Read The Product Safety Interview
A Q&A with Prime Line CEO Rick Brenner on what distributors need to know today to ensure products they provide to clients are safe.
Rick Brenner is passionate about a topic that many people would simply rather not discuss. He’s keenly aware that many in the ad specialty market hear the word "safety" and, at best, groan and listen. At worst, they close their eyes and ears and walk away.
"Sure, I know many distributors tune out when somebody tries to talk to them about product safety, but there’s no bigger issue that the industry faces today," says Brenner, who’s the CEO of Counselor Top 40 supplier Prime Line (asi/79530). "We’re at risk as an industry, because we’re putting companies’ names on products. We’re being entrusted with that logo and that brand, so we have to take safety seriously."
And, if it’s not taken seriously, which Brenner fears many in the industry – both distributors and suppliers – are guilty of, then the risks are very high. "We’re all in this together," he says. "If there’s a big recall or some big American brands publicly question whether they want to use promotional products in their marketing because the safety risk just isn’t worth it, then it’s going to impact all of us. That’s why everyone needs to be vigilant and educated."
Brenner, a member of the board of directors of the International Consumer Product Health and Safety Organization (ICPHSO) and a founding board member of the Quality Certification Alliance (QCA), talked to Counselor about what both suppliers and distributors need to do to ensure that the industry is completely informed about product safety, and that the items it sells are safe for everyone.
Counselor: Why do many in the market shrug their shoulders when it comes to safety?
Rick Brenner: I think it’s the "it’s not my job" syndrome. Too many people believe that somebody else in the supply chain is going to handle it, but that’s a dangerous viewpoint to have. Everybody has to take some ownership of it.
Counselor: But, who really owns it the most?
Brenner: Suppliers. The burden is on suppliers to put processes in place to vet factories, test incoming products, and ensure the safety of the items they’re selling. However, that doesn’t completely exempt distributors. They need to be an active part of the process, as well. They need to become educated and make sure they’re asking suppliers the right questions and vetting them thoroughly.
Counselor: What can distributors do to take more of an active role?
Brenner: They need to ask questions – of both their clients and suppliers – that they’ve never had to ask before. Any item that’s intended for children (even if it’s not a traditional children’s item) has to be fully tested and compliant with the CPSIA law. So, distributors need to know exactly who a product is intended for. They need to ask clients precisely what the intended audience is for every promotion they’re doing, just in case children could potentially end up with the product in their possession.
Counselor: So, it’s not OK to be blind to the end-user audience?
Brenner: No. Distributors must be aware of who their clients are targeting and whether children are involved. For example, water bottles and bags aren’t technically children’s products, but if you put a Winnie the Pooh logo onto either of them, then you’ve definitely just turned it into a children’s product. Anybody who sells promotional products needs to be aware of the differences, and more importantly, be able to explain the differences to clients.
Counselor: Is some of this process just simply an education that distributors need to give to their clients?
Brenner: Ultimately, yes. But distributors also need to be interested enough in product safety and compliance so that they first get their own education. How can you educate your client if you don’t first understand the laws and regulations? You can’t. That’s why distributors really need to get involved in understanding what qualifies as a children’s product, testing, certification reports, and everything else that goes into product safety today.
Counselor: What does qualify as a children’s product?
Brenner: Broadly, it’s anything that is intended for use by children under the age of 12. However, there are interpretations to the rule that make this difficult, especially in the promotional products space. We manufacture or import many items like water bottles, bags and pens that are general-use items and would not technically be categorized as children’s products. But then we often change the nature of the item with a logo that’s placed on it or a marketing message imprinted on it. That’s why the audience a client is targeting is such important information for distributors to know about today. A general-use item can be turned into a children’s product so quickly depending on who is supposed to receive it and what’s imprinted on the item. Everyone in the industry – suppliers, distributors, clients – needs to be extremely vigilant about logos and artwork to know if a product is ultimately going to end up in a child’s hand.
Counselor: How well do you think the industry is doing today at ensuring safe products?
Brenner: We’ve made strides at the fringes, but there’s a long way to go. Large distributors and suppliers are figuring it out, but it’s still not part of the culture of the whole industry. Some suppliers are extremely conscientious, but others aren’t so diligent. They need to be extremely vigilant about testing and ensuring that the factories they’re using overseas have testing and compliance reports for every product they import to the United States. Everyone needs a heightened sense of awareness, and I just don’t think that exists yet for all suppliers.
Counselor: How about distributors’ awareness? What do they need to do?
Brenner: You need to understand everything about the suppliers you’re doing business with. Look under the hood and ask questions about what they’re doing to test their products. Do they have a full-time compliance person? What’s their testing process? What do their overseas factories do to test products? When can I come see the process in person? Get involved more by asking these types of questions and actually visiting your supplier offices to see what they do. That’s important. They need to be open to that kind of questioning and effort.
Counselor: Distributors are often rushed to get orders filled and products into their clients’ hands. Is there enough time built into the supply chain to do all of this?
Brenner: We have to make the time. Indeed, about 30% of our orders are rush, so things in the supply chain regarding testing and safety could be missed. That’s why you have to be extremely vigilant every step of the way. It has to be part of the everyday process, so that we’re not building in extra steps for safety. Safety and testing have to be an everyday aspect of what we do – for both suppliers and distributors.
Counselor: You talk about the risks that the industry faces if safety isn’t taken more seriously. What more can and should be done?
Brenner: We’ll be less at risk when the safety conversation is top of mind and part of the culture for everyone in the industry. When distributors ask clients on every single call exactly who products are intended for, then we’ll be better off. And when distributors and suppliers work in tandem so both know that products are tested and who the intended audience for an item is, then we’ll be less at risk. But these conversations just aren’t happening every day, and they really should be.
Counselor: And, ultimately, it’s better for everybody involved if these topics are discussed regularly?
Brenner: Definitely. We’re at risk as an industry because we’re putting people’s names and companies’ logos on products. We’re being entrusted with that logo and that brand image, so we’d better be secure in what we’re providing. If we’re not having these kinds of conversations throughout the whole supply chain, then we’re putting clients at risk. And, that’s the danger we face as an industry. If there’s a big recall or some big American brands publicly question whether they want to use promotional products in their marketing because the safety risk just isn’t worth it, then it’s going to impact all of us. That’s why everyone needs to be vigilant and educated.