We Got a Plan.. An Import Safety “Plan” – Part 2

Friday, November 9, 2007 7:11
Comments Off on We Got a Plan.. An Import Safety “Plan” – Part 2

After reading the transcript of the press conference, I knew I had to get my hands on the report itself and read through it for myself (Action Plan can be downloaded here). I needed to see just what the findings were, and more than that, I needed to see what their recommendations were….

Now, given it is a 86 page and I am sure you all are not looking for the page by page, so first I will offer some thoughts on the points the government felt summed up their “plan”… and then I will offer a few comments

So first, the framework (as seen in the picture below)

The highlights of the findings as per the U.S. government fact sheet:

  • The Action Plan proposes a strategy focused on a risk-based prevention with verification model that allocates import safety resources based on risk.
  • The sheer magnitude of the import-export enterprise makes clear that our Nation cannot inspect its way to safety.
  • The Action Plan presented today reflects the Administration’s commitment to continually strengthen and improve the import safety system

and their 14 recommendations:

  1. Create new and strengthen existing safety standards.
  2. Verify compliance of foreign producers with US safety and security standards
  3. Promote good importer practices
  4. Strengthen penalties and take strong enforcement actions to ensure accountability
  5. Make product safety and important principle of our diplomatic relationships with foreign countries and increase the profile of relevant foreign assistance activities
  6. Harmonize federal government procedures and requirements for processing import shipments
  7. Complete a single window interface for the intra-agency, interagency, and private sector exchanges of import data
  8. Create an interactive import-safety information network
  9. Expand laboratory capacity and develop rapid testing methods for swift identification of hazards
  10. Strengthen protection of IPR to enhance consumer safety
  11. Maximize the effectiveness of product recalls
  12. maximize federal-state collaboration
  13. Expedite consumer notification of product recalls
  14. Expand the use of electronic track and trace technologies

Some comments on the above. These are all in the grand scheme of things are all processes and actions that need to be in place… but these 14 items fall well short of what it is needed, and I would say that some of them actually will bring little return on investment.

The interagency collaboration and consumer notification are items that are needed.. but the rest is little more than window dressing.

Let’s start with the fact that the majority of goods imported from China (I know.. I know.. this “plan” is not a “China” plan…) are exported from China from non-Chinese firms.. and that many of these firms are US firms. Not even mentioned. As far as this report is concerned, anything imported is “foreign” and those “foreigners” need to be held accountable. uh.. excuse me, but wasn’t it MATTEL’s designers who designed 17.8 million magnets that could lodge in the throat of children… and wasn’t it MATTEL’s quality control team that failed to inspect their suppliers paint shop as specified by THEIR OWN regulations?

Next, we need to address the fact that every single item manufactured in ANY factility around the world CAN fail. every single item…. There has NEVER in the history of produciton been a 0% failure rate. there are always problems in manufacturing, and while it doesn’t mean that a process will fail.. IT CAN FAIL.. and it is the job of the manufacturer to ensure that their QC is in place to catch failures before they get out to market.

That is why the “rapid response” lab is a pork barrel item that is just meant to make people feel safe.

Further to that (and putting aside food and drug for a minute here) who in this club of 12 agencies would have said that toys were a high risk category 8 months ago? What about tires? cribs? how would they ever have picked one shipment of the millions and millions coming in every month?

Next, why is there not a single line item directed at the brand themselves that outsource. Why not pass a bill that says if you outsource your production you are considered just as liable for any failure to the same level as if you were making the product? Why not say that failing to having an inhouse inspection of all shipments before they reach the shelves is mandatory?

The fact of the matter is, that the biggest factor in cutting out these issues is the pressure the public places on companies to conform. Consumers want their stuff cheap, manufacturers find ways to make it cheap (WAL MART model). Consumers want manufacturers to stop using 16 year old from working 20 hour shifts… well, Nike will tell you what happens. And just ask Mattel what happens when products are not designed with the safety of the children in mind… swallowable magnets are hard pills for consumers to swallow.

In the end, while I agree many of these things need to be in place, the fact is that without addressing more fully the role of the manufacturers, little will change.. this plan is more of a political tool to push domestic agendas overseas. Rather than accept the role of manufacturers, this document is looking to place the onus on other countries to ensure the quality of goods. yet, they have no role in the decision. they are not the one approving product designs, deciding on metal grades, etc… that is the role of the outsourcer, and what I hope someone will do is add that into this “plan” so that the plan is holistic in nature.. not political.

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