# CPSC OGC Advisory Opinion No. 307 (1985): CPSC OGC Advisory Opinion No. 307

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/CPSC_AO_307

## Section

- **Citation:** CPSC OGC Advisory Opinion No. 307 (1985)
- **Heading:** CPSC OGC Advisory Opinion No. 307
- **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. 307

## Text

U . S .
F R O O U C T S A F E T Y

C .
M a r c h

Aaron Locker, Esq.
Locker,
Greenberg
P.C.
One Penn Plaza
New York,
New York 10001
Dear Mr. Locker:
In an October 4, 1985 letter,
you discussed a preemption
question that arises under the Federal Hazardous S&stances Act
and involves a requirement enacted recently in Texas.
When you
I met on November 15,
1985 to discuss your letter,
you requested an advisory opinion on the question of whether the
FHSA preempts the portions of the Texas requirement concerning
firms that distribute toys and other articles intended for use by
children
Enclosed with your letter were a September 20, 1985 letter
from the Texas Department of Health
to the Toy
Manufacturers of America concerning registration; an October 1985
letter from Texas to firms that it believes must register under
the new requirement;
a blank registration form: Texas'
regulations implementing the requirement; a January 7, 1982
National Highway
Safety Administration preemption
interpretation;
and an August 10,
1983 federal district court
memorandum opinion.
At our meeting you also provided your
October 17,
1985 letter to Texas.
On November 19, 1985, Texas
submitted a letter on this subject.
Enclosed with that letter
were the requirement;
its implementing regulations, with
explanatory comments:
a booklet containing the Texas
Hazardous Substances Act and Rules Promulated Thereunder. On
February 14, 26, and 27,
1986 Texas sent additional letters,
including a legal memorandum.
This advisory opinion is based, in
on all of these
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\J\.,'A~iHINGTON,
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11, 1986
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("toys")
.
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documents.
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J KL M N O PQ R S T U V W X Y Z [
U.S. CONSUMER FROOUCT SAFETY COMMISSION
WASHINGTON,D. C. 20207
March 11, 1986
Aaron Locker, Esq.
Locker,
Greenberg & Brainin, P.C
207
11, 1986
QF;:iC:: OF THE
& Brainin,
("FHSA")
and
("toys")
.
("Texas")
Traffic
a.nd-
part,
documents.
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307
J KL M N O PQ R S T U V W X Y Z [
U.S. CONSUMER FROOUCT SAFETY COMMISSION
WASHINGTON,D. C. 20207
March 11, 1986
Aaron Locker, Esq.
Locker,
Greenberg & Brainin, P.C.
One Penn Plaza
New York, New York 10001
Dear Mr. Locker:
OFFICE OF THE
GENERAL COUNSEL
In an October 4, 1985 letter, you discussed a preemption
question that arises under the Federal Hazardous S&stances Act
("FHSA") and involves a requirement enacted recently in Texas.
When you and I met on November 15,
1985 to discuss your letter,
you requested an advisory opinion on the question of whether the
FHSA preempts the portions of the Texas requirement concerning
firms that distribute toys and othe r articles intended for use by
children ("toys").
Enclosed with your letter were a September 20, 1985 letter
from the Texas Department of Health ("Texas") to the Toy
Manufacturers of America concerning registration; an October 1985
letter from Texas to firms that it believes must register under
the new requirement;
a blank registration form: Texas'
regulations implementing the requirement; a January 7, 1982
National Highway Traffic Safety Administration preemption
interpretation;
and an August 10,
1983 federal district court
memorandum opinion.
At our meeting you also provided your
October 17, 1985 letter to Texas.
On November 19, 1985, Texas
submitted a letter on this subject.
Enclosed with that letter
were the requirement;
its implementing regulations, with
explanatory comments: and a booklet containing the Texas
Hazardous Substances Act and Rules Promulated Thereunder. On
February 14, 26, and 27, 1986 Texas sent additional letters,
including a legal memorandum.
This advisory opinion is based, in
part, on all of these documents.
A¥"\\ fl r. r'J'"
i
 Cibi
k:

