Approximately three-fourths of product safety recalls in the United States are the result of some design flaw in the product rather than a manufacturing or other defect. Most violations of the U.S. Consumer Product Safety Commission (CPSC) “small parts” standard, for example, are the result of nonexistent or inadequate design-hazard review, not defective materials or production techniques.

The CPSC is now preparing to propose the most significant product safety testing and certification regulations in its history, yet there is little mention of the importance of proper design-hazard analysis in product development and response to safety problems that arise. After spending a career successfully helping companies avoid product safety problems before they arise, I believe this is an oversight the commission must address.

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