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Question: 51
Which token is always assigned the Accessor ID of 00000000-0000-0000-0000-000000000002, regardless of what
cluster you are working on?
A. anonymous token
B. Consul DNS token
C. master token
D. the second token created by the user
Answer: A
Explanation:
The anonymous token is used when a request is made to Consul without specifying a bearer token. The anonymous
token's description and policies may be updated but Consul will prevent this token's deletion.
When created, it will be assigned 00000000-0000-0000-0000-000000000002 for its Accessor ID and
anonymous for its Secret ID.
https://www.consul.io/docs/acl/acl-system.html#builtin-tokens
Question: 52
Complete the sentence:
The main restriction on Consul's K/V store is an object's size, which can be a maximum of _______?
A. 512KB
B. 64KB
C. 1MB
D. 8KB
Answer: A
Explanation:
The main restriction on an object is size - the maximum is 512 KB. Due to the maximum object size and main use
cases, you should not need extra storage. https://www.consul.io/docs/agent/kv.html#using-consul-kv
Question: 53
The LAN gossip pool provided by Serf requires that all cluster members (servers and clients) can communicate over
what tcp/udp port, by default?
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A. 8301
B. 8300
C. 8500
D. 8600
Answer: A
Explanation:
LAN Serf: The Serf LAN port (TCP and UDP) requires port 8301. This port is used for all members of the
datacenter to communicate.
https://www.consul.io/docs/install/ports
Question: 54
Complete the following sentence with the proper order of answers:
Consul uses two types of certificates for encryption. Consul agent communications are secured by _________ and
Consul Connect uses __________ between registered services.
A. mutual TLS, TLS
B. SSL, TLS
C. mutual TLS, SSL
D. TLS, mutual TLS
Answer: D
Explanation:
Consul agent communications are done using TLS certificates that can be created by the built-in CA or an external CA
if you need more control over certificates.
Consul Connect uses mutual TLS for authorization and encryption. https://www.consul.io/docs/connect
https://learn.hashicorp.com/consul/security-networking/certificates
Question: 55
Your colleague has deployed a new Consul cluster, and you want to double-check the encryption key used for gossip
communication. You open up an SSH session to a Consul node and type the command consul keyring -list but receive
the following error.
From the error message below, what is missing from the Consul agent configuration file?
$ consul keyring -list
==> Gathering installed encryption keys...
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A. the encryption parameter with a valid of true or 1
B. the encrypt parameter and the corresponding value
C. the gossip parameter and a value of true
D. configuration for the tls certificate, the private key, and the CA bundle
Answer: B
Explanation:
In the configuration file, the encrypt parameter must be used to enable gossip encryption and set the gossip encryption
key. The provided key is automatically persisted to the data directory and loaded automatically whenever the agent is
restarted. The fact that the key is persisted in the data directory means that in order to encrypt Consul's gossip protocol,
this option only needs to be provided once on each agent's initial startup sequence.
https://www.consul.io/docs/agent/options.html#_encrypt
Question: 56
Which of the following are true about running Consul in development mode? (select three)
A. development mode allows you to easily experiment with most of Consul's functionality
B. development mode is not secure
C. it is acceptable to run development mode in a production environment
D. development mode is easily scalable
E. development mode should never be used in a production environment
Answer: A,B,E
Explanation:
Running Consul in development mode is not secure or scalable but does let you quickly experiment with most of
Consul's functionality without extra configuration. Development mode does not use TLS to secure communications.
Therefore, it is not secure.
Development mode runs the Consul as an in-memory server. Therefore, it is limited to a single node and is not
scalable. Because Consul dev mode runs only on a single node, it is not suited for production environments.
More information on using the -dev flag to run Consul development mode can be found here.
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Question: 57
Select the benefits that the LAN gossip pool provides to a Consul datacenter (select three)
A. reliable and fast event broadcasts
B. failure detection work to be shared by the entire cluster
C. automatically discover servers, reducing the amount of configuration needed
D. perform cross datacenter requests
Answer: A,B,C
Explanation:
Consul makes use of two different gossip pools. We refer to each pool as the LAN or WAN pool respectively. Each
datacenter Consul operates in has a LAN gossip pool containing all members of the datacenter, both clients and
servers. The LAN pool is used for a few purposes. Membership information allows clients to automatically discover
