This column in the July issue of PPB introduced Michelle, a newbie compliance manager at Golfster Promo, a leading golf products supplier. She was struggling with the challenges of getting compliance testing done on one of her products. This month, we catch up with Michelle as she is about to authorize a shipment of 20,000 golf towels made at a Chinese factory. The towels measure 16 x 24 inches and are made of double-sheared cotton terrycloth with the embroidered logo of a Fortune 500 company sponsoring a prestigious, nationally televised professional golf tournament. The quality of these towels is a top concern to Golfster Promo because the sponsor has made a huge fuss in demanding the best quality in materials and workmanship for this item.
What are Michelle’s options in ensuring that the towels will meet the sponsor’s high quality expectations? Of course, she can do nothing and hope that the towels arrive in good shape at Golfster’s warehouse next month. However, after suffering through a restless night with a terrible nightmare about receiving 20,000 used shop towels with the sponsor’s logo poorly screen printed on them, she decided to reach out to her client service manager at her third-party testing lab for some advice.
The lab’s customer service rep patiently explained the benefits of conducting a pre-shipment inspection of the towels before Michelle issues her approval to the factory to ship the goods. The lab quoted her only $300 per work day for one person plus OOP (out of pocket) costs to cover the inspector’s local travel costs, including taxi, bus, train travel and overnight stay expenses if needed to conduct the one-day inspection. For about $350 USD, Michelle believed this was cheap insurance to confidently and competently reduce the risks of receiving a shipment of non-conforming goods.
Michelle promptly filled out the lab’s Inspection Request Form and prepared a detailed list of inspection specifications to advise the inspector of Golfster’s (and the client’s) quality expectations for the golf towels. The towels had previously passed testing for safety and performance criteria such as flammability, fiber content, fabric thickness and weight, dimensional stability (lab speak for shrinkage) and colorfastness. The one thing Michelle feared most was the factory doing a bait-and-switch by shipping inferior products at the last minute. She would have a catastrophe on her hands if this happened.
As a best practice, there are typically three stages during a product’s production cycle when a quality inspection should be conducted:
- Top Of Production (TOP) Inspections are product evaluations performed at the start of production for conformance with customers’ specifications. A TOP inspection is typically done when a new factory or supplier is engaged, and it serves as a useful tool to gauge the factory’s initial performance and understanding of QC requirements.
- During-Production Inspections (DUPRO) can be performed at various manufacturing points after production has started, but before a substantial portion of an order is completed. This inspection helps to reveal any nonconformities early in the manufacturing process in order to address issues without jeopardizing the shipping schedule.
- Pre-shipment Inspections (PSI) help to verify product quality, packaging, product labeling and carton markings before the product leaves the factory. Although the PSI may occur too late should the goods fail the inspection, it at least helps the importer avoid the surprise and disappointment of receiving poor-quality goods after pre-payment and shipment. Oftentimes, just having the factory know that a PSI will take place prior to shipment will be enough “motivation” for the factory to use extra care in making the goods to meet the customer’s expectations.
In Michelle’s case, there was just enough time to have a PSI done before the scheduled ship date. She decided, with the lab’s help, that the inspector should use the general criteria of the ANSI/ASQ Z1.4-2008 standard, a Normal Single Sampling Plan, and General Audit Level II to conduct the random sampling for the inspection. Pre-shipment Inspections are typically done when the order is 100-percent completed but with at least 80 percent of the goods packed.
Waiting until the entire order is 100-percent complete provides assurance that the sampling process can be reliably conducted by the inspector and none of the order is intentionally left out of the inspection process by the factory. Based on the order size of 20,000 pieces and the lab’s recommendation in using the General Audit Level II, the sample size will be 315 pieces. Using a standard formula, all 315 samples will be randomly selected from the total number of cartons available for inspection. Each sample will be thoroughly inspected by the trained inspector using the specifications provided by Michelle.
In order to objectively determine whether the goods will conform to the client’s quality specifications, the inspection will be conducted using an Acceptable Quality Level (AQL) for workmanship that the lab recommends for these towels. The AQL is defined as the maximum percent of defects that, for the purposes of sampling inspections, can be considered satisfactory as an average for defects that are being shipped to the customer. Defects are categorized according to critical, major and minor defect classifications and are defined as follows:
- Critical Defect: This is a defect that fails to meet mandatory regulations and/or affects the safety of the consumer.
- Major Defect: This is a defect that will likely result in product failure, a reduction in product usability or renders the product unsellable to the consumer.
- Minor Defect: This is a defect that is not likely to reduce the usability of the product, but is likely to reduce the item’s selling potential, or is any minor discrepancy from the established acceptance limit for the product.
As a last step in her pre-inspection preparations, Michelle carefully examined the customer’s quality expectations for the towels and, with the help of the lab’s general inspection guidelines, was able to compile her own set of specific inspection criteria for each of the following categories:
- Aesthetic appearance
- Manufacturing specifications
- Colors/embroidery work
- General safety considerations
By the end of the day, Michelle had sent her inspection specifications by e-mail and a few approved reference samples by express courier to the China-based inspection team to use in the inspection. A week later, much to her relief, Michelle received an e-mail from the lab’s inspection manager informing her that the towels had passed inspection with only a handful of major and minor defects. No critical defects were found. Within 24 hours, she received the formal 35-page inspection report from the lab.
Michelle was amazed at the amount of effort the inspector devoted to painstakingly perform, describe and record (with many photos) all the various aspects of the inspection while following Michelle’s inspection criteria and generally accepted inspection practices. The golf towels arrived at the warehouse in excellent shape a couple of weeks later. The golf tournament sponsor was thrilled with the towels and promised that next year’s order would be even bigger and better. Being a quick learner, Michelle instantly realized that she could also use the inspection report to improve her inspection specifications and as the basis of a “corrective action plan” to help the factory improve the quality for the next order.
Leeton Lee has been in the product safety and compliance industry for 18 years, starting as in-house legal counsel at The Walt Disney Company where he worked for seven years and helped to form Disney’s industry-leading Corporate Product Integrity Department and managed the company’s legal matters for its worldwide product safety and liability program. As an attorney for approximately 25 years, he has extensive experience in regulatory compliance and product safety, namely in toys, children’s products, promotional products and apparel. In addition to working at Disney, he has performed associate general counsel duties at industry leaders Sega Gameworks and Equity Marketing (aka EMAK Worldwide). He is currently vice president of regulatory compliance and general counsel at drinkware supplier ETS Express, Inc. in Oxnard, California. He serves on PPAI’s Product Responsibility Action Group (PRAG).
>>Follow Michelle’s example by learning all you can about product safety. Check out PPAI’s website for dozens of resources including product guides, webinars, articles and other documents and links designed to help educate distributors and suppliers about product safety requirements and compliance. Find these at www.ppai.org/productsafety.