CPSIA Comments, Question 6

Back to the task at hand: Question 6 is HARD! Again, please feel free to comment, and help me with these complex questions. Here goes:

"What changes in inventory control methods, if any, should be required if third-party testing of component parts were permitted. Address receipt, storage and quality control of incoming materials, management and control of work-in-process, non-conforming material control, control of rework, inventory rotation, and overall identification and control of materials."


A manufacturer would need to make sure that there is a system for labeling and tracking incoming components, and have that tracking linked to the test results and the final units.

The manufacturer must have an inventory system where untested components be kept separate from tested components. If a component is proven to be non-compliant, there must be a “quarantine” area to which workers on the floor do not have access. Then the manufacturer would need to make the determination whether to return that component to the initial manufacturer, scrap the component, or use it in a different manufacturing application.

There must be coordination between the inventory control and tracking system and the physical location in the facility. Once a component has been tested, logged, and stored that component must still be traceable to the final product by assigning batch ID#’s. For a micro-producer or artisan, this can be accomplished by supplier provided certifications, and not allowing non-compliant components into the workspace.