The CPSC has requested comments from interested parties regarding component vs. unit testing and supplier provided certification. I'm going to take these question by question, even though many seem to be redundant. Please feel free to use my responses as part of your own, but I do think the more varied the verbiage the better. If they hear from many of us in our own voices, maybe they will actually listen.
On to the questions:
Number 1: How the risk of introducing non-compliant product into the marketplace would be affected by permitting third-party testing of the component parts versus of a finished consumer unit.
The only risk that would be introduced into consumer goods by component testing versus unit testing would be if a manufacturer substituted a different component after the component testing was completed. Say for example a certain trim was used in the prototype and the testing was completed on that particular trim. That trim then became unavailable for production and a different trim was substituted for the production run that was similar, but untested.
Similarly, if the manufacturer embellishes the product with appliqués, roller paints, iron decals, or other such embellishments, and did not have these components tested previously, there might be a chance of introducing non-compliant components.
However, a manufacturer should be allowed to permit the certifications from suppliers for the unaltered component parts, and additionally test those components for which no testing has been performed. Then that unit should be deemed sufficiently tested. Provided the manufacturer tested each component that was part of the finished unit, and no substitutions were made, then no subsequent risk would be introduced.