Helping Clients Avoid and Solve
Consumer Product Safety Problems

Big Law Firm Experience with Small Law Firm Benefits

Helping Clients Avoid and Solve Consumer Product Safety Problems

Avoid Problems

Get help complying with federal, state and international mandatory and “voluntary” consumer product safety and chemical content requirements.

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Timely and Practical Solutions to Problems

Recognize and timely resolve product safety problems that arise, reducing the likelihood that a compliance issue will become a public relations problem or lead to product liability litigation.

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Protect Your Company’s Valuable Assets

Gain the benefit of our 30 years of experience to protect your company, its brands, products and commercial and consumer relationships. Your products will have enhanced appeal, because safe and chemically-compliant products sell.

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Helping Clients Avoid and Solve Consumer Product Safety Problems

Avoid Problems

Product Safety and Chemical Content Compliance—CalletLaw clients get succinct advice on how to make their products compliant with the ever-increasing federal, state and international product safety and chemical content requirements so that products can be sold throughout the United States and worldwide. Because published lists of requirements are often not sufficient, CalletLaw clients get a sophisticated, coordinated plan of action for complete product safety compliance.

CalletLaw clients get answers to questions like:

  • Which mandatory product safety requirements apply to my company’s products?
  • How do the U.S. Consumer Product Safety Improvement Act’s (“CPSIA”) third party testing and certification requirements affect my company’s products?
  • What do state and local laws concerning “Chemicals of High Concern” mean for my company’s products, particularly if the company sells children’s products?
  • What can I do to reduce the risk that my company will receive a California Proposition 65 “60-Day Notice” about one of our products?
  • What will the recently-revised U.S. Toxic Substance Control Act (TSCA) mean for chemicals that may be used in consumer products?

CalletLaw clients also get advice on how “voluntary” product safety standards affect their products and how to build product safety into their product development cycle.

Timely and Practical Solutions to Problems

Duty to Report Potential Product Safety Issues to the CPSC—With the CPSC’s enforcement efforts dramatically increasing and companies agreeing to multi-million dollar civil penalty settlements, knowing when a Consumer Product Safety Act Section 15(b) Report must be filed with the CPSC, and a corresponding report filed with Health Canada, has never been more important.

CalletLaw regularly advises clients on when the company’s reporting obligation to the CPSC has been triggered. This determination can be difficult and should not been made without counsel experienced in practice before the CPSC. On one hand, filing a Section 15(b) Report often results in the CPSC “encouraging” the company to conduct a product recall, which can have negative impact on the company’s valuable brand. On the other hand, failing to timely file a Section 15(b) Report, when required to do so, can result in the CPSC initiating a civil penalty investigation against the company for late reporting, with civil penalties up to $15.15 million at stake.

Not every filing of a Section 15(b) Report leads to a recall of the company’s product. CalletLaw helps clients that have filed a Section 15(b) Report know when to agree to a product recall and when to dispute the CPSC’s claim that remedial action is necessary.

Product manufacturers and retailers can have different views about when a Section 15(b) Report should be filed and whether/what type of remedial action should be taken. CalletLaw regularly represents clients in both categories and helps them protect their interests before the government while maintaining their valuable commercial relationships.

A limited product safety issue, particularly when a Section 15(b) report has been filed, can morph into a larger product safety problem and even a public relations problem for a company. CalletLaw provides strategic counsel on how to limit the impact of a potential or actual product safety problem on the company.

Product Recall

Meeting Obligations While Minimizing Commercial Disruption—When a product recall becomes necessary, CalletLaw helps clients meet all recall requirements, while limiting the recall’s economic impact on the company. Equally important, CalletLaw strategic advice helps clients to reduce the potential that the product recall will unduly impact the company’s operations, consumer and commercial relationships, and the reputation of the company’s valuable brands.

Our Products Have Been Stopped at the U.S. Border. Now What?

Your company’s products are scheduled to be on retailers’ shelves shortly, but they have been held up at the border by the U.S. government and you have received a CPSC Notice of Non-Compliance for an alleged product safety violation. CalletLaw can help get your product released and avoid having this initial product safety issue become a larger problem for your company.

California Proposition 65

CalletLaw helps companies develop a strategy to become a “hard target,” reducing the risk that the company will receive a California Proposition 65 “60-Day Notice” about one of its products. When a client receives a Prop 65 Notice, CalletLaw advises on what type of response to the Notice is most appropriate for that company. Many clients want to resolve the notice as inexpensively as possible. Others clients want to develop the scientific evidence necessary to defend their products to show that no Prop 65 warning need be put on the product. Calling upon extensive products liability litigation experience, CalletLaw is adept at either strategic approach in response to a Prop 65 Notice.

