# CPSC OGC Advisory Opinion No. 19 (1973): CPSC OGC Advisory Opinion No. 19

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CPSC_AO_19

## Section

- **Citation:** CPSC OGC Advisory Opinion No. 19 (1973)
- **Heading:** CPSC OGC Advisory Opinion No. 19
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** CPSC Office of General Counsel Advisory Opinions / CPSC OGC Advisory Opinion No. 19

## Text

August 16, 1973
Mr. Allen Walters
American Warehousemen's Association
222 West Adams Street
Chicago, Illinois 60606
Dear Mr. Halters:
Our office was notified by Hr. Albert Limberg, Acting
Director, Chicago Area Office, that you had inquired whether
public warehousemen who are neither manufacturers, distributors
nor retailers were subject to_ section lS(b) of the Consumer
Product Safety Act.
That section provides:
(b}
Every nanufacturer of a consl.Lŭer
product distributed in Co::\I:1crcŮ, and
every distributor and retailer of such
product, \•Tho obtains information which
reason.::.bly supports the conclusion that
such product ­
{1) fails to comply with an applicable
consůŰcr product safety rule; or
(2} contains a defect which could create
a swx;tantL:i.1 product hu.zard described in
subsection {.:i.) {2),
shc::tll irn:,cdiately inform the Corr.r:1i=,sion
of such failure to conply or of such defect,
W1less such manufacturer, distributor or
retailer has actual knm-,ledgc that the
Cormaission has been adequately informed
of sucll defect or failure to comply.
Section lS(b) places the duty of reporting on rnanufacturerstL•---
,,------
distributors and retailers.
If public warGhouser..cn clo not
i.._,_____
act as manufacturers, distributors or retailers of the goods
in their possession, but merely store the goods for others,
t.i'-icy would not be subject to the r3porti11g rcquiren::;nts of
section lS(b) of the Consuner Product Safety Act.
If I cnn be of further assistance please do not hesitate
to call on me.
ASchoem:jh 8-16-73
Michael A. nrO'.•m
gc file
Acting Gűneral Counsel
gc c:1ron
('.C, L-,Y, 1i::ce\
\

## Nearby sections

- [CPSC OGC Advisory Opinion No. 2 (1973) CPSC OGC Advisory Opinion No. 2](https://www.frixlaw.com/law-library/statutes/CPSC_AO_2.md)
- [CPSC OGC Advisory Opinion No. 4 (1973) CPSC OGC Advisory Opinion No. 4](https://www.frixlaw.com/law-library/statutes/CPSC_AO_4.md)
- [CPSC OGC Advisory Opinion No. 8 (1973) CPSC OGC Advisory Opinion No. 8](https://www.frixlaw.com/law-library/statutes/CPSC_AO_8.md)
- [CPSC OGC Advisory Opinion No. 9 (1973) CPSC OGC Advisory Opinion No. 9](https://www.frixlaw.com/law-library/statutes/CPSC_AO_9.md)
- [CPSC OGC Advisory Opinion No. 12 CPSC OGC Advisory Opinion No. 12](https://www.frixlaw.com/law-library/statutes/CPSC_AO_12.md)
- [CPSC OGC Advisory Opinion No. 17 (1973) CPSC OGC Advisory Opinion No. 17](https://www.frixlaw.com/law-library/statutes/CPSC_AO_17.md)
- [CPSC OGC Advisory Opinion No. 19 (1973) CPSC OGC Advisory Opinion No. 19](https://www.frixlaw.com/law-library/statutes/CPSC_AO_19.md)
- [CPSC OGC Advisory Opinion No. 20 (1973) CPSC OGC Advisory Opinion No. 20](https://www.frixlaw.com/law-library/statutes/CPSC_AO_20.md)
- [CPSC OGC Advisory Opinion No. 24 (1973) CPSC OGC Advisory Opinion No. 24](https://www.frixlaw.com/law-library/statutes/CPSC_AO_24.md)
- [CPSC OGC Advisory Opinion No. 27 (1973) CPSC OGC Advisory Opinion No. 27](https://www.frixlaw.com/law-library/statutes/CPSC_AO_27.md)
- [CPSC OGC Advisory Opinion No. 33 (1973) CPSC OGC Advisory Opinion No. 33](https://www.frixlaw.com/law-library/statutes/CPSC_AO_33.md)
- [CPSC OGC Advisory Opinion No. 34 (1973) CPSC OGC Advisory Opinion No. 34](https://www.frixlaw.com/law-library/statutes/CPSC_AO_34.md)
- [CPSC OGC Advisory Opinion No. 35 (1973) CPSC OGC Advisory Opinion No. 35](https://www.frixlaw.com/law-library/statutes/CPSC_AO_35.md)
- [CPSC OGC Advisory Opinion No. 36 (1973) CPSC OGC Advisory Opinion No. 36](https://www.frixlaw.com/law-library/statutes/CPSC_AO_36.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CPSC_AO_19. Check the current official text before relying on it. Not legal advice.