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Since its inception, the U.S. Consumer Product Safety Commission (“CPSC”) has encouraged companies to implement active product safety management programs. Since 2010, however, the CPSC has made this a bit more official. Requirements for the establishment of safety compliance programs has appeared in a final rule of factors to be considered for civil penalties, in a number of consent decrees and settlement agreements for civil penalties, in letters from the CPSC where they decided not to seek civil penalties, and finally in a proposed interpretive rule.