Looks Like Trump’s Consumer Product Safety Commission Nominee Is Toast
June 30, 2020, Huffington Post
It looks like President Trump’s nominee to lead the CPSC, Dr. Nancy Beck, isn’t going anywhere. It’s just math. Beck’s nomination doesn’t appear to have the votes to clear the Senate Committee on Commerce, Science and Transportation.
Probe Says Boeing Withheld Data Linked To 737 Max Crashes
June 30, 2020, Crain Chicago Business
The Chicago plane maker provided only “limited information” on the flight-control software later implicated in two fatal crashes of the 737 Max as it was being approved by federal regulators, a government watchdog report has found.
As The Pandemic Persists: A Good Sign For Chinese Exports
July 1, 2020, CNBC
As the global economy continues to falter, the interest in Chinese medical supplies is an encouraging sign for the country’s exports — which support a critical part of its economy, as well as millions of jobs
Managing communications And Brand Through A Crisis
July 1, 2020, Forbes
Crises force us to reevaluate our lives. The COVID-19 crisis has been no exception, with its rapid spread immobilizing the lives of hundreds of millions across the globe within a few short weeks.
The Technology 202: IBM And Notre Dame Team Up On New Tech Ethics Lab
July 1, 2020, The Washington Post
The University of Notre Dame unveiled a new Tech Ethics Lab with the backing of IBM, which will conduct research on some of the most pressing dilemmas confronting the field — from how to build privacy into products to weighing how police should be able to use tools such as facial recognition without perpetuating racial biases.
EPA Publishes Final Risk Evaluation For Methylene Chloride
June 30, 2020, Safety+Health
Methylene chloride poses “unreasonable risk” to workers under certain conditions, according to a final risk evaluation recently released by the Environmental Protection Agency, which now is compelled to propose within one year regulatory action to mitigate the chemical’s hazards.
Needle In A Haystack: Learning To Prioritize Your Customer Data
July 1, 2020, Retail Customer Experience
Every minute of every day, retailers collect massive amounts of customer data — but they’re far from determining how best to leverage it.
Study: All PFAS Pose Risk To Public Health, Should Be Treated As A Class
June 30, 2020, Environmental Working Group
In a study published recently in the journal Environmental Science & Technology Letters, a group of U.S. and international scientists emphasized that the current approach to regulating and managing the harm of the toxic fluorinated chemicals known as PFAS has failed to protect public health.
Opinion: The Most Effective Crisis Leadership Advice? Just Lead.
June 30, 2020, Forbes
I work as a personal and corporate crisis manager, and my answer seems to mystify many of those leaders who ask for my perspective. “It’s simple; you just lead,” I explain.
China Demands Covid-19 Declaration On U.S. Exports
June 26, 2020, The Packer
Chinese customs officials are demanding U.S. ag exporters sign a form guaranteeing their exports are free from COVID-19, trade and government reports say. That demand has sparked pushback from trade industry leaders and the Trump administration.

