The US Consumer Product Safety Commission (CPSC) should enforce existing standards, reduce the cost burden of testing and put more emphasis on cost benefit analysis, according to the American Apparel & Footwear Association (AAFA).

Michael McDonald, manager of government relations at the AAFA, made his comments in written testimony to a hearing on CPSC priorities and strategies for fiscal 2014 and 2015.

Describing product safety as a “top priority” for his members, McDonald said the commission’s strategic goals were “commendable”, but made three main suggestions.

Firstly, he echoed previous AAFA comments that there should be a stronger emphasis on cost benefit analysis in rule-making, to help direct scarce resources and targeted responses towards addressing the greatest risks and hazards.

McDonald also urged full implementation of Public Law 112-28 on reducing the burden of third party testing, nearly two years after the law was enacted.

“As far as tangible burden reduction we have been, quite frankly, disappointed with the progress that has been made,” he said, noting that most suggestions from the AAFA had not been acted upon.

Finally, McDonald said the CPSC must ensure that existing standards, particularly laws covering children’s sleepwear, should be properly and fairly enforced.

“Uneven enforcement undermines the effectiveness of well-developed product regulations,” he noted. 

“In the case of children’s sleepwear, we have provided the Commission with examples of non-compliant children’s sleepwear that remains on the market and continues to be sold year after year.

“The presence of non-compliant product raises fundamental safety issues and creates unfair competitive advantages.

“It is for this reason that we strongly encourage the CPSC to look at its policies regarding industry communications.”