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Sarah Wilson

Sarah Wilson is a litigation and investigations partner who chairs the firm’s market-leading Product Safety Practice Group. Her clients include the world’s largest global consumer and commercial products manufacturers across a range of industries, including consumer packaged goods, automotive vehicles and equipment, aviation, electronics, life sciences, and information technology. Sarah has successfully represented clients in the largest recalls and safety-related investigations in recent history, including airbags, fire extinguishers, single load liquid laundry packets, toxic chemicals in household products, lithium-ion battery-powered laptops, car seats, and electric bikes and scooters. Sarah assists clients in developing cutting edge recall policies, compliance program enhancements, and voluntary safety standards.

Prior to joining Covington, Sarah served in several high-ranking federal government positions, including as a federal judge on the U.S. Court of Federal Claims, as Senior and Associate Counsel to the President, and as a Deputy Assistant Attorney General and Trial Attorney in the Department of Justice.

Contact:Read more about Sarah WilsonEmail

California’s new autonomous vehicle regulations create the state’s first pathway for testing and deploying heavy-duty AVs while imposing a more rigorous permitting, safety-case, reporting, and enforcement framework for all AV manufacturers.

Finalized by the California Department of Motor Vehicles (the DMV) on April 28, 2026, the regulations (the Regulations) introduce significant new safety and oversight…

Continue Reading California’s New AV Rules Open Door to Heavy-Duty Deployment While Imposing Significant New Compliance Obligations

NHTSA recently issued a First Amended Standing General Order requiring electronic portal submission of crash incident data for automated and semi-autonomous vehicles. As of August 12, 2021, automated motor vehicle manufacturers, motor vehicle equipment manufacturers, and operators will be required to report and upload crash incident data within 24 hours to the NHTSA Incident Report…
Continue Reading NHTSA Amends Standing General Order on Automated Vehicle Crash Reporting

Poison prevention has been one of several top priorities of the U.S. Consumer Product Safety Commission (“CPSC”) during the COVID-19 pandemic. President Trump’s recent speculation about the ingestion of disinfectants as a potential COVID-19 treatment prompted the agency to tweet an urgent safety warning the following day, and product manufacturers have issued similar warning statements about proper use of household cleaning products.

Even before this “ingestion incident,” the CPSC had focused on poison prevention as a top COVID-19 product safety priority. Under the Poison Prevention Packaging Act, originally passed by Congress in 1952 (then the “Poisons Act”) and exclusively enforced by the CPSC, manufacturers are required to test, certify conformance with, and market household cleaning products containing toxic chemicals, as well as prescription drugs and certain over-the-counter drugs (such as aspirin), in special child-resistant packaging.

The U.S. Environmental Protection Agency enforces similar packaging requirements for certain EPA-registered disinfectant products, such as products that exceed specified toxicity levels, under the Federal Insecticide, Fungicide, and Rodenticide Act. Under the Federal Hazardous Substances Act (“FHSA”), enforced by the CPSC, products containing toxic substances must contain precautionary warning statements, such as “Danger” and “Harmful if Swallowed.”

Products that are not compliant with special packaging and labeling requirements are considered misbranded under the Food, Drug, and Cosmetic Act or the FHSA and can trigger mandatory hazard reporting to the CPSC, as well as corrective action such as recalls. Failure to report or late reporting of hazardous or noncompliant products also can trigger government investigations, enforcement actions, and civil or criminal penalties under the Consumer Product Safety Act.

COVID-19 has required the consumer product industry to confront an array of challenges, as businesses seek to protect the health of their employees and consumers, while navigating major supply-chain disruptions, testing lab closures, and unanticipated changes in production and consumer demand for products. Consumer product manufacturers, importers, and retailers should remain vigilant about product safety compliance during this extraordinary time.

Summarized below are the top five points for consumer product companies to keep in mind during the COVID-19 pandemic:Continue Reading Consumer Product Safety Compliance During the COVID-19 Pandemic

Last week, Covington dispatched a team of connected and automated vehicles (“CAV”) practitioners to participate in the Mcity Congress, in Ann Arbor, Michigan.  Lawyers from our Technology and IP Transactions, Public Policy, Product Safety and Liability, and Insurance practice groups presented a series of observations and insights around mitigating liability in the CAV industry, and we saw first-hand what’s happening at the cutting edge of CAV technology.
Continue Reading IoT Update: Who’s at the Wheel? Connected and Automated Vehicles Stakeholders Weigh In from the Mcity Congress

On October 4, the U.S. Department of Transportation published Preparing for the Future of Transportation: Automated Vehicles 3.0 (“AV 3.0”), a policy vision statement that embraces automation as a critical tool to improve motor vehicle safety. AV 3.0 identifies several avenues to remove regulatory barriers to automated driving systems (“ADS”), including potential changes to rules that may stand in the way of driverless vehicles. These changes are of interest to automotive manufacturers, parts and systems suppliers, and technology companies.
Continue Reading IoT Update: DOT Publishes Policy Statement on Automated Vehicles

Recently, the U.S. Consumer Product Safety Commission (“CPSC”) issued a Public Notice announcing that it will be conducting a hearing on May 16, 2018 to receive information from all interested parties about potential safety issues and hazards associated with Internet-connected consumer products.Continue Reading Covington Internet of Things Update: CPSC to Consider Safety of IoT Products

The “Internet of Things” (IoT)—the network of consumer devices connected to the Internet through digital connections and sensors—has dramatically grown over the past five years. A McKinsey analysis estimated that the potential annual economic impact of IoT in 2025 could be between $4 trillion and $11 trillion, with value accruing in manufacturing, urban spaces, human wellness, retail, autonomous vehicles, homes, and other sectors. An analysis by Gartner, Inc. estimated that in 2018, nearly 11.2 billion connected things will be in use globally, and that this figure will surpass 20 billion by 2020.

IoT already has global reach. Nearly one-third of the overall installed IoT base is located outside China, North America, and Western Europe. And although IoT use will continue to grow in commerce and industry, more than 63% of IoT-connected units are already available on the consumer market. Some “smart” consumer products—such as fitness monitors, wearable devices, smart thermostats, and smart TVs—are well-established. In the coming years, connected devices will continue to expand in other categories, including kitchen appliances, toys, and medical devices, among many others.
Continue Reading Covington Internet of Things Update: U.S., U.K., and E.U. Regulators Turn Focus to IoT