Jvi\i
that letter
were the requirement;
its implementing regulations, with
explanatory comments: and a booklet containing the Texas
Hazardous Substances Act and Rules Promulated Thereunder. On
February 14, 26, and 27, 1986 Texas sent additional letters,
including a legal memorandum.
This advisory opinion is based, in
part, on all of these documents.
A¥"\\ fl r. r'J'"
i
 Cibi
k:

Jvi\i

Aaron Locker, Esq.
--Page Two--
Background
The Child Protection Act of 1966 amended the Federal
Hazardous Substances Labeling Act to provide a preemption
provision that was limited to precautionary labeling
requirements. Pub. L. 89-756.
Since 1976, however, the FHSA has
contained a preemption provision that states in relevant part:
under
of the Commission promulgated under or
for the enforcement
section 2(q) a requirement is established
to protect against a risk of illness or injury associated with a
hazardous substance,
no State or political subdivision of a State
may establish or continue in effect a requirement applicable
such substance and designed to protect against the same risk
illness or injury
such requirement is identical to the
requirement established under such regulations."'
15 U.S.C. 1261,
note (FHSA,
section N(b)(l)(B)).
The FHSA defines the term "hazardous substance" to include
toy or other article intended for use by
which
the [Commission] by regulation determines...presents an
electrical, mechanical, or thermal hazard."
15 U.S.C.
1261(f)(l)(D).
FHSA defines the term "banned hazardous
substance"
to include
toy,
or other article intended for use
by children,
which is a hazardous substance, or which bears or
contains a hazardous substance in such manner as to be
susceptible of access by a child to whom such toy or other
article is entrusted."
15 U.S.C. 1261(q)(l)(A)
an
electrical, mechanical, or thermal hazard."
15 U.S.C.
1261(f)(l)(D).
FHSA defines the term "banned hazardous
substance"
to include
toy,
or other article intended for use
by children,
which is a hazardous substance, or which bears or
contains a hazardous substance in such manner as to be
susceptible of access by a child to whom such toy or other
article is entrusted."
15 U.S.C. 1261(q)(l)(A).
The Commission has issued numerous regulations applicable
to toys,
including the ones mentioned in
letter to TMA:
electric trains, toy ovens, toy sewing machines, and toy
with peak sound pressure levels.
16 C.F.R. Part 1500 et seq.
Some of these regulations, such as the one for caps, classify an
entire category of toys as hazardous substances and banned
hazardous substances.
16 C.F.R. 1500.18(a)(5).
Then, a
regulation exempts some toys in that category from
such classification so long as they meet specified safety
criteria.
16 C.F.R.
1500.86(a)(6).
A second type of
regulation classifies as hazardous substances and banned
hazardous substances only toys in a category that fail to meet
specified safety criteria.
Examples of this type are the
regulations for electrical toys,
including electric trains and
toy ovens.
16 C.F.R. Part 1501.
·---··----·--·-·
..
"[I]f
"[a]ny
"companion"
regulations
of
unles,s
· The
"any
§
§
Texas'
§
chi..idren
