of one individual by the
name of Collin Church some of you who have been around for a while may even
remember him so I think obviously a lot has changed since then and that is
obviously led to the significant achievements that we’ve seen starting
from our first summit in 2011 and as we sit here and conclude our fourth I think
what that does show and demonstrate is the commitment that each of our
jurisdictions is placing on the importance of collaboration and
coordination across our three regulatory organizations I think it’s really
important to note that trilateral cooperation across our regulatory
agencies does not only benefit industry consumers and broad stakeholders but it
benefits our roles as regulators and simply put it’s good for us too without
that collaboration and coordination we’ve heard countless times today the
rate of introduction of products from conception to market entry and to the
fact that ecommerce is driving so many sales in the world today and believe it
or not we as three regulators do have limited resources that are
interjurisdictional cooperation and collaboration is key for us to be
successful and in fact it’s my belief from Health Canada that we would not be
as successful as we have been in achieving the important responsibilities
and mandate of protecting the health and safety of our citizens in our respective
jurisdictions if we did not have that level of cooperation and collaboration
so one key takeaway from me and there’s many and I don’t want to repeat many of
the things that has already been said but one of the areas that I do feel is a
is an error that we can focus in going forward is in areas where we may not
have any requirements or we maybe haven’t identified hazards or risks and
I agree there’s a difference I think there’s an opportunity for the three
jurisdictions to come together at very early stages at initial stages from the
ground up to work together to compare knowledge to compare data to compare
expertise and to the greatest extent possible work together at the earliest
stages whether or not that includes the innovative product process standard I
think that may fall into that type of category at Health Canada and under the
Canada Consumer Product Safety Act we have 34 regulations that from time to
time need to get updated and need to get modernized based on latest standards
latest test methodology changes an incident data whatever the case may be
and when we review those requirements I think it goes without saying that we
look at other jurisdictions and update and modernize those regulations to try
to align them as much as possible and that is in fact what we’ve done and I
can just give you three quick examples that are quite recent
first of all lead in children’s jewelry and then soon-to-be final publication in
our Canada Gazette part two or playpens and small magnets and toys so I think
we’ve got some very recent examples and I hope our stakeholder today realize
that we hear you loud and clear that when
possible we align our requirements aligning those requirements so I would
say is not the only area that we can collaborate and coordinate we have many
programmatic elements that we’ve talked about be it recall or trying to
coordinate better on say a fast-track recall process or on import
there are many programmatic elements beyond just our regulatory frameworks I
would be remiss if I didn’t just take a moment to note though that from time to
time this is my big caveat there’s going to be differences and those differences
could exist for a variety of reasons it could come from the fact that we have
come to conclusions and a risk assessment that have made different
conclusions or we may conclude that the best approach to manage risks in those
products may be different than some of our colleagues but I think it’s fair to
say that those should not be the norm and ideally would be limited to the
greatest extent possible and I think to date we’ve demonstrated that so with
that and marine rajulio you and your staff have brought no doubt
positive energy enthusiasm to all of your work and that has been reflected I
think in the discussions that we’ve had not only today but as we spent time
yesterday together it’s been a truly productive and constructive summit and I
know that our teams have a lot of work to do going ahead and we look forward to
to continue to build on the momentum to date and just to conclude I like to say
that Health Canada is very much looking forward to hosting the next North
American consumer product safety summit in Ottawa Ontario so stay tuned for
those details and we’ll be excited to report on the progress that we will have
made in the next three years so thank you again merci gracias thank you very much Robert royally Oh buenas tardes alcira desta cuarta Cumbre
so Brazoria productos de consumo es necesario Y estamos octo table God owes
express our nuestro reconocimiento nuestra gravis in en toe Marianne es su
equipo para certain Sione’s los potala de la feet ronia que nos and odd o s
todos dias crotches on portal apoyo y por el entusiasmo con el Casa armado
your hanazad Oeste important IC malunion para nosotros también day hora con hacer
la participation compromise a de de CD de the Health Canada para que esta
reunion to be Arab Rio he Posterous Moo’s areas a professional me concretist
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este de Sirois yo postrera productos en ellos Murkowski no stroke a vigilar case
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teresa momento momento habla de los reyes bossy
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con los estándares record Eidos en cualquiera de los tres Price’s miembros
capers i paused esta Cumbre pi seguramente no van a circular you know
de los otros dos and robert Engan las Altezza de que todo product okay sarah
tirado del mercado en este pais when canada o poder a commercializes en
mexico 10 ganas assert esse gracias por su apoyo a collaboration con una de la
que o estamos dando n testimony o la inscribe oh no parte del programa del
Presidente del gobierno el presidente pena que en su initio llamo programa
Nacional para la protección he defends a delicious little songs to be Doris those
mil tres a don’t miss yo Joe los trabajos de esta Cumbre y las tres
previus no tienen Presidente’s en la historia de la relación de
nuestras de nuestras Naciones es algo que no se hace a– occ Asiya a rob a
standing formal e para Miren non-normal gu us here k some parties to trabajos
they look at our video part of their plan that the fence and a loser rituals
consumers as their president opinion vamos esperar con mucho con ansiedad
econ entusiasmo yo mildwin – no en medio de Sol tengan la certeza de que vamos a
trabajar da cunha in LA in acaba de in a kebab litera esta rebus ando los
productos cases tan commercially Sandra’s us troll mercado’s locales esta
suerte okay Sergei estan conclu yendo los trabajos de esta cuarta hombre de
seguridad productos de consumo in America Norton our sin embargo pienso
que no conclusion Asteria last areas que tendremos que estar realizado para
continuar on Rondo el compromiso que nos permitir
que no permit a need askance owes me bahar los brazos que consiste en
guarantees our la presencia en nuestros mercado’s solamente de productos que no
resultant pernicious para la salud y la seguridad de los mejores ago botos para
que este tipo de reuniones a multiplication a lo largo del rey
mysterio e in our awareness poor kinara restores news report mexico measures thank you very much and let me just
finally thank both of my colleagues and their staffs for making the trip here to
the United States to Bethesda Maryland to engage with us for this trilateral
summit not only have we had just an excellent two days with a lot learned
and a lot of tasks laid out before us but I think we have forged some
friendships and relationships that I am confident that we will continue the
conversations and the relationships only to strengthen product safety throughout
our continent at this time I just would wish both of my colleagues safe travels
and all of their staff safe travels this has been a wonderful two days
congratulations to all of the organizers and thank you for your service
this Ensign concludes our summit Britany i think i turn it over to you yeah thank
you and quickly just a few closing remarks
we’re gonna if we would ask for the three principals to stay here they’re
gonna have some photographs before we leave today so thanks to everyone for
coming just one last piece that I wanted to make sure everybody aware it was
aware of there were a few questions regarding the slides on the CPSC slides
that you saw today will be available later I guess probably next week on the
CPSC website so if anybody was interested in getting a copy of the
slides presentations from the CPSC staff today please check the website and then
there was another question regarding the entire summit today that has been taped
and it will also be available next week on our youtube channel so you can find
that on forward slash CPSC so with that I’d like to thank everybody
for being here today thank you for attention and I wish everyone a safe
travels and have a wonderful weekend and I would like to note that we’re finished
before 5:00 for the people who were concerned about happy hours so thank you

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