Next month, the federal agency charged with protecting the public from unsafe consumer products will be holding a public hearing to consider the safety implications of Internet of Things (IoT) devices.
Traditionally, the Consumer Product Safety Commission (CPSC) focuses on protecting consumers from products that may cause fire, electrical, chemical or mechanical hazards. But as devices increasingly are connected to the internet, the CPSC has begun a process of investigating potential harms associated with IoT connected devices.
Specifically, the CPSC is asking for public comment on hazards such as fire, burn, shock, tripping, lacerations, and chemical exposure, and how to mitigate those concerns. The CPSC has no authority over – and will not consider – privacy or data security.
According to the agency, “internet connectivity is … capable of introducing a potential for harm (a hazard) where none existed before the connection was established.” The CPSC intends to use this information to guide its risk management work – and the results could have serious implications for IoT manufacturers.
The CPSC is also looking for information about prevention or elimination of hazards, and information about how a product that is connected to the internet can become hazardous through malicious, incorrect, or careless changes to the operational code. For example, if a consumer remotely activates a cooktop resulting in an inadvertent fire, a generally safe product becomes more dangerous.
The CPSC has also asked for comment about the following topics:
- The effectiveness of voluntary standards
- Devices that may need additional safety controls
- The need for a certification process
- Hazard prediction and unaddressed hazards
- Controls to prevent or mitigate hazards
- Any incidents or injuries that have been caused by IoT products
- Data collection on incidents
- Ways CPSC can collaborate with other agencies or organizations to address outstanding issues
- Consumer education
- The role the government should take in preventing hazards
IoT manufactures may consider submitting comments or making a presentation at the upcoming public hearing. The deadline to request to present at the hearing is May 2nd, the hearing will be held on May 16th, and the deadline for submitting comments is June 15th.
If you would like additional information, please contact IoT attorney Ronald E. Quirk, Jr. at (703) 714-1305 or firstname.lastname@example.org, or Alex Schneider, at (703) 714-1328 or email@example.com. Further information about Marashlian & Donahue’s Internet of Things and Connected Devices practice is available here.