ICPHSO 2011Orlando, 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 productCompliance 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 15-30 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 500oF– 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