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Multi-Jurisdiction Recalls

Multi-Jurisdiction Recalls. Future of Co-operation And Inter-Agency Recalls. Product Safety Regulations. Key U.S. Product Safety Regulations: CPSA, FHSA, PPPA, FFA, VGBPSSA, CGBPA, and RSA Health Canada Product Safety Regulations:

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Multi-Jurisdiction Recalls

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  1. Multi-Jurisdiction Recalls Future of Co-operation And Inter-Agency Recalls

  2. Product Safety Regulations • Key U.S. Product Safety Regulations: CPSA, FHSA, PPPA, FFA, VGBPSSA, CGBPA, and RSA • Health Canada Product Safety Regulations: HPA, Food & Drug Act Cosmetics Regs, Department of Health Act Soon: Canada Consumer product Safety Act

  3. Agency Powers • Key differences in Legislated Powers: • US CPSC has mandatory reporting requirement in USA, Monetary Penalty schedule • Health Canada does not have mandatory reporting requirement in Canada, uses Advisory as necessary, can place product under seizure

  4. Agency Responsibilities • Key differences in Product Categories regulated: • US CPSC responsible for consumer products, including ATV's and electrical products, excluding Cosmetics • Health Canada responsible for consumer products, DC powered electrical products and Cosmetics, excluding ATV's

  5. What is a Recall? • All recalls are voluntary and were posted with the consent of the company. These postings include the following actions: • Stop sale • Product removal • Corrective Action on Affected Product • Design Change for Future Stock • Investigate cause of problem • Customer support • Communication strategy

  6. Volumetrics • Recalls are defined as • stop sale + corrective action + publicity (minimum: posting to website) • Recalls Posted in 2009 (calendar year) • 396 posted by CPSC (137 of these Sold in Canada and USA) • 305 posted by HC (168 Sold only in Canada)

  7. Levels of Inter-Agency Cooperation • Various levels of cooperation: • Recall posted independent of other agencies • National: • Agree to post common message on multiple sites (eg: HC with TC or CPSC with DOT/NHTSA) • HC is negotiating MOU’s with ESA (Electrical Safety Authority) & TC (Transport Canada) • CPSC have signed an Interagency Agreement with DOT/NHTSA • International: • Agree to post common message and sync timing • Agree to Joint Recall Posting • CPSC and HC have signed an MOU

  8. Criteria for Cooperative Recalls • CPSC-HC: • Product sold in both countries • Corrective measures and customer support extended to customers in both countries • Timing works for CPSC, HC & Company • Have agreement from company to share all information with both jurisdictions early in the process • Recall is conducted voluntarily

  9. CPSC Procedures for Joint Recalls • Initial contact made with Health Canada to confirm joint recall and company agreement to share information between HC and CPSC • Periodic updates between company, HC, and CPSC to determine case status and time frames • Draft press releases shared to ensure accuracy and consistency of language (Joint Header) • Date of release coordinated between HC, CPSC, and the company • Links placed on both HC and CPSC websites

  10. Joint Health Canada- US CPSC Recall postings As of Feb 2010, 25 Joint HC-CPSC recalls posted • Features: • Agency Seal on header, banner indicate joint recall, Media contacts for both agencies (on CPSC site) • Numbers of product sold in each country, injuries and incidents reported in each country, web links to each others' websites (on BOTH sites) • Advantages: greater exposure in both countries in more languages (Spanish, French), reduction in burden and delays in negotiating + posting, synchronized time of posting with common message

  11. Disclaimer "This presentation has not been reviewed or approved by the Commission and may not reflect its views“ - US CPSC

  12. Contacts Marc Schoem, Office of Compliance and Field Operations, CPSC e-mail: MSchoem@cpsc.gov tel: (301) 504-7520 Mark Veitch, National Coordination Division, CPSD, HC e-mail: mark_veitch@hc-sc.gc.ca tel: 613-952-5656

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