What’s the most common response distributors receive when asking suppliers if their products are safe? “We have tested our product.” Yet in spite of this testing, I’ve heard countless stories from distributors and suppliers alike about how they have had to refuse product during the warehouse receiving process because inspection or random testing revealed that the product failed to meet required safety standards. While this is certainly a problem for the shipment in question, the issue is much broader. Who’s to know how many other suppliers have received unsafe blank goods from the same factory as in the above example?
Of course, requesting product safety testing results from the factory about the specific item it is making for you is a natural first step. Seems easy enough, right? Unfortunately, the factory will routinely send you an outdated test report that often was done on a different, but similar, product. I’ve witnessed this firsthand, having once received an eight-year-old test report written in Chinese on a product that was only vaguely similar to the product I ordered.
And, sadly, I’ve heard of many worst-case scenarios for distributors where clients did their own testing after receiving the product and the product failed testing miserably. After all, what’s a little lead—actually a lot, 7,200 ppm—have to do with getting a safe travel mug?
I have a pretty good idea of the effect these issues have on the relationship with your customer. These are among the many reasons that end-buyer clients take a “trust-but-verify” approach to product safety and compliance. They can’t depend on us to reliably provide it, so they must validate it themselves at great cost and inconvenience to all parties involved.
How do these situations happen? I think there are three primary reasons:
- There is an assumption that someone knows not only what the product requirements are but are also meeting them.
- There is a “golden sample.” Factories knowingly send samples they know will pass testing into the labs, and no one took responsibility to verify that actual production matches pre-production sampling.
- There is an over reliance on product testing as the only vehicle for delivering safe products.
In terms of product safety, we get what we measure. The things we measure, ironically, tell our supply chain what we value. If we do not know what product standard to measure/test against or how to ensure production matches the golden sample sent in for testing, we are left with trying to put our Humpty Dumpty project back together again after it has fallen off the proverbial wall.
On a side note, even if we deliver safe products we must remember product safety is only one part of the equation. While product recalls are drawing much attention these days, historically, more big companies have been tripped up by social accountability issues rather than product safety problems. This has become such a concern that most Fortune 1000 companies now have some sort of Corporate Social Responsibility (CSR) program. There are even published lists of the alleged worst offenders, which I imagine does wonders for the stakeholder stock price.
Testing or factory audits are certainly best-practice steps to measure the effectiveness of your compliance program. But in and of themselves, testing and factory audits are not a compliance program. The CPSC has given some direction on what should be done in the presentation “Reasonable Testing Program & Third-Party Testing.”
The goal of a testing program is to create a reasonable certainty that all manufactured products comply with rules, standards and bans. The components of this program include:
- Product Specifications
- Certification Testing
- Production Testing
- Remedial Action Plan
- Documentation
Testing must be proactive. Testing must be current. Testing must be specific to the project you are manufacturing if you have changed that product by putting a logo on it. I’m not aware of any ink suppliers that offer current test reports on their inks. So in the absence of their component testing, you are obligated to test these inks yourself. Product testing must be a component of your product safety and compliance program rather than an end-of-the-game “Hail Mary” to see if product safety exists.
To help you determine if your supplier partners are following the CPSC protocol, ask these questions:
- What is your testing program?
- What is your social accountability program?
- How do you develop the product specifications that you give to your factories?
- What are your checks and balances to ensure production matches the tested sample, and where does this take place?
- What happens when a product fails testing?
- What steps do you take to correct the manufacturing process?
- Heaven forbid it should ever be needed, but what is your product recall process in case something slips through?
If your supplier can send documentation within an hour or two, it has a proactive compliance program. If it takes a day or two, the policies are most likely being quickly written so the info can be sent to you. If the supplier says, “Huh?,” we wish you luck and hope you have a big product liability policy because we’ll be hearing or reading about your customer in the headlines soon. Let’s hope your relationship with that customer and your business survives this inevitability.
Brent Stone is executive director – operations for Quality Certification Alliance (QCA), the promotional products industry’s only independent, not-for-profit organization dedicated to helping companies provide safe products. A Six Sigma Black Belt, Stone has more than 25 years of in-depth supply chain management experience with extensive expertise in process design, development, improvement and management. He can be reached at [email protected] or visit www.qcalliance.org for more information.
