PPB February 2018

| FEBRUARY 2018 | 61 INNOVATE are extensive. What is the responsibility of suppliers and distributors when vulnerabilities are discovered? How will they handle registering users of IoPT devices so that software and firmware can be updated with patches? How will suppliers develop firmware and software patches (to remedy vulnerabilities) without having in- house expertise in circuit board design, microchip programming and other intricacies of IoT devices? Whose responsibility will it be to pay for these fixes and for how long? Will there have to be a new provision added to Section 15(b) of the Consumer Product Safety Act requiring companies to report on security breaches? How will CPSC and other global regulators treat IoT vulnerabilities for product recalls? And how will all this impact insurance policies and premiums? These questions and many more should be adequately addressed before the industry jumps into the deep end of the pool with IoPT devices. So while it will ultimately be very cool to have a lunch box that can send an alert if peanuts are within 50 feet of someone in danger of anaphylaxis, or a backpack that allows a worried mom to track her elementary school child, or pens that can automatically notify the advertiser to send out a new refill when the ink is running dry, you should take the time now to implement an education program in your company to learn about the technology, the cybersecurity issues, the privacy issues, the regulatory issues and how you will evaluate products and vendors when these types of products come to market. Rick Brenner, MAS+, is president of RFBrenner LLC, a strategic consulting company providing a wide range of advisory services to industry participants. He was previously CEO of supplier Prime Line, leading its growth for 12 years until 2016. A founder of QCA and of PPAI’s Product Responsibility Action Group (PRAG), Brenner was chair of PPAI in 2015 and is currently president of International Consumer Product Health and Safety Organization (ICPHSO).