caps
to
of
Aaron Locker, Esq.
--Page Two--
Background
The Child Protection Act of 1966 amended the Federal
Hazardous Substances Labeling Act to provide a preemption
provision that was limited to precautionary labeling
requirements. Pub. L. 89-756
ovens.
16 C.F.R. Part 1501.
·---··----·--·-·
..
"[I]f
"[a]ny
"companion"
regulations
of
unles,s
· The
"any
§
§
Texas'
§
chi..idren
caps
to
of
Aaron Locker, Esq.
--Page Two--
Background
The Child Protection Act of 1966 amended the Federal
Hazardous Substances Labeling Act to provide a preemption
provision that was limited to precautionary labeling
requirements. Pub. L. 89-756.
Since 1976, however, the FHSA has
contained a preemption provision that states in relevant part:
"{I]f under regulations of the Commission promulgated under or
for the enforcement of section 2(q) a requirement is established
to protect against a risk of illness or injury associated with a
hazardous substance, no State or political subdivision of a State
may establish or continue in effect a requirement applicable to
such substance and designed to protect against the same risk of
illness or injury unless such requirement is identical to the
requirement established under such regulations."'
15 U.S.C. 1261,
note (FHSA, section N (b) ( l) (B) )
.
The FHSA defines the term "hazardous substance" to include
"[a]ny toy or other article intended for use by children which
the [Commission] by regulation determines ... presents an
electrical, mechanical, or thermal hazard."
15 U. s. C.
1261 (f) (1) (D) .
The FHSA defines the term "banned hazardous
substance" to include "any toy,
or other article intended for use
by children, which is a hazardous substance, or which bears or
contains a hazardous substance in such manner as to be
susceptible of access by a child to whom such toy or other
article is entrusted."
15 U.S.C. § 1261 (q) ( 1 ) (A).
The Commission has issued numerous regulations applicable
to toys,
including the ones mentioned in Texas' letter to TMA:
electric trains, toy ovens, toy sewing machines, and toy caps
with peak sound pressure levels.
16 C.F.R. Part 1500 et seq
substance in such manner as to be
susceptible of access by a child to whom such toy or other
article is entrusted."
15 U.S.C. § 1261 (q) ( 1 ) (A).
The Commission has issued numerous regulations applicable
to toys,
including the ones mentioned in Texas' letter to TMA:
electric trains, toy ovens, toy sewing machines, and toy caps
with peak sound pressure levels.
16 C.F.R. Part 1500 et seq.
Some of these regulations, such as the one for caps, classify an
entire category of toys as hazardous substances and banned
hazardous substances.
16 C.F.R. § 1500.18 (a) (5).
Then, a
"companion" regulation exempts some toys in that category from
such classification so long as they meet specified safety
criteria.
16 C.F.R.
§ 1500.86 (a) (6).
A second type of
regulation classifies as hazardous substances and banned
hazardous substances only toys in a category that fail to meet
specified safety criteria.
Examples of this type are the
regulations for electrical toys,
including electric trains and
toy ovens.
16 C.F.R. Part 1501.

