From: House, Mary

To: Heggs, Angela

Cc: Lee, Arthur

Subject: FW: confirmation and 2 questions re: CPSC Proposes to Add Certain Seasonal Lighting Goods to Substantial

Product Hazard List -

Date: Monday, October 20, 2014 8:05:03 AM

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Please post to the docket for the seasonal and decorative lighting products proposed rule. Thank

you!

From: Lee, Arthur 

Sent: Friday, October 17, 2014 3:27 PM

To: Laura Friend

Subject: RE: confirmation and 2 questions re: CPSC Proposes to Add Certain Seasonal Lighting Goods

to Substantial Product Hazard List -

Hi Laura,

That is correct, if the products have all current and legitimate markings, certification mark from

UL, Intertek Co (ETL), or the CSA Group, or products carrying a listing for UL 588 would be

considered conformance with the proposed rule.

Does the propose rule require any additional paperwork (certificates, permits, etc)?. No. A 15(j)

rule is not a consumer product safety rule and does not create a consumer product safety

standard. Thus, the rule does not trigger any testing or certification requirements under section

14(a) of the CPSA

What is meant by readily observable? This is tricky and I think I’m going to quote from the

proposed rule under Section A. Background and Statutory Authority 

The Commission did not define a “readily observable” characteristic in either

[previous] rule. In the proposed drawstring rule (75 FR 27497, 27499, May 17, 2010), the

Commission

found that the requirements detailed in the relevant voluntary standard could be evaluated with

“simple manipulations of the garment, simple measurements of portions of the garments, and

unimpeded visual observation.” The Commission stated: “more complicated or difficult actions

to determine the presence or absence of defined product characteristics also may be consistent

with ‘readily observable.’” Finally, the Commission stated its intent to evaluate “readily

observable” characteristics on a case-by-case basis. 75 FR at 27499.

That is correct, all 3 readily observable characteristics need to be met for the products in the

proposed rule

I hope that answers your questions. Please contact me if you have any additional questions or
concerns.

Arthur Lee

US Consumer Product Safety Commission

Directorate for Engineering Sciences

Division of Electrical Engineering

5 Research Place

Rockville, MD 20850

301 987-2008

alee@cpsc.gov

From: Laura Friend [mailto:lfriend@hayneedle.com] 

Sent: Friday, October 17, 2014 2:01 PM

To: Lee, Arthur

Cc: Laura Friend

Subject: confirmation and 2 questions re: CPSC Proposes to Add Certain Seasonal Lighting Goods to

Substantial Product Hazard List -

Good afternoon Arthur. My name is Laura Friend and I work for an e-retailer Hayneedle.com. I am

enquiring about the CPSC proposed rule to add certain seasonal lighting goods to the substantial

product Hazard List 

My original question to my compliance contact; will there be some type of documentation required

with the imported commodity such as a certificate and/or special marking on the cartons. After

reading the notice in the Federal Registry I believe this question was answered but would like to

confirm. 

Can you confirm:

· that all current marking, certification mark from UL, Intertek Co (ETL), or the CSA Group, or

products carrying a listing be considered conformance with these requirements

· the proposed rule does not require any paperwork (certificates, permits, etc)

2 more questions:

1. What is meant by readily observable

2. Do all 3 readily observable characteristics need to be met

I look forward to your response.

Thank you
LAURA FRIEND

TRANSPORTATION SPECIALIST

....................................................................

9394 WEST DODGE ROAD SUITE 300 OMAHA, NE 68114-3319

T: 402.715.3333

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