Coronavirus Complicating Company Recalls
June 25, 2020, AZ Family.com
The CPSC website has an alert warning consumers that some recall remedies may not be available because of COVID-19. A CPSC official say it’s “a difficult situation”, but the agency is still trying to find the products that need to be recalled
J&J Baby powder Verdict Upheld, But Damages Cut
June 23, 2020, Reuters
A Missouri appeals court rejected Johnson & Johnson’s bid to throw out a jury verdict in favor of women who blamed their ovarian cancer on its baby powder and other talc products, but reduced damages by more than half, to $2.12 billion.
Physicians Seek Regulation Of Digital Advertising To kKds
June 23, 2020, WREG (CNN Wire)
No less than $900 million is spent marketing snack foods, video games and sugary drinks to kids each year. Opposed to these unhealthy choices, a pediatric group urges lawmakers to take bold action.
New Study Shows Firefighters Face Possible Risk From PFAS
June 23, 2020, Bloomberg Law
Waterproofing chemicals in the protective gear worn by firefighters may be exposing them to “significant quantities” of potentially toxic fluorochemicals, according to a new study from the University of Notre Dame.
Bayer Settles Roundup Lawsuits For Up to $10.9 Billion
June 24, 2020, St. Louis Post-Dispatch
Bayer AG said it has agreed to spend almost $11 billion to settle U.S. lawsuits claiming that its widely-used weedkiller Roundup caused cancer. It’s also paying up to $400 million to settle dicamba lawsuits and $820 million to settle PCB lawsuits.
Crisis Communications Redefined: Why Planning Is Key
June 24, 2020, Themediaonline
The pandemic has made it hard for businesses to operate and the need for suitable and regular communication with employees, clients, customers, suppliers, regulators, and other stakeholders has increased tremendously.
Leadership lesson: Diffuse Functional Leadership Throughout Your Organization
June 23, 2020, Phoenix Business Journal
We read, write and speak much about leadership. Yet we often erroneously see it as generic and relative only to the CEO of an organization. Yes, CEO leadership skills and behaviors are critical. But how do you apply them to the various functional leaders of the organization.
Report Uncovers Toy Safety Concerns Across: TIE Pushes For New Laws For Online Marketplaces
June 23, 2020, Toy News
A new report by Toy Industries of Europe has made the striking discovery that 97 per cent of almost 200 toys bought from third-party sellers on four online marketplaces in Europe did not comply with the strict EU toy safety regulations. The report – EU Toy Safety: The problem of unreputable sellers on online marketplaces – also found that 76 per cent of those tested had defects that made them dangerous for children.
Grainger Agrees: To Divest Grainger China
June 22, 2020, Yahoo Finance
Grainger, the leading broad line supplier of maintenance, repair and operating (MRO) products serving businesses and institutions, today announced it has entered into a definitive agreement to sell its distribution business in China, Grainger China LLC.
3 ways: Retailers Can Adjust Strategy In A Global Pandemic
June 23, 2020, Total Retail
As retailers scramble to adjust their strategy to be more focused on e-commerce while improving the customer experience, they should focus on three core tactics — now and post-pandemic — to continue generating revenue while meeting the changing needs of consumers.

Scientists warn against CPSC nominee Dr. Nancy Beck
June 16, 2020, NPR
More than 90 leading scientists signed a letter arguing that Dr. Beck’s work at the EPA “consistently disregarded scientific best practices, favor[ed] chemical manufacturers, and put vulnerable people in harm’s way.”
Health Canada recalls unsafe hand sanitizer products
June 16, 2020, Cosmetics Design.com
Canada’s safety agency has recently warned consumers of the risks associated with hand sanitizer products made with unapproved ingredients and called for 12 companies to stop selling unsanctioned sanitizer.
5 ethical challenges employers will face as they reopen
June 17, 2020, HR Dive
Businesses are reopening as cities and states around the country begin to emerge from novel coronavirus pandemic lockdowns. The ethical challenges to businesses in this new normal may be familiar but take on additional meaning and priority.
Craigslist and Facebook Marketplace still list incline sleepers
June 18, 2020, Consumer Reports
A year after the products were linked to deaths, Sears, Kmart, and many others have pulled them, but a few holdouts remain.
ACCC: E-scooter giant Lime failed to disclose safety issues
June 18, 2020, ABC.net.au
There are growing calls for an overhaul of e-scooter laws after Australia’s consumer watchdog found Lime failed to disclose safety issues it was aware of to riders.
Post-COVID supply chain probably won’t be what you expect
June 17, 2020, Forbes
There has been a lot of discussion as the coronavirus crisis progressed about the U.S. supply chain. Now that things seem slowly to be calming down, let’s take a look at what changes are actually a good idea, and at what’s really likely to happen.
CPSC will hold webinar on improvements to SaferProducts.gov
June 18, 2020, National Law Review
The Consumer Product Safety Commission (CPSC) will hold a public webinar on July 1, 2020, to receive information from interested parties about changes to CPSC’s Publicly Available Consumer Product Safety Information Database, www.SaferProducts.gov.
Key Republican jeopardizes nomination of Trump consumer safety pick
June 17, 2020, The Hill
Sen. Shelley Moore Capito (R-W.Va.) will vote to oppose Nancy Beck’s nomination for the chair of the consumer safety agency, which, barring a Democratic defection, would lead to a 13-13 vote and the ultimate failure of the nomination.
13 strategic approaches to communicating major company changes To employees
June 11, 2020, Forbes
In business, change is the only constant. Evolution is what makes a company competitive, and many times, that change happens from the top of the organization. However, leaders must be able to communicate that change effectively. While business heads may dream up things that must occur, it’s up to those lower down the hierarchy to understand the goals and intentions of those decisions.
Traveling this summer? 12 things to keep you safe and comfortable
June 17, 2020, USA Today
As states lift their stay-at-home orders after months of quarantine, more and more people are beginning to venture out. But they aren’t just heading to the grocery store or the gym—some people are starting to travel again, as well.
We’re all in it together’ attitude drives consumer confidence in COVID-19
June 17, 2020, Total Retail
Despite the unprecedented challenges retailers are facing as a result of the COVID-19 pandemic, their resilience and determination is both impressive and encouraging.