servers, reducing the amount of configuration needed. The distributed failure detection allows the work of failure
detection to be shared by the entire cluster instead
of concentrated on a few servers. Lastly, the gossip pool allows for reliable and fast event broadcasts.
https://www.consul.io/docs/internals/gossip.html#gossip-in-consul
Question: 58
There are two methods for creating and distributing client certificates for Consul.
What are the two? (select two)
A. auto encryption
B. openSSL generation
C. Vault integration
D. operator
E. manual
Answer: A,D
Explanation:
There are two methods for distributing client certificates, operator or auto encryption.
The auto-encryption method introduced in Consul 1.5.2 alleviates the client certificate generation and distribution step
for operators. This method uses the Connect CA to generate client certificates and then Consul will automatically
distribute the certificates to all clients and is beneficial for large datacenters with many clients.
The operator method is recommended if you need to use a third-party CA or need more fine-grained
control over certificate management.
https://learn.hashicorp.com/consul/security-networking/certificates#client-certificate-distribution
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Question: 59
A service supporting a grocery store is using Consul for service discovery. Multiple instances of the inventory service
have been registered with a health check to ensure each individual instance is healthy. You've decided that you want to
add a second health check to the service, so you update the agent configuration file. However, the new health check
has not been registered with Consul.
How can you update the Consul agent without any downtime to include the new health check?
A. restart to the Consul service
B. perform a consul reload
C. log into the Consul UI and add the health check manually
D. instruct the Consul servers to update all of the Consul client configurations
Answer: B
Explanation:
You can update service definitions without any downtime by changing the service definition file and sending a
SIGHUP to the agent or running consul reload. Alternatively, you can use the HTTP API to add, remove, and modify
services dynamically.
https://learn.hashicorp.com/tutorials/consul/get-started-service-discovery#update-services
Question: 60
HashiCorp Consul is a networking automation tool that provides what functionality for an organization? (select six)
A. enables secure communication between services
B. service configuration
C. scheduling of services and containers
D. provides service segmentation
E. service discovery
F. key/value storage
G. service-mesh control plane
Answer: A,B,D,E,F,G
Explanation:
The key features of Consul are:
Service Discovery: Clients of Consul can register a service, such as api or mysql, and other clients can use Consul to
discover providers of a given service. Using either DNS or HTTP, applications can easily find the services they
depend upon.
Health Checking: Consul clients can provide any number of health checks, either associated with a given service ("is
the webserver returning 200 OK"), or with the local node ("is memory utilization below 90%"). This information can
be used by an operator to monitor cluster health, and it is used by the service discovery components to route traffic
away from unhealthy hosts.
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KV Store: Applications can make use of Consul's hierarchical key/value store for any number of purposes, including
dynamic configuration, feature flagging, coordination, leader election, and more. The simple HTTP API makes it easy
to use.
Secure Service Communication: Consul can generate and distribute TLS certificates for services to establish mutual
TLS connections. Intentions can be used to define which services are allowed to communicate. Service segmentation
can be easily managed with intentions that can be changed in real-time instead of using complex network topologies
and static firewall rules.
Multi Datacenter: Consul supports multiple datacenters out of the box. This means users of Consul do not have to
worry about building additional layers of abstraction to grow to multiple regions.
Consul is designed to be friendly to both the DevOps community and application developers, making it perfect for
modern, elastic infrastructures.
Information obtained from the Consul website found here https://www.consul.io/intro/index.html.
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HashiCorp Certified: answers - BingNews https://killexams.com/pass4sure/exam-detail/Consul-Associate Search results HashiCorp Certified: answers - BingNews https://killexams.com/pass4sure/exam-detail/Consul-Associate https://killexams.com/exam_list/HashiCorp Take a CompTIA deep dive for just $65 No result found, try new keyword!If you’re ready to pursue a career in IT in 2024, The Complete 2024 CompTIA Certification Training Super Bundle by IDUNOVA is right up your alley. This massive bundle gives you guidance and training ... Thu, 04 Jan 2024 18:14:56 -0600 en-us text/html https://www.msn.com/ 4 Certified Senior Designations Worth Holding

