Alphabet Soup of Promo Products Industry: CPSC, WBENC, ETS and QCA Webinar

Two former Consumer Product Safety Commission (CPSC) commissioners, Nancy Nord and Inez Tenenbaum, recently appeared in the news talking about two contrasting safety compliances issues. Ms. Nord expressed her thoughts about the testing burden of phthalates and what the CPSC is doing to lessen those burdens on suppliers. Simply put, if the CPSC can determine that a product will never contain phthalates then testing would not be required. Nord observed that while that may be fine for simple products like wood or fabrics where it’s easy to predict reliably that phthalates are not being used, it could be more complicated elsewhere. On a different topic, Ms. Tenenbaum talked about the benefits of having a third party conduct a recall required by the CPSC. As you’ll read in the article, one of the platforms in which she chose to publish her views was a curious (and perhaps even questionable) choice, due to their involvement in third party recall services. Commissioner Tenenbaum points out that the precautions taken regarding an in-house recall may divert attention away from other key parts of a recall plan. These parts include things like public communication, ongoing public relations efforts, and a media plan. This is in addition to the procedures involved in actually locating any defective product. Also read about QCA Distributor Advocacy Council member and SwervePoint principal Juli Sinnett, who was featured in the Women’s Business Enterprise National Council (WBENC) President’s Report and a notable achievement for ETS Express Inc. In the report, Sinnett talked about QCA accreditation and utilizing it to tier SwervePoint’s supplier base. Sinnett went one to say, “Big brands care about making sure they are not going to put their logo on something that might potentially be recalled—right now there is no vetting process in place to make sure that the vendor base is safe.” Lastly, if you missed our live webinar on corporate social responsibility, you can join Jeremy Lott, Brandon Mackay and Jon Levine for a lively and informative 55-minute session on how safety and social compliance work together in the day-to-day activities of their respective organizations. It’s an excellent opportunity to learn more about how you can make this happen for your company. This webinar will be available on demand until September, so make time to watch it when you can. Read the full story in my column for Promo Marketing here: The Alphabet Soup of the...

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Frequently Asked Questions about Compliance

For a word that means so many different things to different people, it makes sense to ensure that we’re all on the same page when it comes to our understanding of compliance. Particularly so when it comes to the manufacture and supply of promotional products, where the meaning and application of the term differs from company to company. And with the industry focus shifting more and more toward compliance, I thought that for this week’s column a review of some of the most frequently asked questions that we get about compliance might be helpful. Many suppliers have adopted a “code of conduct” but what does this really mean? In general, “code of conduct” refers to the policies a company holds related to their social accountability policy. Some companies have expanded the scope of the code of conduct to include codes of practice related to broader manufacturing concerns. A code of conduct is a step in the right direction for suppliers and manufacturers of promotional products. At the moment, the code is being treated by many suppliers as a philosophical statement and by adopting these guidelines suppliers are purportedly showing their commitment to compliance responsibility. However, in order for a code of conduct to be substantiated, this statement needs to be actively adhered to by suppliers and manufacturers. Without commitment to the journey, compliance will never have the proper guidelines that the promotional products industry requires. The factories we use have certifications from World Responsible Accredited Production (WRAP) and Fair Labor Association (FLA). How does this fit into compliance? While many suppliers and manufacturers use WRAP and FLA programs, they really only address one area of compliance – social accountability, which is just part of the picture. To truly ensure that everyone in the promotional products industry upholds the same values and responsibility, there needs to be commitment to a code of conduct to compliment these programs. While social accountability is a good starting point for the industry, these programs alone don’t constitute a fully developed compliance program required for conducting business in today’s market. Some companies rely on factory audits to measure compliance. Is this enough? Undoubtedly, factory audits are an important tool to measure a company’s ability to adhere to social responsibility guidelines.  However, factory audits as a sole means of measuring compliance don’t address other equally important areas of compliance, such as product safety. Factory audits only...

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Promotional Products: The Importance of Transparency and the Supply Chain

I had a chance to spend time recently with Stephanie Leader, President and CEO of Columbus, Ohio-based distributor LeaderPromos and we spoke about the importance of transparency and the supply chain as it relates to promotional products. By virtue of our mission at QCA, we focus a great deal on the collaborative effort between suppliers and distributors to present a transparent supply chain to end users who are increasingly asking more difficult questions. Stephanie provided some valuable insights about what she sees from, and with, her customers. Here’s our conversation: Transparency is the new normal with promotional products clients. What do you think is the most important thing a supplier can do to help you along that path? Our clients are asking for more transparency. Our suppliers need to understand that if clients want transparency with regard to the supply chain, our focus is on delivering just that. And if suppliers don’t understand that, and aren’t proactive about being able to deliver transparency, they’re quite likely not suppliers we would work with. That’s why we’re supporters of QCA accreditation, but that’s not the only thing I want to discuss. In short, though, the accreditation is for the process that includes suppliers’ factories, corporate facilities, and supply chain so that we have the necessary information we need. It’s both for our own peace of mind about the integrity of the supply chain, and peace of mind and assurances that we can pass along to our clients. Some suppliers struggle with the whole transparency issue, for a variety of reasons, but often because they often don’t want to give up information about their chosen manufacturers and their processes. That’s obviously their prerogative, but it’s a choice that comes with no small amount of risk. By comparison, the people who we do business with, they’re all about accountability throughout the supply chain. In fact, they actually come in and they perform their own audits, in addition to outside audits or accreditation. How does transparency impact your customers? For our customers, transparency makes all the difference. For them, knowing our processes and the steps we take ahead of the curve, and that the suppliers we work with have been audited, and that we only affiliate with these types of companies helps earn their confidence and trust. They get a real sense of what our focus is as a company and understand that we...