Aaron Locker, Esq.
--Page Three--
The Texas Hazardous Substances Act, a state law patterned
after the FHSA,
defines the term

to include
toy or other article other than clothing intended for use by
children which presents an electrical, mechanical, or thermal
hazard."
Section
Article 4476-13, V.T.C.S.
Implementing
regulations,
which use the same definition, state that they
designed to
to and be supplemental to the applicable
provisions and requirements of the
and
. 42.
A recent amendment to the Texas Hazardous Substances Act
requires registration and payment of a $150 annual fee by
manufacturers, repackers, and distributors
of hazardous
substances (excluding retailers,
unless they distribute hazardous
substances made to their specifications), prior to their doing
business in the state.
Section
Article 4476-13, V.T.C.S
visions and requirements of the
and
. 42.
A recent amendment to the Texas Hazardous Substances Act
requires registration and payment of a $150 annual fee by
manufacturers, repackers, and distributors
of hazardous
substances (excluding retailers,
unless they distribute hazardous
substances made to their specifications), prior to their doing
business in the state.
Section
Article 4476-13, V.T.C.S.
Regulations implementing the amendment again define hazardous
substance to include
toy or other article other than
clothing intended for use by children which present% an
electrical, mechanical, or thermal
10 Tex.Reg. 3768 (Sept. 27, 1985).
The implementing regulations specifically apply the
registration and fee requirement to manufacturers of hazardous
substances
"whose products might normally be banned, but who meet
specific exemption criteria enabling their products to be sold in
Texas...."
Id.
The two examples of such products
provided in the regulations are toy electric trains and toy caps.
and
Id.
Discussion
Based on the FHSA preemption provision, the Texas
requirement would be preempted if (1) an FHSA requirement has
been established to protect against a risk of illness or injury,
(2) the Texas requirement is designed to protect against the same
risk,
and (3) the Texas requirement is not identical to the FHSA
requirement.
Unless all three criteria are satisfied, there is
no express preemption under section 18(b)(l)(B) of the FHSA. As
noted earlier,
this advisory opinion will address only possible
preemption of the provisions in the Texas requirement that apply
to toy firms.
• -- - • --
-r----
----
-
- -·-------·---
- ---
"hazardous
substance
11
"any
1 ( 4) ,
"are
confGrm
[FHSA] ....
11
§§205.4l(c)
2A,
"any
hazard
....
"
§205.44(b)
(2) (A) (ii),
§205.44(g),
§205.44(g)
(1)
section 18(b)(l)(B) of the FHSA. As
noted earlier,
this advisory opinion will address only possible
preemption of the provisions in the Texas requirement that apply
to toy firms.
• -- - • --
-r----
----
-
- -·-------·---
- ---
"hazardous
substance
11
"any
1 ( 4) ,
"are
confGrm
[FHSA] ....
11
§§205.4l(c)
2A,
"any
hazard
....
"
§205.44(b)
(2) (A) (ii),
§205.44(g),
§205.44(g)
(1)
(2),
2.
•
Aaron Locker, Esq.
--Page Three--
The Texas Hazardous Substances Act, a state law patterned
after the FHSA, defines the term "hazardous substance" to include
"any toy or other article other than clothing intended for use by
children which presents an electrical, mechanical, or thermal
hazard."
Section 1(4), Article 4476-13, V.T.C.S.
Implementing
regulations,
which use the same definition, state that they "are
designed to conform to and be supplemental to the applicable
provisions and requirements of the [FHSA]...."
§§205.41(c) and
42.
3.
A recent amendment to the Texas Hazardous Substances Act
requires registration and payment of a $150 annual fee by
manufacturers, repackers, and distributors of hazardous
substances (excluding retailers, unless they distribute hazardous
substances made to their specifications), prior to their doing
business in the state.
Section 2A, Article 4476-13, V.T.C.S.
Regulations implementing the amendment again define hazardous
substance to include "any toy or other article other than
clothing intended for use by children which present% an
electrical, mechanical, or thermal hazard.... "
§205.44(b) (2)(A) (ii), 10 Tex.Reg. 3768 (Sept. 27, 1985).
The implementing regulations specifically apply the
registration and fee requirement to manufacturers of hazardous
substances "whose products might normally be banned, but who meet
specific exemption criteria enabling their products to be sold in
Texas ...."
§ 205.44(g), Id.
The two examples of such products
provided in the regulations are toy electric trains and toy caps.
§205.44(g) (l) and (2), Id
enting regulations specifically apply the
registration and fee requirement to manufacturers of hazardous
substances "whose products might normally be banned, but who meet
specific exemption criteria enabling their products to be sold in
Texas ...."
§ 205.44(g), Id.
The two examples of such products
provided in the regulations are toy electric trains and toy caps.
§205.44(g) (l) and (2), Id.
Discussion
Based on the FHSA preemption provision, the Texas
requirement would be preempted if (1) an FHSA requirement has
been established to protect against a risk of illness or injury,
(2) the Texas requirement is designed to protect against the same
risk,
and (3) the Texas requirement is not identical to the FHSA
requirement.
Unless all three criteria are satisfied, there is
no express preemption under section 18 (b) (1) (B) of the FHSA. As
noted earlier, this advisory opinion will address only possible
preemption of the provisions in the Texas requirement that apply
to toy firms.