In recent years, the number and scope of professional designations available have grown, and many financial advisors are now unsure of which credential will serve them most effectively. This is especially true for specialized designations for retirement planning and working with the specific financial needs of older adults. As the Bureau of Labor Statistics notes, the major driver of the growth in jobs for financial advisors is the aging population. The large baby boomer generation is on the way to retirement, and longer life spans are leading to prolonged retirements, adding to the demand for financial planning services aimed at older adults. Here, we take a closer look at some of the designations used and whether they are worth pursuing for those looking to offer financial advice on retirement planning, retirement income, longevity planning, and estate planning.

Key Takeaways

  • Many financial advisors are specializing in retirement planning and income.
  • As a result, these advisors have sought targeted training and education to validate their expertise and signal their skills to those who need it.
  • Several professional credentials and designations are now available for financial planning for older adults, with certified senior advisor (CSA) being the most recognized.
  • Chartered advisor for senior living (CASL) was a popular certification no longer available for new applicants (though existing license holders are still required to continue their education).
  • Some designations, like the certified senior specialist (CSS), face restrictions from state bodies and are not recognized as valid in some areas.
  • Another well-rounded certification option is the chartered senior financial planner (CSFP).

What Are Designations Focused on Older Adults?

Several designations have been created in the financial planning industry in recent years. Designations focused on the needs of older adults primarily involve financial strategies for individuals aged 50 and older.

The Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) do not officially recognize any professional titles such as “retirement advisor” that financial professionals use. Nevertheless, this financial planning consumer demographic has been increasingly targeted from almost every direction by the financial services industry, including banks, insurance companies, and independent financial and estate planners.

With potentially larger portfolio balances, given their longer investment timeline and a growing need for retirement and succession planning services, there are ample needs and opportunities for working with older clients.

The Financial Industry Regulatory Authority (FINRA) does not approve or endorse any professional designation. The designation's inclusion in its database doesn't mean that FINRA considers the designation acceptable for use by a registered representative.

4 Main Designations

Here are four main designations that financial professionals may use to signal expertise in the financial planning needs of older adults:

Certified Senior Advisor

Offered and recognized by the Society of Certified Senior Advisors (SCSA), a CSA is the best-known advisory certification on this list. Candidates need to pass a certification examination on the social, medical, cultural, financial, and legal aspects of aging to become a license holder.

There is no prescribed training or education program, but the SCSA offers resources like textbooks and live course training. Preparation for the exam usually takes 50–60 hours. Candidates must also complete 30 hours of continuing education and pass a criminal background check every three years to maintain their certification.

CSAs are typically professionals in different fields who work exclusively or frequently with the aging and want to supplement their professional knowledge with the designation. Many advisors who earn this designation work primarily with fixed or indexed annuities. However, some nonfinancial professionals, including estate planning attorneys, healthcare professionals, and administrators, carry this designation. CSAs must inform consumers that the designation alone does not imply financial, health, or social expertise. 

Chartered Advisor in Senior Living (CASL)

Offered by The American College, CASL applicants need to have worked with older adults for a minimum of three years before they can take the required examination. Applicants must also adhere to The American College's code of ethics.

A CASL advisor is tested on retirement distributions from pensions and Social Security, planning for health and long-term care needs, and effective estate planning strategies. The CASL designation is no longer offered to new students. However, existing certificate holders are required to participate in the Professional Recertification Program to keep their credentials.

Certified Senior Specialist (CSS)

CSS requires more course work than the others in retirement planning, estate tax planning, annuities, Social Security, and Medicare. The exam covers long-term care and issues related to the care of adults 80 and over, the demographics of the population of older adults, charitable estate planning techniques, and reverse mortgages.

