Why is the term “Reasonable Testing Program” (RTP) sometimes used for both CPSIA Certification Programs of children’s products and general use products?
The certification program for non-children’s products was called a “Reasonable Testing Program” in CPSIA. Since the children’s product certification program did not have a specific name in that draft, the term “Reasonable Testing Program” has become a common name for any certification program encompassing children’s and general use products. However, under the regulations, a general use product specifically falls under a RTP and a children’s product falls under a “children’s product testing program” (CPTP).
Should I implement a Reasonable Testing Program for my product when that section has been reserved?
The CPSC was not required to create a rule for the certification of non-children’s products such as apparel and hardgoods but CPSIA states any non-children’s product with an applicable rule, ban or standard enforced by the CPSC must be certified based on a Reasonable Testing Program. Therefore, a manufacturer not implementing a Reasonable Testing Program would not be in compliance with the certification requirements of CPSIA.
Will the requirements of a RTP or CPTP be retroactive?
The requirements will apply to products manufactured on or after the effective date as designated in the final rule so it will not be retroactive.
I manufacture general use products that do not require certification or General Conformity Certificates (GCC). Do I need to implement a RTP?
No. Only general use products that require certification or a GCC require a RTP. However, it could be beneficial for your company to implement some or all of the program elements to help ensure good manufacturing procedures.
I manufacture children’s sleepwear. Does this change the sampling requirements of 16 CFR 1615 and 1616?
The CPSC has stated that the requirements of a RTP and CPTP would not supersede any established requirements of an existing rule, ban or standard. Your children’s sleepwear will still need to be tested in accordance with 16 CFR 1615/1616, including testing every 5,000 linear yards which can be part of the periodic testing plan, and comply with the other elements of a CPTP.
What is the intent of the product specification under a Reasonable Testing Program?
The product specification has several purposes: to differentiate the product from other consumer products; to provide identifying manufacturing information; and to list all applicable rules, bans and standards applicable to the product.
What is the difference between using your own product specification rather than the RTP specification?
Many companies produce product specifications for goods they manufacture. If particular product specifications meet the requirements mandated by the RTP, they may be used. Otherwise, it would be necessary to supplement the company product specification with any requirements missing that are mandated by the RTP.