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Promotional Products Industry: Balancing Risk and Reward

Recently, I spent some time with the Ohio Promotional Professionals Association at their “Promotions At the Bay” event. While I was there, I spoke to a group of both suppliers and distributors about some research I’d done on recent Consumer Product Safety Commission fines for the presentation. The latest update to the CPSCIA is anything but light reading, but provides much insight into the agency’s current direction. Many of the folks that attended the OPPA event are sales reps who are out in the trenches, actually making the sales of promotional products on a day-to-day basis. But the fact is, not everyone sells to the Fortune 500 end-user every day. Likewise, not every company ships product to California, where it’s imperative to understand and deal with PROP65 concerns. And, of course, not everyone works for an organization with unlimited resources for monitoring the thousands of regulated chemicals and products, as well as the many changes made by the CPSC and Food and Drug administration. So, for me and my team, one of our biggest challenges is the question of how we can help those promotional product reps actually making the sales and working with limited resources make it part of their decision to deliver safe and socially compliant product? It’s all in the balance of risk and reward. The Basics of the Risk and Reward Equation When you’re evaluating a potential customer relationship or a sale and thinking of it in the terms of risk and reward, simply consider these three questions: What does my company expect? What does my customer expect? What does the state of destination require? Let’s First Consider The Risk The CPSC lately has turned to widely publicized fines, rather than simply creating new regulations, to gain more attention for product safety responsibilities. Not every situation merits a $3.9 Million fine like repeat offender Ross stores, or the $400,000 fine to Kolcraft, or $987,500 to Williams-Sonoma. But every situation could result in a personal civil penalty of $100,000 per violation (Well, that’s getting serious, isn’t it?). Unless, of course, there is a death involved with a product failure. Then the fines go to $250,000 per incident for individuals and $500,000 per incident for companies. In short, choosing to sell a product that does not have a readily available certificate of conformity means the question becomes, “is it worth that risk?” Risk has a way of finding...

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Register Now For PPAI Product Safety Summit

Register Now For PPAI Product Safety Summit

Product safety doesn’t just make good business sense—today’s consumers and clients are becoming increasingly vocal about choosing products that are safe and reliable. And if you’re in the promotional products industry, the upcoming PPAI Product Safety Summit is an ideal opportunity to focus on the most pressing product safety issues facing businesses today, as well as the business implications, challenges and opportunities associated with compliance. Held from August 14-15, the PPAI Product Safety Summit offers a combination of keynote presentations and smaller sessions designed to explore product safety developments and best practices that you can apply to your own product process and safety strategy. You’ll hear from industry thought leaders, as well as representatives from product safety labs and product certification groups, to give you a comprehensive view of product safety and compliance and why it’s a critical area of focus in today’s marketplace. The summit will begin directly after the North American Leadership Conference on August 13th, 2013 and will feature keynote speaker Neal Cohen, CPSC. Neal is the current Small Business Ombudsman at the U.S. Consumer Product Safety Commission (CPSC) and works with the CPSC to provide educational and outreach materials to the CPSC-regulated industry community. Interested in a closer look at the summit and why you should consider attending? Check out this video from PPAI: Business trends may come and go—but product safety and compliance aren’t among them. As PPAI says, “Corporate social responsibility and compliance aren’t the future or a fad. Your clients expect compliance now.” Seating is limited at the summit, so be sure to register online and secure your spot now. And once you’re registered, check out PPAI’s discounts on hotels and airfare. We’re already packing our bags for the Windy City. Join us, won’t you? Image: ` TheDreamSky via Compfight...

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Getting Started with QCA: A Quick Reference Guide

Getting Started with QCA: A Quick Reference Guide

In today’s rapidly evolving marketplace, regardless of the industry in which you operate, safety is no doubt a primary concern. For those in the promotional products manufacturing business, safety is only one of several pertinent issues that companies must address and implement. An effective solution? QCA Accreditation, an all-encompassing solution that protects brand equity throughout the supply chain, boosts your brand reputation and increases buyer confidence. That invariably leads to increased revenues and greater profitability. If you’re considering QCA accreditation, we hope you’ll explore the myriad of benefits available through this certification. At QCA, we are your partner and your guide when it comes to safety, compliance and social responsibility. QCA Application and Accreditation Information Now that you understand the benefits of QCA Accreditation, you’ve likely got some questions and want to know what’s next. First, the questions: How long is the accreditation process? The QCA Accreditation process varies for each company but can, on average, take 15 to 18 months to complete. How much does it cost? QCA Accreditation is priced on a fee schedule that’s calculated according to annual company revenue. For complete details, please see the QCA Accreditation fee schedule. What can we expect as part of the process? The QCA Accreditation process includes a third-party testing organization that evaluates performance of each facility submitted by a QCA Applicant for Accreditation. Each QCA Applicant facility will receive an overall assessment based on a numeric score compiled from the compliance scorecard. Once all five areas of compliance are approved or approved with corrective action, a third-party audit of the supply base will commence. What happens after accreditation? Are there ongoing fees and certifications required? QCA Accreditation and the QCA Seal of Approval are given to certified suppliers for an initial two-year period. In the second year, random maintenance audits will be performed as part of ongoing checks and balances established to validate the QCA Certification Program. We hope you’re now ready to get started with the QCA Accreditation process for your company. Follow these four steps and you’ll be on your way: Download the QCA Accreditation application and complete it. Sign the self-certification letter. Review the fee schedule to determine your application fee. (Application to QCA is non-refundable). Send your completed application, self-certification letter and check for application fee (credit cards are not accepted) to: Quality Certification Alliance PO Box 446 Seattle, Washington 98111 Once the application...

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