The CSS license is issued by Certified for Senior Studies, although not all jurisdictions recognize the designation. For example, California treats this license differently than the CSA since the designation can't be used by agents or brokers to sell insurance to adults 65 and over. For this reason, the CSS license holds much less value than some of the other licenses.

Chartered Senior Financial Planner (CSFP)

Issued by the Association of Chartered Senior Financial Planners, the CSFP designation trains recipients in advanced retirement and estate planning strategies. To take the exam, trainees must have two years of insurance experience, two years of securities experience, or be a licensed attorney or CPA. Three-day training sessions are available before the exam, and 16 hours of continuing education are required every two years.

Like other exams, the CSFP designation prescribes a code of ethics and demonstrates a holder's proficiency in preretirement, post-retirement, and asset protection strategies.

Broad Based Designations That Serve Seniors

While designations for expertise in the financial needs of older adults may differ substantially in the academic training, none of them can compare to the curricula for established and respected designations such as Chartered Financial Planner (CFP), Chartered Life Underwriter, or Chartered Financial Consultant.

If you wish to position yourself as an expert in financial planning for anyone, including older adults, you should first consider earning one of the more traditional, comprehensive designations. Afterward, you could earn one of the designations focusing on older adults. At that point, your competence in the needs of this demographic would mean a great deal more as you've honed in on a specific Topic while having a broad background in financial planning. You would also be subject to a code of ethics that can be enforced.

Pending Consequences

Given they often have access to savings that are meant to take them through their retirement years, older adults are frequently targeted by scam artists and charlatans. The National Council on Aging (NCOA) reports that in 2022, there were 88,262 complaints of fraud, resulting in $3.1 billion in losses from people age 60 and over. This may vastly underrate the problem, given that such frauds often go unreported, according to the NCOA. The most common scams involve impersonating government officials, supposed sweepstakes winnings, and robocalls.

As a result, state and federal regulators have taken notice of inadequate training and the business approach many certificate holders take to the financial matters of older adults. One of the main limits regulators face when dealing with this problem is that no overarching agency monitors the financial designation community like there is for insurance or securities licensing. Therefore, any “rogue” credential must be dealt with state-by-state.

What Is the Best License Designation for Working With Older Adults?

The Certified Senior Advisor (CSA) designation is the most recognizable professional license. Though it still falls well short of the breadth and depth of wide-scale professional licenses, it remains a strong option for those looking for specific certification in the financial matters of older adults.

Is It Worth Getting a Designation for Working With Older Adults?

There are mixed opinions on the value of these license designations. Some argue any sort of formal training and exam provides value and boosts your credibility as a financial planner. Others point out the gap in education between these license designations and broader financial planner certifications. As long as your clients understand the limits of what the designation means, there is some value in pursuing them.

Are All Designations for Working With Older Adults Recognized?

No, such license designations are often recognized on a state-by-state basis. Each state will have its own reporting requirements, and many limit the recognition of some designations. When a designation is limited in a state, the financial advisor can't use that title while pursuing sales of insurance or securities. To check whether your license is recognized in a specific state, check with that state's Department of Insurance.

The Bottom Line

While the differences between designations such as the CFP and CSA may be apparent to those in the business, most people looking for financial advice may have difficulty comprehending the gap in training between the two. Although it would be unfair to label every financial professional who holds a designation for advising older adults as dishonest, the increasing pressure from state regulators is making the future of these designations uncertain.

Advisors considering whether to pursue a designation for working with older adults may want to check with their state's insurance commissioner and securities bureau before enrolling in a program. While bogus designations can fool prospects and clients at least temporarily, regulators are certain to rectify the situation eventually.

Thu, 14 Dec 2023 08:34:00 -0600 en text/html https://www.investopedia.com/financial-advisor/close-look-at-certified-senior-designations/
Pay attention! Our attention spans are shrinking Pay attention! Our attention spans are shrinking - CBS News

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Are attention spans getting shorter? Are you getting more distracted by multitasking on top of multitasking? Correspondent David Pogue tries to get answers from researcher Gloria Mark, author of "Attention Span," at the same time he talks with Cornell psychology professor James Cutting AND with counselor Lauren Barnett AND her daughters about how distractive technologies are affecting our behavior, productivity and stress levels.

