ICPHSO 2011 Orlando, FL February 23, 2011 Carol Pollack-Nelson, Ph.D. Independent Safety Consulting Rockville, Maryland The Role & Limitations of Voluntary Standards in Consumer Product Safety

Acknowledgment Shelley Waters Deppa, co-author Safety Behavior Analysis Olney, Maryland

Benefits of Voluntary Standards Bring together concerned parties, allowing for discussion of hazards and remedial approaches Establish minimum design and testing criteria as a means of addressing a safety issue Faster development time than mandatory standards

Limitations of Voluntary Standards  Consensual process - Standard is the result of what everyone could agree to Doesn’t cover all hazards May not address hazards as stringently as necessary  Pertains to a class of products; not a particular product  Compliance does not ensure a safe product

Window Blind Cords 1985 – 35+ deaths –Strangulation in exposed window blind cords –Ages 6 months – 6 years –In cribs, beds, climbing on furniture Hazard patterns include: –Looped cords –Single cord wraps around the neck –Inner cords that pull out to form a loop Looped Cords Wrap-around Single Cords Inner Cords

Voluntary Standards 1996 – ANSI standard eliminated free- hanging looped cords. Required warning labels 2002 – ANSI standard revised to address inner cords from pulling out Today – Cord deaths continue –Long cords wrap-around the neck –Tassels entangle to form a loop Future - Voluntary standard should eliminate the hazard

Hunting Tree Stands Used to elevate hunter above the ground Climb to feet Biggest risk is falls Voluntary Standard requires inclusion of full body fall harness (since 2004)

Voluntary Standards Today – Strangulation deaths in full-body harnesses Problem - Standard doesn’t address practical aspects of falling in a full-body harness –No requirements regarding comfort of harness –Fails to address post-fall self-rescue

Other Examples Gas fireplaces –Glass fronts can reach 500 o F –ANSI standard – limits temperature of metal surround –Some manufacturers limit risk through design –Subcommittee asked to incorporate hazard mitigation into standard, but no action taken to date. Bunkbeds – –ASTM standard to address head entrapment –Head entrapment not permitted in some parts of the bed, but not tested in others –Children have strangled between ladder and side of bed

Conclusions Standards –Can promote safer products –Can also give a false sense of security –Should be viewed as a starting point for individual manufacturers, not an end point

–Assess potential hazards for your product Do a Behavioral Task Analysis to understand how consumers will use your product (foreseeable use and reasonable unintended uses) Know the injury data for similar products –Compare potential hazards against relevant standards Are identified hazards addressed? In some cases, there is no relevant standard –Eliminate the hazard or block access to it, where possible –Take an active role in VS development Initiate a subcommittee where there is none Encourage subcommittee members to speak openly about hazards they are seeing Encourage subcommittees to adequately address all meaningful hazards; preferably through design Consider if existing standards still adequate as technology/market evolves. Recommendations