Consumer Federation of America, Consumer Reports, Kids In Danger, U.S. Public Interest Research Group, and National Center for Health Research welcome the opportunity to submit comments to the U.S. Consumer Product Safety Commission (CPSC, Commission, or agency) regarding the proposed rule for disclosure of interests in commission proceedings. Our organizations support the CPSC’s proposed rule and offer the following comments.
Founded in 1972 as an independent federal agency, the CPSC works to save lives and keep families safe by reducing the unreasonable risk of injuries and deaths associated with consumer products. Transparency is integral to this work. To that end, the agency proposed to establish disclosure requirements for persons and organizations seeking to make certain appearances before the Commission. The proposed rule will promote transparency and fairness, help to better identify potential conflicts of interest, ensure the agency’s decisions and actions are in the public’s best interest, and address unreasonable risks consumer products may pose. Recently, participants testified before the Commission representing themselves as a parent-focused group without disclosing that their association also included representatives from regulated industry and urged the agency to refrain from engaging in any regulatory action. This instance is just one example that demonstrates the need for this proposed rule to ensure greater transparency. It is important for the Commission and the public to know if regulated industry is financing or writing the testimony or presentation of a proposed participant.
To read the full comments, click here.