Be the first to know

Get browser notifications for breaking news, live events, and exclusive reporting.

Sat, 28 Oct 2023 23:10:00 -0500 en-US text/html https://www.cbsnews.com/video/pay-attention-our-attention-spans-are-shrinking/
Michigan Test for Teacher Certification

MTTC tests are meant to ensure that each certified teacher has the necessary skills and subject area knowledge to serve in Michigan's schools. These tests are designed and implemented by the Michigan Department of Education.

Save all official MTTC score reports in a safe place because you may need them for employment or teacher certification in other states. If you need new score reports, additional copies may be ordered using these instructions.

In order to be certified, students must pass the MTTC subject area tests that correspond to the major and minor field(s) of study. These tests should not be taken until the final year of the program, but it is highly recommended that students pass their MTTC subject area test(s) before student teaching.

  • Find out which subject tests you need to take.
  • Subject area test scores are valid for five years from the date of testing (students need to be recommended for certification within those five years).
  • Register at the Michigan Test for Teacher Certification website
  • The fee for each subject test is $129.
  • During the registration process, be sure to identify yourself as a Calvin student and also request that your scores be sent to Calvin.
  • Be careful to enter an accurate social security number. It is a huge inconvenience if you enter an incorrect number. Canadians, please register using your U.S. social security number, not your Canadian social insurance number.
  • When asked if you are completing an “alternative route” to teacher certification, answer “No” (Calvin’s program is a traditional route).
  • Candidates with diagnosed disabilities may register for alternative testing arrangements.
  • Candidates who do not speak English as a primary language may request additional time for any MTTC test except world language subject tests.
  • Be sure to review the appropriate study guides. Depending on your subject area, you may find helpful practice problems at education.com or 240Tutoring. Curriculum Collection middle or high school textbooks may be used to review content.
  • Tests are no longer offered on campus. All MTTC tests are now computer-based only. Test Center locations are available in cities worldwide. 

Elementary Education Students

Students seeking elementary certification must also take the Elementary Education MTTC test #103. Do not take the new Lower or Upper Elementary tests 117-124. When registering for the Elementary Education test, report elementary education as a "major." Take the time to review the online study guide and test objectives. Spend extra time studying for these subareas, which have lower pass rates:

  • Social Studies
  • Visual and Performing Arts
  • Health and Physical Education

Special Education Program Students

Candidates interested in teaching grades 9–12 special education in a Michigan public school may need to take additional MTTC tests later in consultation with the hiring school (mathematics, integrated science, and/or language arts).

If you have questions, contact Calvin's certification and assessment coordinator at (616) 526-6208 or certification@calvin.edu.

Sat, 23 May 2015 04:48:00 -0500 en text/html https://calvin.edu/academics/departments-programs/education/certification/michigan-test-for-teacher-certification/
Risk Learning: Risk Certified Faculty Risk Learning: Risk Certified Faculty - Risk.net
Wed, 06 Jul 2022 09:10:00 -0500 en text/html https://www.risk.net/static/risk-learning-risk-certified-faculty
CPSC Proposes Significant Changes to Rule Governing Certificates of Compliance

The Consumer Product Safety Commission (CPSC or Agency) recently published a Supplemental Notice of Proposed Rulemaking (SNPR) (88 Fed. Reg. 85760 (December 8, 2023)) to revise the existing rule on Certificates of Compliance (CoC or certificates), 16 CFR § 1110 (Rule 1110). The last time CPSC proposed changes to Rule 1110 was in 2013, when the Agency received more than 500 comments responding to its Notice of Proposed Rulemaking (2013 NPR), many voicing specific legal and other objections to the proposed changes. A decade later, CPSC is reviving the CoC rulemaking process. This SNPR proposes a number of significant changes to Rule 1110, including the addition of an electronic filing (eFiling) requirement for all imported CPSC-regulated products or substances, an expanded definition of “importer” to include the importer of record and certain other entities, and new CoC content and recordkeeping requirements.