Hand Sanitizers Can Ignite, Cause Burns, Experts Warn Workers
June 10, 2020, Safety+Health
Although alcohol-based hand sanitizers can help prevent the transmission of COVID-19, the liquid solutions – which contain isopropyl alcohol – are flammable and can cause burn injuries, the Mechanical Contractors Association of America is warning workers.
Videos Of Ikea Furniture Tip-Overs Highlight The Need For Stronger Stability Standards
June 10, 2020, Consumer Reports
Home videos showing toddlers narrowly evading injury prompt calls for product safety reform.
Why Empathy Is Important in Leaders Right Now
June 10, 2020, Entrepreneur
Right now, you need to practice social, not emotional, distancing. Your team deserves an empathetic leader who understands what people are going through. Making the right decisions are challenging in good times. Harder amid a global pandemic.
Cybercrime Against Retail Brands Is Up 41% During Pandemic
June 9, 2020, TechRepublic
A dramatic uptick in scams, counterfeiting, and hacking plague retail and e-commerce industries during the coronavirus crisis, as businesses try to define their new normal, according to a report from brand intelligence agency, Red Points.
Exclusive: Chanel, Revlon, L’Oreal Pivoting Away From Talc In Some Products
June 9, 2020, WTVB Radio
Chanel, Revlon and L’Oreal, three of the biggest brands in cosmetics, are quietly moving away from using talc in some products as U.S. cancer lawsuits and consumer concerns mount.
My Story: Gary Spagnuolo
May 24, 2020, Health+Safety
My start in safety was an unwanted accident. I began in 1970, about the same time OSHA was created. The factory I worked in, in an attempt to be proactive, determined it needed a safety manager. So, for whatever reasons, they chose the quality control manager – me
‘Extremely hazardous’: Alert Warns Against Using Ethylene Oxide To Sterilize Masks, Respirators
June 9, 2020, Health+Safety
Ethylene oxide should not be used to sterilize filtering facepiece respirators for reuse because “this extremely hazardous toxic chemical poses a severe risk to human health,” the Washington State Department of Labor & Industries warns in a new alert.
How Black Dolls Can Help Teach Kids About Race, Identity And Self-Esteem: ‘It’s Important To Give Black Children Childhood’
June 10, 2020, Yahoo Life
With social injustice still very prevalent in our society, racial identity and representation are as important as they have ever been and the teachings start young. Amid the protests following the killings of George Floyd and Breonna Taylor, Yelitsa Jean-Charles, founder and CEO of Healthy Roots Dolls, went viral on Sunday after sharing a picture on Twitter of herself and her product, a beautiful black doll named Zoe, who has a wide nose, full lips and curly hair.
Canada Cracks Down On COVID-19 Related Product Advertising Claims
May 29, 2020, Smart & Biggar
Industry must be careful not to make claims that transform an unregulated product into one that requires authorization by Health Canada; care must also be taken to ensure that even if a product already has Health Canada authorization, no claims are made which exceed what is lawful.
A New Era For Consumer Goods
June 8, 2020, Future Trading Charts
More efficient, sustainable, practical and natural. That’s probably how products will look like after the global pandemic caused by COVID-19. But these alone won’t be enough to ensure the longevity of companies or their sales success, whether products are sold on the supermarket shelf or online. The pandemic will create new habits and trends.
Just Launched “Reuters Events” Transform Europe Virtual Series
June 10, 2020, Ethical Corporation
Ethical Corporation by Reuters Events launches the new Reuters Events Transform Europe Virtual Series to address the big issues facing businesses as they look to deliver a new blueprint fit for a worldwide recovery post COVID-19.

