Transcript Standards Carol Pollack-Nelson, Ph.D. and Shelley

The Role & Limitations
of Voluntary Standards
in Consumer Product Safety
ICPHSO 2011
Orlando, FL
February 23, 2011
Carol Pollack-Nelson, Ph.D.
Independent Safety Consulting
Rockville, Maryland
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
Wrap-around Single Cords
Looped Cords
•
Hazard patterns include:
– Looped cords
– Single cord wraps
around the neck
– Inner cords that pull out
to form a loop
Inner Cords
Voluntary Standards
• 1996 – ANSI standard eliminated freehanging 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
Recommendations
– 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.