Given the staggering number of imported consumer products and the expansive scope of proposed changes, the SNPR warrants close attention by anyone making CPSC-regulated products abroad for distribution in the United States or direct shipments to U.S. consumers. Comments are due February 6, 2024. 

Key Proposed Changes

  • Mandatory eFiling for Imported Goods. Under the existing Rule 1110, importers must ensure that a CoC “accompany” a regulated product or product shipment, meaning that the certificates must be available to the CPSC at the time imported products are available for inspection. Likewise, domestic manufacturers must make certificates available to the CPSC immediately “upon request” before the product is introduced into commerce. In practice, many importers and manufacturers email certificates in PDF format when requested. This will no longer be permitted. CPSC proposes to change this long-established practice to a requirement that all certificates covering imported consumer products be eFiled with CBP. Specifically, the SNPR will require importers to enter required certificate data elements with ACE at the time the entry is filed or when the entry and entry summary are filed, if filed together. This requirement would apply to all imported products regulated by CPSC. As proposed, this includes de minimis shipments and products imported from foreign trade zone (FTZ). The requirement that certificates be made available for inspection to CPSC or CBP “upon request” remains (with a proposed clarification that “immediately” means within 24 hours), but this obligation is not a substitute for eFiling the CoC.
  • Imported Products Shipped Directly to Consumers. The 2013 NPR had proposed a separate “accompany” requirement for imported finished products that are delivered directly to U.S. consumers. The SNPR nixes that proposal and instead states that those certificates will be collected electronically. For finished products that are imported by mail, the finished product certifier will have to enter the certificate data elements into CPSC’s Product Registry prior to the product arriving in the U.S.
  • Entities Responsible for Certifying Imported Products. The SNPR broadens the definition of “importer” to include not only any entity that the U.S. Customs and Border Protection (CBP) allows to be an importer of record (IOR), as proposed in the 2013 NPR, but other entities as well, including private labelers, consignees, owners, purchasers, and others with “financial interest in the product.” A customs broker can also be an importer “when appropriately designated by the owner, purchaser, or consignee of the product or substance.” The SNPR clarifies that for purposes of testing and certification, “CPSC will not typically consider a consumer purchasing or receiving products for personal use or enjoyment to be an importer.”
  • Entities Responsible for Certifying Domestic Products. The SNPR maintains the 2013 NPR proposal that, unless otherwise required in a specific rule, the manufacturer must issue the certificate except for consumer products or substances that are privately labeled. Because the manufacturer’s name does not appear on privately labeled products, CPSC reasoned that placing the certification obligation on the private labeler “is both pragmatic and appropriate.” Nevertheless, the SNPR gives private labelers the option to rely on a manufacturer’s testing or certification.
  • Optional Electronically Available Certificates. The SNPR states that the requirements that a CoC be “furnished” to each distributor or retailer of the finished product and be “available for inspection immediately” upon request by CPSC and CBP may be satisfied with an “electronic certificate.” Such an electronic certificate must be “identified prominently on the finished product, shipping carton, or invoice by a unique identifier [that] can be accessed via a World Wide Web uniform resource locator (URL) or other electronic means, provided that the certificate, the URL or other electronic means, and the unique identifier are accessible … on or before the date the finished product is distributed in commerce.”
  • Replacement Parts Defined. In response to multiple comments to the 2013 NPR expressing confusion about “replacement parts” and “component parts,” the SNPR defines the terms and clarifies certificate of compliance requirements. Certificates are required for regulated “replacement parts” that are “imported for consumption or warehousing, or are distributed in commerce, and that are packaged, sold, or held for sale to, or use by, consumers.” Such replacement parts are considered “finished products” and included in the proposed finished product definition. For example, a handlebar stem for a bicycle sold to consumers as a replacement part must be tested and requires a certificate. Likewise, parts of toys, such as doll accessories, sold to consumers as separate finished products, must be separately tested and certified. However, not all replacement parts are finished products requiring testing and certification. For example, doll accessories that are imported for manufacturing purposes or intended to be combined with a doll for sale are not deemed “finished products” and do not require a separate certificate apart from the certificate for the finished doll.
