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The CPSC simply requires firms to report whenever a product fails to comply with a consumer product safety rule, fails to comply with a voluntary standard upon which the Commission has relied, contains a defect that could create a substantial product hazard, or creates an unreasonable risk of serious injury or death...
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Thus, a product does not need to actually create a substantial product hazard to fit the reporting requirement.
It is the Commission's view that a firm should take the first step of notifying the Commission when the information available to the company reasonably indicates that a report is required...
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