# CPSC OGC Advisory Opinion No. 20 (1973): CPSC OGC Advisory Opinion No. 20 > Federal · Agency guidance · In force URL: https://www.frixlaw.com/law-library/statutes/CPSC_AO_20 ## Section - **Citation:** CPSC OGC Advisory Opinion No. 20 (1973) - **Heading:** CPSC OGC Advisory Opinion No. 20 - **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. 20 ## Text    ,&l / W. O. Schoedinger, President F. O. Schoedinger, Inc. Box 28 Columbus, Ohio 43216 Dear Mr. Schoedinger: We are in receipt of your letter dated August 8, 1973 in which you state that you were told that it is necessary to divulge a hazard in any product that you handle. You have requested clarification as to the definition of a hazard. Section 15 of the Consumer Product Safety Act, 15 USC 2064, states in relevant part: ̓ Sec. 15(a). For purposes of_this section, the term "substantial product hazard" means ̔ (1) a failure to comply vith an applicable consumer product safety rule which creates a substantial risk of injury to the public, or (2) a product defect which (because of the pattern of defect, the number of defective products distributed in commerce, the severity of the risk, or otherwise) creates a substantial risk of injury to the public. (b) Every manufacturer of a consumer product distributed in commerce, and every distributor and retailer of such product, who obtains information which reasonably supports the conclusion that such product - (l) fails to comply with an applicable consumer product safety rule; or (2) contains a defect which would create a substantial product hazard described in subsection (a) (2), shall immediately inform the Commission of such failure to comply or of such defect, unless srsi  acturer, distributor, or retailer has actual knowledge that the Commission has been adequately irfcrred of such defect or failure to comply. It can be seen from the foregoing tltat all "hazards" are not reguirod to be reported to the Co:z-ission. Rather, onlv those product dbf-3ts vhich could crente a substantiel risk of injury to the public, or products which fail to cc..ply   :  acturer, distributor, or retailer has actual knowledge that the Commission has been adequately irfcrred of such defect or failure to comply. It can be seen from the foregoing tltat all "hazards" are not reguirod to be reported to the Co:z-ission. Rather, onlv those product dbf-3ts vhich could crente a substantiel risk of injury to the public, or products which fail to cc..ply   : -2- with an applicable consumer product safety rule and create a risk of injury to the public must be reported. For your information we are enclosing a copy of the Consumer Product Safety Act as well as a proposed regulation governing Section 15(b) of the Act. ASchoem KAZI6M; smm:8-17-73 cc: GC File GC Chron Alan Schoem Enclosures (2) Sincerely, Michael A. BF9B Michael A. Brown Acting General Counsel ÉÊ ## 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) --- Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/CPSC_AO_20. Check the current official text before relying on it. Not legal advice.