  • Component Parts Defined. “Component parts” are defined as “intended to be used in the manufacture or assembly of a finished product” and “not intended for sale to, or use by, consumers as a finished product.” Component part certificates are voluntary and are not required to accompany an imported component part, be furnished to retailers and distributors, or eFiled.
  • One Product per CoC. The SNPR maintains the 2013 NPR proposal that each CoC describe a single product. According to CPSC, “[o]ne product per certificate allows the RAM [CPSC’s Risk Assessment Methodology] to conduct risk analysis on unique products in a shipment, which allows better targeting of potentially violative products and avoids delaying delivery of products in a shipment that do not warrant examination.”
  • CoC Content. Currently, Rule 1110 requires seven data elements on all certificates: (1) information identifying the product; (2) list of all applicable rules which the product meets; (3) name, mailing address, and telephone number of importer or domestic manufacturer; (4) name, email, mailing address, and telephone number of individual maintaining test results; (5) date and place of manufacture; (6) date and place of product testing; and (7) name, mailing address, and telephone number of third party lab for any required testing. The SNPR proposes additional required details for some of the seven data elements, including, for example:
    • Data element (1) must include at least one unique product identifier from a list of seven options (GTIN, model number, registered number, serial number, SKU, UPC, or alternate identifier), as well as a “sufficient description to match the finished product to the certificate”;
    • The SNPR adds an email address requirement to data element (3), and specifies that mailing address means street address, city, state or province, country or administrative region, and if no street address is available, requires a GPS coordinate or “a location identification typical of the country of origin”;
    • Data element (5) as proposed must include not just date and place of manufacture, but also the manufacturer’s name, street address, city, state or province, country or admin region, email address, and telephone number where finished products are manufactured, produced, or assembled; and
    • Data element (6) must include the most recent date of testing, together with expanded contact information for each testing body, including full mailing address, email, and telephone number (similar to contact information for importer/manufacturer and manufacturing facilities).
  • New Attestation of Compliance Requirement. In addition to the seven existing data elements, CPSC has proposed a new requirement: each CoC must also include an attestation of compliance. The SNPR provides specific language for the attestation, which includes an express acknowledgement that “it is a United States federal crime to knowingly and willfully make any materially false, fictitious, or fraudulent statement, representation, or omission on this certificate.”
  • New Recordkeeping Requirement. The current rule does not include specific recordkeeping requirements. The SNPR proposes an effective five-year record retention period for both children’s product certificates and general certificates of conformity. According to the 2013 NPR, which also included this proposal, a five-year retention period “may, for example, aid both the certifier and the Commission in the event of an investigation or product recall.”

Effective Date

The SNPR proposes an effective date that is 120 days after publication of the final rule in the Federal Register. According to CPSC, importers will require this time to update their systems and software in order to use CPSC’s Product Registry, and CPSC asserts that this relatively short timeframe is consistent with the experience of eFiling Beta Pilot participants who initially tested the eFiling system.

Conclusion

Interested parties may submit comments on all aspects of the SNPR, including, for example, the expanded definition of “importer,” issues presented by requiring eFiling of certificates with CPB at the time of entry, concerns with the additional detail required on the certificates (including the potential disclosure of proprietary information), financial, technical and other burdens of compliance should the proposed new requirements be adopted, and the feasibility of the proposed 120-day effective date. The proposed rule will have a significant impact across the entire consumer product spectrum, and those interested in commenting should consider both any benefits and efficiencies, as well as costs and other impacts. 

Wed, 03 Jan 2024 10:00:00 -0600 en text/html https://www.natlawreview.com/article/cpsc-proposes-significant-changes-rule-governing-certificates-compliance




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