May 3, 2010
Partner Christie Grymes Thompson was interviewed in the GC Agenda section of the May Practical Law The Journal regarding product safety audits. Ms. Thompson recommended that companies should review their product safety compliance programs in light of a new Consumer Products Safety Commission (CPSC) final rule interpreting the factors to be considered when seeking civil penalties for knowing violations of CPSC laws. The final rule, which is a requirement of the Consumer Products Safety Improvement Act of 2008, identifies and provides guidance on the factors the CPSC may consider in determining penalty amounts for violations of the Consumer Product Safety Act, Federal Hazardous Substances Act and Flammable Fabrics Act. Ms. Thompson identified the non-exhaustive list of factors the CPSC may consider in addition to factors already specified in the relevant statutes.