Discussion Points

• Submissions Requested

44. The Ministry regards mandatory product safety standards as being appropriate when other options have been considered and it has been concluded that these options would be inappropriate or are likely to be ineffectual.

45. Thus the Ministry will recommend a mandatory standard if the following criteria are met:

• there is a proven problem with the safety of a product
• voluntary action by suppliers of the product is not possible or would not be effective
• an unsafe goods notice or a compulsory product recall would not be sufficient to eliminate a safety problem or would be inappropriate
• a cost/benefit analysis demonstrates that the benefit in making a mandatory standard outweighs the cost
• a mandatory standard would solve the problem.

46. Some specific issues have been raised in this paper. To assist those wishing to make submissions they are repeated here below.

• What has been a success or weakness associated with the current Unsafe Goods Notice? In particular the stringent requirement placed on suppliers to have a current test certificate from an accredited laboratory of less than 12 months old.
• The effectiveness and possible inadequacies associated with the national standard BS 1970:2001?
• Will compliance with a mandatory standard impose additional costs on the supplier? If so, what is the nature of these costs and what monetary value do they have? Submissions should identify the range of costs involved, e.g. overheads, testing, etc.
• What are the costs associated with rubber hot water bottle injuries? Submissions should identify the range of costs involved, e.g. hospitalisation, general practice costs, home care costs (includes loss of earnings), loss of capabilities, etc.
• If you are an organisation that undertakes community-based education programmes, what are the costs involved? Submissions should identify the range of costs involved, e.g. overheads, editing, resources, artwork, publishing, distribution or dissemination etc.
• Would consumer choice be affected by a mandatory standard?

47. Comment on the criteria listed above has been made throughout this paper. However, this paper does not presume to have covered every issue relevant to rubber hot water bottle safety. The Ministry seeks the input of all interested parties to assist it in expanding the debate. To aid the Ministry's evaluation where possible, submissions should address the issues outlined above and raise any others that are considered relevant. Any information relating to costings or other commercial matters will be treated in the utmost confidence.

Submissions Requested

48. Your comments are sought on any matters raised in this paper or on any other matter that you may consider relevant to assist the Minister in her decision to develop a mandatory product safety standard for rubber hot water bottles.

49. Comments should be with the Ministry of Consumer Affairs by 9 December 2005, and directed to:

Jane Budge
Advisor - Product Safety Standards
Measurement and Product Safety Service
Ministry of Consumer Affairs
PO Box 1473
Wellington

Email: jane.budge@mca.govt.nz