Consumer Product Safety Improvement Act (CPSIA)

The Consumer Product Safety Improvement Act of 2008 (CPSIA) changes the operating landscape for many manufacturers, retailers, and distributors. Modifications to the role of the Consumer Product Safety Commission (CPSC) have changed the responsibilities, duties, and accountability of these parties with respect to the performance, testing, advertising, and tracking of consumer products, particularly children’s products. Exponent scientists and engineers have contributed to the scientific body of work relevant to key topics addressed by the Consumer Product Safety Improvement Act of 2008, including the communication of safety information (e.g., alongside advertising), children’s ability to access product components, standards application and testing, corrective action plans for products, the tracking and analysis of injury and consumer complaint data, exposure testing methods and protocols, and health effects of low levels of lead and phthalates in products.

Exponent’s Human Factors, Engineering, and Health Scientists have in-depth experience in drawing on sound science and engineering practices to help clients meet the highest standards of safety in the evolving regulatory landscape.

In February 2009, new requirement of the CPSIA take effect. Manufacturers, importers and retailers are expected to comply with the new congressionally-mandated laws that include the following:

  • Beginning February 10, 2009 children’s products cannot be sold if they contain more than 600 ppm total lead, even if they were manufactured before this date. The allowable level for lead is lowered to 300 ppm by August 2009 and may be lowered further in 2011 to 100 ppm, if technologically feasible. 
  • Certain children’s products manufactured on or after February 10, 2009 cannot be sold if they contain more than 0.1% of specified phthalates or if they fail to meet new mandatory standards for toys.


Our services include:

Human Factors and Engineering

  • Analysis and interpretation of reports of harm relating to a consumer product 
  • Investigation of whether a product complaint is materially accurate 
  • Design of cautionary statements for product advertisements shown on internet sites, catalogs, and other locations 
  • Assessment of the effect of product warnings at point of sale on purchasing decisions and user behaviors 
  • Testing the conspicuity and comprehension of safety information 
  • Evaluation of difficulty of child access to product components 
  • Design, administration, and analysis of consumer-product interaction studies 
  • Assessment of developmental and age appropriateness of products or activities 
  • Development of Corrective Action Plans 
  • Assistance in developing internal standards, testing programs, product databases and tracking procedures 
  • Assessment of impact of public safety campaigns


  • Analysis and interpretation of harm relating to chemicals in a consumer products 
  • Evaluation of potential exposure based on product handling and exposure simulation studies 
  • Analysis as to whether available data demonstrate a potential health hazard - including bioavailability studies and Physiologically Based Pharmacokinetic (PBPK) modeling
  • Strategically-targeted lead and phthalate product testing programs 
  • Lead and phthalate toxicity and exposure studies 
  • Evaluation of product exemptions based on inaccessibility or lack of adverse impact on public health or safety

Exponent offers scientific guidance as to how the recent Consumer Product Safety Improvement Act of 2008 and its reauthorization and modernization of the CPSC may affect clients’ operations and responsibilities. An understanding of scientific research relating to children’s abilities and their use of products, chemical toxicity and exposure issues, the validity and reliability of consumer complaint data, and the effectiveness of warnings in product materials allows Exponent scientists to advise as to the most appropriate, scientific-based responses to these far-reaching regulatory changes.



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