CPSC Civil Penalty Investigations

After a product recall, the CPSC often investigates to determine whether the company conducting the recall timely reported under Section 15(b) of the CPSA. The CPSC also investigates companies for patterns of non-compliance with product safety requirements. These investigations can be burdensome, as the CPSC’s investigatory requests are often quite extensive. CalletLaw has successfully convinced the CPSC to drop a civil penalty investigation of its clients. Where appropriate, CalletLaw provides a response that can reduce the likelihood that a CPSC investigation will result in a civil penalty proceeding. If the CPSC insists in pursuing a civil penalty, CalletLaw has experience in negotiating a CPSC civil penalty agreement.

CalletLaw also assists clients by helping them develop a Product Safety Compliance Program to reduce the possibility that they will be subject to a CPSC investigation in the first place.

Protect Your Company’s Valuable Assets

Developing a Product Safety Compliance Program is an Important Proactive Step that Can:

  • Reduce the risk that a product safety problem will occur
  • Help your company recognize when a product safety problem has arisen
  • Assign the appropriate personnel to address the problem with an appropriate plan of action
  • Ensure that timely Section 15(b) Reports are filed with the CPSC and equivalent reports with Health Canada and EU authorities, when necessary; and
  • Address the issues that caused the product safety problem to occur in order to avoid reoccurrence of similar product safety problems.

Crafting a California Prop 65 “Hard Target” Strategy

Companies find complying with California’s Prop 65 confusing and often frustrating. CalletLaw clients frequently ask whether they need to put a Prop 65 warning on products. CalletLaw helps companies develop a strategy to become a “hard target,” reducing the risk that the company will receive a California Proposition 65 “60-Day Notice” about one of its products.

Create a Reasonable Testing Program

This Program is designed to help your company comply with the Consumer Product Safety Act and the CPSC’s Part 1107 Testing and Certification Regulations, including the requirement to test a “sufficient number” of “representative” product samples to give your company a “high degree of assurance” that its children’s products are compliant with all substantive and procedural CPSC-mandated product safety requirements.

Establish a Product Recall Preparedness Program

Companies should not wait until a product recall decision has been made to consider how to conduct a recall. If a product recall becomes necessary, a well-designed Product Recall Preparedness Program will reduce the impact of that recall on your company, its consumer and commercial relationships, and the reputation of your company’s valuable brands.

Reduce the Likelihood of Product Liability Litigation

To help clients reduce the risk that products will be subject to product liability claims, CalletLaw reviews companies’ existing products and those in the product design and development phases. Products are evaluated for how they function in the real world and whether the product use instructions, labeling and warnings are adequate.

Educate Your Company’s Personnel on Consumer Product Safety Compliance

CalletLaw has presented numerous in-depth product safety seminars and webinars over many years. Thousands of people have attended these seminars, many returning year after year. Why? Because David Callet gives a good presentation. He has a facility for taking this complex subject and making it understandable, and yes, even interesting and entertaining. You can’t say that about most product safety presentations! CalletLaw can provide one of these understandable, interesting and entertaining product safety compliance educational programs specifically designed for your company and its products.


DaviD P. Callet


David P. Callet

David Callet provides comprehensive client representation on all aspects of consumer product safety compliance. He guides clients on how to create and implement product safety compliance programs that reduce product recalls, limit products liability litigation, and help protect their valuable brands from adverse publicity associated with non-compliance with product safety requirements. He regularly represents clients in matters involving the U.S. Consumer Product Safety Commission (CPSC), including:

  • compliance with the Consumer Product Safety Improvement Act (CPSIA), including the creation of CPSC-mandated Reasonable Testing Programs;
  • determining when a “substantial product hazard” exists and when a duty to file a Section 15(b) report with the CPSC arises;
  • implementing a U.S. or worldwide recall of a product with a minimum of business disruption, when a recall is required;
  • preventing a recall or other product safety compliance matter from becoming a public relations issue or leading to products liability litigation;
  • CPSC civil penalty proceedings and related matters.

David also counsels clients on compliance with state consumer product safety and chemical composition laws, especially California’s Proposition 65, and product safety labeling and warnings.



CalletLaw LLC
5335 Wisconsin Ave, NW Suite 440
Washington, DC 20015

DIRECT: 240-396-6739
DIRECT: 202-478-6297