Aaron Locker, Esq.
--Page Four--
1. FHSA requirements.
Numerous FHSA requirements apply
toys that present electrical, mechanical, and thermal risks.
not every such toy or risk is covered by a regulation,
there are broad regulations for electrical toys, toys intended
for children under eight containing sharp points and edges, toys
intended for children under three containing small parts, and
others.
These regulations; apply to all toys that
present the electrical, mechanical,
or thermal risks addressed,
and not only to the toys that fail to meet the established safety
criteria. In particular,
their applicability does not depend on
whether they are classified under the FHSA as "hazardous
substances."
Drawing a substantive distinction between the
types of regulations discussed earlier--the type used to regulate
compared with the type used to regulate electrical toys--is
not justified because they only differ in regulatory format.
2.
Texas requirement
ished safety
criteria. In particular,
their applicability does not depend on
whether they are classified under the FHSA as "hazardous
substances."
Drawing a substantive distinction between the
types of regulations discussed earlier--the type used to regulate
compared with the type used to regulate electrical toys--is
not justified because they only differ in regulatory format.
2.
Texas requirement.
-
-
Neither the Texas
nor
its implementing regulations state directly whether any risk(s)
of injury is being addressed.
In addition,
I am unaware of any
. legislative history or other explanatory documents that are
relevant to this question.
The Texas requirement might be
protecting against electrical, mechanical, and thermal risks
presented by toys,
perhaps by identifying firms that make such
toys to facilitate any recalls that become necessary.
However,
it is alternatively possible that the requirement is only
intended to raise revenue for the state and not address any risk
of injury at all.
3.
identicalness.
The Texas requirement, for registration
and annual payment of a' fee,
applies to firms that distribute or
make any toy presenting an electrical, mechanical, or thermal
hazard.
In contrast,
the Commission requirements ban toys that
present an electrical, mechanical,
or thermal risk because of
failure to meet established safety criteria.
so
safety cr
responsib
requireme
distribut
or
Commissio
lo
as a toy complies with the Commission's
it eria,
its manufacturers and distributors have n
il
under Commission regulations.
Under the
nt
firms must register if they manufacture or
e any toy presenting a potential electrical,
1 risk,
regardless of whether such toys comply wi
n regulations addressing those risks.
i fied
other
T'exas
nical,
h the
While
caps,
therma
,ng
ities
,,
.,;.,
potentiallv
requ,irernent
spec
0
mecha
t
to
two
Aaron Locker, Esq.
--Page Four--
1. FHSA requirements.
Numerous FHSA requirements apply to
toys that present electrical, mechanical, and thermal risks
a potential electrical,
1 risk,
regardless of whether such toys comply wi
n regulations addressing those risks.
i fied
other
T'exas
nical,
h the
While
caps,
therma
,ng
ities
,,
.,;.,
potentiallv
requ,irernent
spec
0
mecha
t
to
two
Aaron Locker, Esq.
--Page Four--
1. FHSA requirements.
Numerous FHSA requirements apply to
toys that present electrical, mechanical, and thermal risks.
While not every such toy or risk is covered by a regulation,
there are broad regulations for electrical toys, toys intended
for children under eight containing sharp points and edges, toys
intended for children under three containing small parts, and
others.
These regulations; apply to all toys that potentiallv
present the electrical, mechanical,
or thermal risks addressed,
and not only to the toys that fail to meet the established safety
eri ter ia. In particular,
their applicability does not depend on
whether they are classified under the FHSA as "hazardous
substances."
Drawing a substantive distinction between the two
types of regulations discussed earlier--the type used to regulate
caps, compared with the type used to regulate electrical toys--is
not justified because they only differ in regulatory format.
2. Texas requirement-
Neither the Texas requirement nor
its implementing regulations state directly whether any risk(s)
of injury is being addressed.
In addition,
I am unaware of any
legislative history or other explanatory documents that are
relevant to this question.
The Texas requirement might be
protecting against electrical, mechanical, and thermal risks
presented by toys, perhaps by identifying firms that make such
toys to facilitate any recalls that become necessary.
However,
it is alternatively possible that the requirement is only
intended to raise revenue for the state and not address any risk
of injury at all.
3.
identicalness
this question.
The Texas requirement might be
protecting against electrical, mechanical, and thermal risks
presented by toys, perhaps by identifying firms that make such
toys to facilitate any recalls that become necessary.
However,
it is alternatively possible that the requirement is only
intended to raise revenue for the state and not address any risk
of injury at all.
3.
identicalness.
The Texas requirement, for registration
and annual payment of a' fee, applies to firms that distribute or
make any toy presenting an electrical, mechanical, or thermal
hazard.
In contrast,
the Commission requirements ban toys that
present an electrical, mechanical,
or thermal risk because of
failure to meet established safety criteria.
so long as a toy complies with the Commission's specified
safety criteria,
its manufacturers and distributors have no other
responsib ilities under Commission regulations.
Under the T' exas
requirement, firms must register if they manufacture or
distribute any toy presenting a potential electrical, mechanical,
or thermal risk,
regardless of whether such toys comply with the
Commission regulations addressing those risks.

