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 May 17, 1999 Office of the Secretary Re: NPR for Bunk Beds Dear Madame Secretary: I write to express the views of The Society of the Plastics Industry, Inc. (SPI) regarding the Commission's March 24 invitation for comments on "what constitutes substantial compliance with a voluntary standard." SPI is the principal trade association for the U.S. plastics industry, with more than $275 billion in annual shipments, over 15,000 companies and 1.3 million employees. Plastics products are subject to literally thousands of different standards in the U.S. alone due to the breadth and diversity of their uses. We strongly support the Consumer Product Safety Commission's strong, historic reliance on the U.S. voluntary standards as the best way of assuring safe and reliable products for American consumers. A tribute to the success of that system is the fact that there is a movement underway internationally to emulate it. However, we are concerned that the Commission is considering making modifications in the manner in which it relates to the voluntary standards system. Specifically, we do not believe that there is justification for a rigid, formalistic approach to defining when there is and is not substantial compliance with a voluntary standard. To take such an approach would undermine the integrity of the voluntary standards system. Further, such an approach would require the Commission to promulgate more mandatory standards that it is either capable of doing or can be justified by cause. The voluntary standards process in this country has served the American consumer well. However, it would not in the consumer's best interest for a federal regulatory agency to create a circumstance that replaces a system that is working well with one that would lead to confusion, confrontation, and potentially undermine U.S. competitiveness. Safety would not ultimately be well served by such an action. Sincerely,
Lewis R. Freeman cc: Chairman Ann
Brown More
Public Policy: Environment
. Worker Safety . Transportation
. Codes and Standards . Food,
Drug,and Cosmetic Packaging . International
Trade
. Other Issues
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 © Copyright 2001 The Society of the Plastics Industry.
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