PublishedOpen access

United States · Governance · Issue #3 · 21/09 – 27/09

CPSC adopts interim delegations ahead of a possible loss of quorum

In August 2025 the Consumer Product Safety Commission adopted interim delegations covering enforcement and regulatory work as it prepared for Commissioner Douglas Dziak's departure and the possibility that the Commission would lack a quorum.

What the evidence says

Acting Chairman Peter Feldman said on 19 August that he and Commissioner Dziak were preparing directives and delegations to maintain operations after Dziak's expected departure. The statement described the Commission's statutory power to delegate functions while noting an exception for certain subpoena authority.

Three separate CPSC Records of Commission Action say Feldman and Dziak voted 2-0 to adopt interim directives covering civil and criminal enforcement, adjudicatory enforcement and regulatory authorities on 22 August 2025.

Later CPSC records show Feldman acting on behalf of the Commission under ID001 in a civil-penalty matter. That later use demonstrates that the delegation had operational consequences, but it does not mean a single Commissioner possessed every power of the full Commission; the text and limits of each directive remain controlling.

Why it matters

The useful distinction

Delegation can keep defined enforcement or rulemaking functions moving when a multi-member agency lacks a quorum. It is not a substitute for checking which power was delegated, to whom, for how long and with what review safeguards.

Scope note

This briefing is an independent summary of the evidence sources below. Context-only links are not used as factual authority. It does not establish that a product, organisation or listing is unsafe, unlawful or non-compliant beyond what the evidence reports.