At only the halfway point in 2016, the U.S. Consumer Product
Safety Commission ("CPSC" or the "Commission")
has already broken last year's record for total amount of civil
penalties. Thanks in part to the largest CPSC civil penalty ever
($15,450,000); the CPSC has already negotiated in excess of $23
million in civil penalty settlements. This is $5.3 million more
than 2015's $18,400,000, which was itself a record. In light of
this, and in light of recent comments by CPSC Chairman Elliot Kaye,
consumer product manufacturers really need to make sure that they
have effective strategies in place for monitoring and, if
necessary, promptly reporting potential hazards to the CPSC.
The basis for CPSC civil penalties is found in Section 15(b) of
the Consumer Product Safety Act (CPSA), which requires
manufacturers, retailers, and importers to report immediately
(within 24 hours) to the CPSC if they obtain information that
reasonably supports the conclusion that a product they