Aaron Locker, Esq.
--Page Five--
This situation has some similarities to one addressed by a
federal court in 1983.
Juvenile Products Manufacturers
Association,

568
714, 716 (E.D.N.Car.
1983).
North
requiring manufacturers to undergo a
fee-based verification process for compliance of their child
passenger restraint
(car seats) with the applicable
federal standard:
The court held North Carolina's law to be
preempted,
under a federal statutory scheme that is similar
the FHSA scheme.
The court concluded that
Congress
sought joint enforcement by both
the federal and state governments to insure
the legislation's success.
While
the states play an important role in the
success of the federal standards, that role
must be performed within the prescribed
limitations
The court held North Carolina's law to be
preempted,
under a federal statutory scheme that is similar
the FHSA scheme.
The court concluded that
Congress
sought joint enforcement by both
the federal and state governments to insure
the legislation's success.
While
the states play an important role in the
success of the federal standards, that role
must be performed within the prescribed
limitations.
Even when states
to
enforce standards identical to those existing
at the federal level,
they may not do so in any
way which significantly burdens manufacturers....
Id. at 719.
Based on available information, I cannot determine
confidently the validity of the Texas requirement for
registration and annual fee payment by toy firms.
Conclusion
For the reasons discussed above, I conclude that FHSA
requirements have been established to protect against electrical,
mechanical,
and thermal risks presented by toys.
However, I
cannot conclude whether the Texas requirement-is designed to
protect against those same risks or, if so, whether it is
to the
requirements.
Sincerely

Daniel R. Levinson
General Counsel
cc:
Mr. R.D.
Jr.
Texas Department of Health

,
Inc.
v.
Edmisten,
F.Supp.
Carolina
was
systems
to
attemp't.
11 identical
11
FHSli.
yours,
~~,;JI?
dQ_,,~'--'~
Sowards,
Sincerely

Daniel R. Levinson
General Counsel
yours,
~~,;JI?
dQ_,,~'--'~
,
Aaron Locker, Esq.
--Page Five--
This situation has some similarities to one addressed by a
federal court in 1983.
Juvenile Products Manufacturers
Association, Inc. v. Edmisten, 568 F.Supp. 714, 716 (E.D.N.Car.
1983).
North Carolina was requiring manufacturers to undergo a
fee-based verification process for compliance of their child
passenger restraint systems (car seats) with the applicable
federal standard:
The court held North Carolina's law to be
preempted,
under a federal statutory scheme that is similar to
the FHSA scheme.
s
Association, Inc. v. Edmisten, 568 F.Supp. 714, 716 (E.D.N.Car.
1983).
North Carolina was requiring manufacturers to undergo a
fee-based verification process for compliance of their child
passenger restraint systems (car seats) with the applicable
federal standard:
The court held North Carolina's law to be
preempted,
under a federal statutory scheme that is similar to
the FHSA scheme.
.
The court concluded that
Congress sought joint enforcement by both
the federal and state governments to insure
the legislation's success.
While
the states play an important role in the
success of the federal standards, that role
must be performed within the prescribed
limitations.
Even when states attempt to
enforce standards identical to those existing
at the federal level, they may not do so in any
way which significantly burdens manufacturers ....
Id. at 719.
Based on available information, I cannot determine
confidently the validity of the Texas requirement for
registration and annual fee payment by toy firms.
Conclusion
For the reasons discussed above, I conclude that FHSA
requirements have been established to protect against electrical,
mechanical,
and thermal risks presented by toys.
However, I
cannot conclude whether the Texas requirement-is designed to
protect against those same risks or, if so, whether it is
"identical" to the FHSA requirements.
Sincerely yours,
 .s e J..
Daniel R. Levinson
General Counsel
cc:
Mr. R.D. Sowards, Jr.
Texas Department of Health

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- [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_307. Check the current official text before relying on it. Not legal advice.