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
Attachments: image002.png image003.png image005.png image006.png

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 orconcerns.

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 youLAURA FRIEND

TRANSPORTATION SPECIALIST

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