Hurricane season: CPSC Says Be Prepared During Pandemic
June 4, 2020, Food Poisoning Bulletin
The CPSC is offering tips on safety during the hurricane season. CPSC Acting Chairman Robert Adler said “Powerful storms and hurricanes are likely to affect millions of Americans. That is why we urge everyone to be informed, be prepared, be safe.”
He Saved Us From Defective Products; Now He Needs Our Help
June 2, 2020, Carroll Times Herald
In a box store or on a retailer’s website you’ll see some of the horrors he’s dedicated a professional life to removing from the seemingly safe shelves where Americans grab the stuff of quick errands or big birthday bashes. Now he needs our help.
Our Leaders Of Tomorrow Are Going To Need These 4 Rare Skills
June 4, 2020, Forbes
Gone are the days when the leaders that made sense for humanity were “the big guy who fights good.” And gone are the days when it was smart to pick “the guy who says he has all the answers.” Tomorrow’s leaders need to be systems thinkers.
8 Small Fixes That Make Your Kitchen Safer
June 4, 2020, She Knows
The kitchen may be the heart of the home, but it can also be dangerous. Especially if you have little ones. There are plenty of things that can go wrong where you cook.
Leadership During a Crisis Means More Than Keeping The Lights On
June 3, 2020, CMSWiRE
The changing nature of the COVID-19 crisis has created extraordinary challenges for leaders. What worked when we were all struggling to make it through the day, may not be serving you now as we’ve all settled somewhat into “the new normal.”
Australian Consumers Need Better Product Safety Laws
June 4, 2020, Manufacturers Monthly
Australia’s product safety laws are poor in comparison to some other nations and this means that there are 6.6 million unsafe products currently under voluntary recall that have been allowed to remain in Australian homes, according the the ACCC.
Tackling Legal And Business Challenges Caused By The COVID-19 Pandemic
June 4, 2020, National Law Review
Virtually every consumer-facing business has been impacted by shelter-in-place orders, supply chain issues, or new uses for products in a socially distanced society. Many are making headway in adapting to the “new normal” as lockdowns are lifted, employees return to work, and facilities are gradually reopened to the public. In the face of these challenging circumstances, it is important that companies take an analytical step-by-step approach, and exercise diligence in following those steps even as the cries for a speedy resolution get louder.
Opinion: An Unexpected Risk Of COVID-19: Canceled Supplier Audits
June 4, 2020, Supply Chain Dive
As society continues to adjust to the strange new world brought on by COVID-19, we need to react in a way that prioritizes the health and well-being of people and society while ensuring business continuity. Maximizing supplier visibility and health while trying to mitigate disruptions is key for success. This highlights a new challenge as ongoing travel restrictions and quarantines are requiring many companies to cancel on-site supplier audits, inhibiting progress and increasing risk exposure.
UK’s Post-Brexit Product Liability And Safety Laws ‘Could Cause Confusion’
June 3, 2020, Out-Law Analysis
Changes to UK product liability and product safety laws after the UK’s withdrawal from the EU will lead to changes for companies bearing liability and regulatory responsibilities for unsafe products.
Minnesota Bans Toxic Chemical TCE; EPA Twiddles Thumbs
June 4, 2020, Safer Chemicals, Healthy Families
Minnesota recently became the first state to ban the dangerous chemical trichloroethylene (TCE), a volatile organic compound that’s used in manufacturing processes and consumer products.

