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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