While firms may report such matters without fear of penalty, the staff will still seek corrective action when such action is needed to protect the public from a possible substantial product hazard. Some firms have expressed concern that the preliminary determination, although not a formal hazard determination of the agency, could have a negative impact in their product liability cases or on their reputation. This pilot project does not modify firms' reporting obligations. At the end of the pilot period, the Commission will evaluate the effectiveness of this initiative and determine whether it should be extended. Currently, many firms do not submit complete information.
Firms sometimes omit copies of complaints and claims.
This information is crucial for the staff to properly evaluate the problem and the firm's corrective action. The staff will not allow firms that do not report fully to participate in this pilot program. Advises the staff it wishes to undertake an expeditious corrective action under the pilot program. Submits a proposed corrective action plan in sufficient time for the staff to review the plan, analyze any replacement product or repair, and work out the details of the corrective action with the firm so that the plan can be implemented within 20 working days after the filing of the report. CPSC staff must have sufficient time to review the information and meet the 20 working day time limit.