Current toxic chemical legislation successes
May 26, 2020, National Caucus of Environmental Legislators
Legislators from around the country have made significant progress on regulation of toxic chemicals. Here are highlights of recent successes,  tracked by a caucus of legislators focused on environmental matters.
Making home safe for kids this summer
May 28, 2020, New York Times
As stay-at-home orders drag on, parents and caregivers will need to be more aware than ever of accident risks in the home. Experts, including CPSC staff, identify common hazards in the home and what can be done to prevent accidents.
Making the best of bad reviews
May 27, 2020, Harvard Business Review
Unfair negative reviews, that stem from unrealistic consumer expectations or are focused on something outside of the company’s control, are common on user-review websites. Given the prevalence of unfair negative reviews, how should companies respond?
COVID-19 shopping habits will remain; Brands race to adapt
May 27, 2020, CNN Business
Every week senior P & G executives check in with each other about their customers. They are not alone in tracking their customers, what they’re buying and how their needs are changing.
4 must-have skills for leaders post-Covid-19
May 28, 2020, Forbes
Now more than ever before it is important for leaders to have strong, effective communications skills. With most stakeholders (including employees) working remotely, effective communications have never been more difficult, but also more important.
My Story: Gary Spagnuolo
February 25, 2018 Safety and Health Magazine
“My path to becoming a safety professional began on Feb. 19, 2000, when I was in my basement building a cabinet. I was using my table saw with a three-quarter-inch dado blade. The board I was cutting kicked backed…” The mishap changed Gary’s life.
CPSC sued over lack of access to consensus standard incorporated into CPSC regulation
May 26, 2020, National Law Review
An interesting and potentially very important case not only in CPSC world but for thousands of statutes and regulations is pending in a federal court of appeals. On May 18th, a civil rights group filed its opening brief against the Consumer Product Safety Commission in the 3rd Circuit case Milice v. CPSC, Docket. No. 20-01373 (3d Cir. Feb 20, 2020).
“The mock recall”: what to do now to avoid a potential recall catastrophe
May 26, 2020, JDSupra
If you are a manufacturer or importer of consumer products, and a potential “catastrophe” shows up on your doorstep in the form of an unexpected product safety complaint, preparing now could prevent an existential threat to the company later.
Hotel industry across U.S. & Canada unite around enhanced safety, cleaning standards
May 21, 2020, American Hotel & Lodging Association
As states across the country navigate reopening and hotels begin to safely welcome back guests, the American Hotel & Lodging Association (AHLA) today announced that hospitality leaders across North America have endorsed Safe Stay, AHLA’s enhanced industry-wide cleaning guidelines.
A guide to evaluating and advertising COVID-19 products
May 26, 2020, Law360
As businesses consider how to reopen safely, they may be evaluating products, such as disinfectants, sanitizers, ultraviolet sterilizing devices, antimicrobial coatings and air filtration devices, that could help mitigate the transmission and spread of COVID-19 in the workplace or retail establishment.
Gardening safety tips
May 27, 2020, Akron Beacon Journal
You may not associate gardening with the possibility of danger but there are some risks to keep in mind, especially if you’re active in the wintertime. According to the Consumer Product Safety Commission, emergency rooms treat more than 400,000 outdoor garden tool-related accidents each year.

May 2020: Important happenings at the CPSC
May 18, 2020, Retail and Consumer Products Law Observer
There have been several important happenings in May at the CPSC, including in Leadership, Hearings and Regulatory Activities and Enforcement.
J&J talc phaseout possible prelude to settling lawsuit
May 20, 2020, Boston Globe
Johnson & Johnson’s decision to phase out the talc-based version of its baby powder may signal a move out of litigation-defense mode over allegations the product causes cancer and preparing for a global settlement of almost 20,000 pending claims.
Good leaders can overcome institutional inertia in a crisis
May 18, 2020, Harvard Business Review
Although Covid-19 is clearly a catastrophe, it offers what social scientists craves: a “natural experiment” that compares different responses to similar shocks. Consider Lombardy and Veneto, the regions where the virus first emerged in Italy.
UA, Clorox, Cleveland Clinic join to promote cleanliness
May 20, 2020, CRSNewswire
United’s “CleanPlus” brings together a most trusted name in disinfection and the country’s leading medical experts to develop protocols designed to help keep customers safe at the airport and onboard.
CPSC issues tips to avoid injury outdoors during quarantine
May 20, 2020, CPSC
In response to the current crisis, the CPSC has created a new series of Home Safe Checklists that focus on outdoor activities. Print the lists that work for you, and spend a few moments checking off the safety items. When so much in the world seems beyond control, these checklists are simple, clear steps you can take for the safety of your family.
New antiviral fabrics could attract luxury shoppers
May 20, 2020, Vogue Business
Can your clothing protect you from Covid-19? A leading Italian luxury manufacturer says it has developed an antiviral fabric that may, and major luxury brands are snapping it up.
Spike in product recalls expected in aftermath of COVID-19
May 21, 2020, KCP News
Product recalls are still occurring, but the process has become more challenging and time-consuming as a result of the current regulatory and business environment, according to Stericycle Expert Solutions’ First Quarter 2020 Recall Index.
330+ major businesses call for a more resilient, sustainable economy
May 20, 2020, B3LMedia
CEOs and representatives from more than 330 businesses, including Adobe, Capital One, CommonSpirit Health, DSM North America, Dow, Eileen Fisher, General Mills, Mars, Inc., Microsoft, NIKE, Salesforce and VISA called on a bipartisan group of federal lawmakers to build back a better economy by infusing resilient, long-term climate solutions into future economic recovery plans.
Despite COVID, CPSC policy discussions forging ahead – sort of
May 19, 2020, National Law Review
Much like the rest of the world, the U.S. Consumer Product Safety Commission (CPSC) and its constituents and stakeholders are trying to determine how to operate amid the historic disruptions of the COVID-19 pandemic. Some CPSC functions – particularly staff-driven operations like recalls – are functioning reasonably well even with a dispersed, telecommuting workforce. But other matters – especially the policy questions that commissioners must answer – present a greater challenge.
Opinion: Is Trump challenging Mother Nature to a duel?
May 20, 2020, The New York Times
if you define wearing a mask, or restrictions on the size of religious gatherings, as a sign of disrespect for your personal freedom — not an act of respect for Mother Nature when she has the whole world in her hands — you’re making a huge mistake.

