INTRODUCTION My name is Russell Hirsch. I am the Director of Information Technology at Panline USA, dba ALEX. I joined ALEX in March, 2008. Before joining the ALEX team, I worked for IBM, Ernst & Young, BNP Paribas, and AllianceBernstein. Throughout my career I have developed software solutions relating to manufacturing analysis, regulatory compliance, and portfolio management, among others. I have 11 years of industry experience in software development and have a Bachelor of Science in Computer Science from Bucknell University. These past experiences have provided me with a wealth of knowledge that I have brought to ALEX which is especially relevant to designing robust compliance solutions that our retailers can have confidence in. Drew Metz, the Director of Product Quality & Engineering assisted me with the interpretation of the CPSIA and defined the requirements of our compliance systems, which eventually led to the creation of our compliance website, www.gcc4alex.com. Drew joined ALEX in January 2004. He is responsible for managing a continuous quality program for all ALEX products, ensuring both the safety and compliance of all products. He is an active member on the Toy Industry Association (TIA) Safety Standards and Technical Committee, where toy standards are reviewed and interpreted for the benefit of TIA members and the industry at large. Drew has over 12 years of toy industry experience including Hasbro and Hoberman Designs, Inc. At these companies, he was responsible for product design, manufacturing and IT systems implementation. Drew holds a B.S. and M.S in Mechanical Engineering from Rensselaer Polytechnic Institute in Troy, NY. Below is an attempt to educate our retailers on the design decisions that led us to the implementation of our website. We are also providing questions we asked ourselves when designing this system. We want all our important customers to understand our conclusion on how best to provide General Conformity Certificates to our retailers.
CPSIA GENERAL CONFORMITY CERTIFICATES For products manufactured on or after November 12th, 2008, the Consumer Product Safety Improvement Act of 2008 (CPSIA) has mandated that General Conformity Certificates be provided by manufactures for products shipped to retailers within the United States. The minimum required information contained within these certificates is as follows: 1. 2. 3. 4. 5. 6.
Identification of product being certified Identification of the issuer of the certificate A statement of certification to applicable standards and regulations Manufacturer (which will be ALEX in the case of domestic shipments) Date range and place of manufacture Laboratory address and phone number for tests in support of certifications
7. Individual responsible for maintaining test reports. We are providing a list of questions and answers to help you understand these new requirements. Frequently Asked Questions: Q. How and why do you track product production? A. The date range and place of manufacture are required pieces of information on all General Conformity Certificates as mandated by the CPSIA. This means that a unique certificate is required for each production batch of a product. For example a certificate that accompanied a shipment for a product manufactured in January, 2009 will not cover that same identical part number in a subsequent shipment if it was manufactured in February, 2009 . Q. For any given product on my shelf, how can I determine when the product was manufactured, so I can locate the appropriate corresponding General Conformity Certificate? A. For our products this is what we call the Production Batch ID, which is on all of our products manufactured on or after November 12th, 2008. Q: Why and how are we going to handle all these certificates from suppliers, without being overwhelmed? A. A week ago we answered a call from a retailer who was concerned that he had over 3000 SKU's in his retail store from dozens of different manufacturers and was alarmed by how many printed certificates would be needed. He was concerned with the burden imposed. The CPSC has now indicated that ‘an electronic certificate is properly “accompanying” the product or shipment of the product as required by the CPSIA if a certificate meeting the requirements…can be reasonably accessed by information on the product or accompanying the product or shipment, for example, a unique identifier, that can be accessed via a worldwide URL [webpage]. Similarly, if a reasonable means to access the electronic certificate is available to distributor(s), and retailer(s), the CPSC has indicated that the statutory requirement to “furnish” is met.’ Our website www.gcc4alex.com, as long as it can be universally and easily accessed by our retailers, and can produce, on demand, a valid certification document with all information required by the CPSIA, for a unique product in your store, is a legal and viable alternative to providing paper certificates with every shipment. There is no requirement that retailers print and maintain a hard copy of these certificates once the shipment arrives. As long as retailers have a reasonable way to furnish a valid General Conformity Certificate upon request, retailers are not required to have a paper hard copy on file. A retailer can produce and print a certification document from our website on demand if it is ever necessary. Please think of our website as an electronic filing cabinet that contains every General Conformity Certificate that you will ever require. For a given Item Number/Production Batch ID combination, a certificate generated on our website will look the same one day after the shipment arrives as it would one month after the shipment arrives, one year after the shipment arrives, or even ten years later. This means our electronic certificates behave exactly the same as a hard copy on file.
Q. What impact does this have for our retailers? A. Our retailers don’t need to do anything differently than they did before. • • • • • •
You don’t need to change your inbound receiving process to locate and file hard copy General Conformity Certificates. You don’t need to print these certifications from our website when the shipment arrives You don’t need to save an electronic copy of the certificate. You don’t need to store and organize thousands of hard copy certifications. You don’t need locate hard copy certificates inside boxes, or packing slips. No lost certificates or paper work.
Again, there is no additional time required, or any additional cost to the retailer. We have chosen to absorb the high startup cost for our compliance website, and the costs associated with ongoing maintenance and future enhancements to our website instead of raising our wholesale prices. Without providing General Conformity Certificates electronically, we would have had no choice but to raise wholesale prices across the board to cover the recurring costs associated with providing hard copy certificates. Lastly, because our shipping and receiving processes have not changed there will be no delay to outbound customer shipments. Q. Is there a legal benefit to Retailers to having these Certificates Available? A. With a Certificate available, Retailers under existing Consumer Product Safety Act provisions can rely on their supplier’s certification of compliance and are alleviated from legal liability in connection with the purchase and sale of consumer products. ENVIRONMENTAL IMPACT With the elimination of a required “paper based” certification system and provision of an electronic alternative, there is a significant beneficial environmental impact. If all manufactures provided electronic certificates like ALEX, Retailers would be able to enormously contribute to reduced paper use. CONCLUSION We put a lot of time, energy, and thought into delivering what we believe to be the industry standard in how manufacturers should provide General Conformity Certificates to retailers. Months of meetings, planning, critical thinking, design and implementation went into our website in an effort to make available to you the best possible solution with minimal impact and disturbance to your business.
If you have any questions, comments or suggestions, please feel free to contact me at anytime. I encourage an ongoing open dialog on the subject that will make this process as transparent as possible for all of you. I wish you and your family a healthy and prosperous 2009. Sincerely, Russell Hirsch Director – Information Technology 201-750-8010 x3354 rhirsch@alextoys.com