Emails: Trump nominee involved in shelving CDC guidelines
May 14, 2020, Time
Internal government emails show that Dr. Nancy Beck was involved in sidelining detailed guidelines to help communities reopen during the pandemic. Democrat on Senate committee questions role played by nominee.

Customs officers seize 5,000 lead-contaminated stuffed toy ducks
May 13, 2020, Fox28 Media
U.S. Customs and Border Protection officers in Savannah recently seized 5,000 stuffed toy ducks after they were discovered to have excessive amounts of lead. CBP officers sent the toys to the Consumer Products Safety Communion for further testing.

Class action lawsuit filed against Ikea over faulty furniture recall
May 12, 2020, Consumer Reports
A class action lawsuit was filed against Ikea over a faulty furniture recall of the Malm dresser. Years after the company pulled millions of these unsafe dressers, the suit alleges, consumers are denied refunds.

In-store safety: Shoppers ready to buy, caveats remain
May 13, 2020, Forbes
It’s not surprising that apparel retailers are looking optimistically toward the lift of lockdowns. But even shoppers who are willing to go back in-store are envisioning an experience that bears little resemblance to how we shopped in the past.

Costco’s Kirkland and other store brands are having a moment
May 12, 2020, CNN
Store-brand toilet paper used to be a second choice. But what may have once been the loneliest item on the shelf is now in high demand as Americans increasingly experiment with alternatives to their favorite consumer product labels.

How COVID is changing kids’ play patterns
May 12, 2020, Kidscreen
Thanks to COVID-19, the way kids are playing is changing and some of these effects will have longer-term implications. Looking at the pandemic’ effect on toys, total US toy sales grew by 26%. And, board games have doubled in popularity among kids.

COVID-19: Steps to protect brands as at-risk retailers face bankruptcy
May 6, 2020, National Law Review
Multiple American flagship retailers, including major department stores, now stand on the verge of bankruptcy, and the “death of the department store” has been well-documented in the media, with numerous retailers already furloughing or laying off staff and closing doors, with more to come.[1] If they have not done so already, product manufacturers must prepare for the possibility that their retail partners may face insolvency and file for bankruptcy.

Scope of online reviews: In litigation evolving
May 10, 2020, National Law Review
Online reviews can be used in litigation matters and, if employed appropriately, can be a useful source of data for expert witnesses. For example, in consumer fraud or product liability cases, online reviews can be analyzed to determine whether consumers identified and commented on alleged defects.

Global juvenile products market assessment 2020-2025
May 13, 2020, Business Wire
The global juvenile products market grew at a CAGR of 6.8% during 2014-2019. Looking forward, the market is anticipated to grow moderately during the next five years. The growth of global juvenile product market is primarily driven by increasing disposable income levels, emergence of e-commerce platforms, growing working women population, rising parental concerns towards child safety, and implementation of various regulatory policies pertaining to child protection.

Product shortages: Supply chains must become less efficient
May 12, 2020, Forbes
Supply chain disruptions are wreaking havoc with everything from supplies of toilet paper to meat. To address this issue in the post-COVID world, businesses are rapidly shifting supply chains from global to local and from efficiently lean to flexibly risk-proof.