|Avoiding Potential Pitfalls in Consumer Safety Standards Development
Consumer product safety standards are the most effective method to improve product safety and reduce injuries. Safety standards affect all products in a given category, not just those made by one manufacturer. They have a greater impact than recalls since even the most effective recalls generally result in the repair or replacement of only a small percentage of products in use by consumers. Eliminating the unsafe product before it is produced is most effective in improving product safety.
In August 1994, baby walkers were associated with more injuries than any other nursery product. Most of the incidents that produced serious injuries or deaths involved babies in walkers falling down stairs. As a result, ASTM Subcommittee F15.17 on Carriages, Strollers, Walkers and Stationary Activity Centers approved a revision in 1996 to standard F 977, Consumer Safety Specification for Infant Walkers, that added new performance requirements to address falls down stairs.
The revision included a performance test simulating a child in a walker moving across a floor, through a doorway, and toward a staircase. The walker is placed on a test platform and accelerated. A walker fails the test if it can pass through a 36-inch-wide [91-cm] opening representing the doorway, and falls off the platform.
Baby Walker-Related Injuries
By 2002, baby walker-related injuries dropped 63 percent, from 20,100 emergency room-treated injuries to 7,400. United States Consumer Product Safety Commission studies indicated that most of the recent walker stair fall injuries involved older walkers that did not meet the revised ASTM F 977.(1)
Safety standard development offers unique opportunities to touch lives through preventing injuries and deaths.
Is Standards Writing Right for You?
Participating in the development of safety standards provides an excellent opportunity for studying safety data and interacting with safety experts from a variety of backgrounds. Typically, representatives include consumer advocates, government agency representatives, consultants, manufacturers, lawyers, educators and testing laboratories. If not for the standard-setting process, these diverse interest groups rarely meet outside of a courtroom or legal proceeding.
Standards meetings are informative and candid. Attendees share their experiences and knowledge to create better standards and, ultimately, better products.
Safety standards are developed in response to incident data promulgated by the Consumer Product Safety Commission. CPSC data sources include the National Electronic Injury Surveillance System, (NEISS), a national probability sample of hospitals in the U.S. and its territories.(2) Other CPSC data sources are death certificates, medical examiners reports, and reports from consumers, lawyers and news clippings.(3)
Once presented with incident data, ASTM International committees analyze the information and determine appropriate standards or revisions.
Challenges for Standards Writers
1. If standard developers oversimplify issues or are not careful in their research, they may create new problems.
Three words: Remember the airbag!
Airbags have saved many lives, but they inflate at speeds up to 140 mph [225km/h]. This blast of energy can severely injure or kill a child sitting sitting too close to an airbag during inflation.(4) Many infant fatalities in low-speed crashes have been caused by airbags.
In the early 1980s, airbag testing procedures were developed. At that time, approximately 15 percent of front-seat occupants wore seat belts. Thus, the speed and force at which air bags inflated were developed to protect unrestrained occupants rather than restrained occupants. Federal Motor Vehicle Safety Standard 208 required vehicles to be tested at 30 miles per hour [48 km/h] using a 50th percentile male crash test dummy that is 5 feet 8 inches [173 cm] tall weighing 167 pounds [76 kg].(5)
The airbag issue is an example of the tradeoffs inherent in safety regulations, standard development and in attempts to reduce risk. By addressing risk and injuries from one cause, another risk may be created. When the focus was unrestrained average adult males, what happened to the newborn 50th percentile female weighing only 7 pounds [3 kg]?
Airbags systems are more advanced today and incorporate smart technology. The airbag controversy serves as a reminder that standard writers and regulators must consider all potential users and not just one target group.
2. Standards should not be design-restrictive.
Standard developers cannot easily foresee the unique and innovative designs of tomorrows consumer products. Yet the standards developed today should not hinder the development of these products either. Standards should be based on performance measurement rather than restricting design parameters. Performance-based standards may cost more in time and money to develop because equipment and testing is necessary. If the first attempt fails, retesting and new equipment will be required. Yet the long-term benefits should not be underestimated. Standards that dictate design may be challenged and require modification in the future. And they may limit creativity and innovative product design.
3. Keep consumer safety first.
The purpose of standards is to make safer products for the consumer. Do not end up confusing that consumer by mistake. Making products overly complicated, or creating warnings that are not well researched, may confuse the consumer. Standards developers must remember that the user of the product may have very limited mechanical skills or understanding of safety issues.
When developing safety standards, think about consumers, their use patterns, and their unique abilities to get things wrong. Warnings should educate and improve the consumers understanding of the product, and his or her ability to use it safely. Warnings must be reasonable and based on communication of risks. Warnings that are cluttered with too many statements to cover us in the event of an injury ultimately do the consumer a disservice.
4. Products must be functional and affordable.
More safety requirements do not necessarily mean safer products. More is not always better. Without data supporting the need for safety features, there can be a downside.
If consumers are forced to seek alternatives because they perceive the product is too expensive or complex, an increase in injuries could result. When babies are placed on sofas or adult beds they are at greater risk of injury than when placed in a full-size crib to sleep. If consumers make their own bed rails because the bed rails that meet the new ASTM International standard are too expensive, it is highly likely that more children will be hurt.
Making a Difference
Safety experts in government and the private sector have an obligation to participate in the process of developing standards. Both government and industry experts have access to data. There are many excuses as to why neither party participates to its fullest extent. Excuses usually involve time and money. We dont have time to develop tests, attend meetings, and share data. Yet somehow, there is time to conduct recalls and to litigate.
Few of us are recognized even in our own organizations for accomplishments in this area. Individuals and organizations that do participate in standards development should be applauded for their contributions of time, talent and resources. At the end of the day, when we look back on our careers and important accomplishments, one of the top items on this list should be the contribution made to develop better safety standards. They really do make a difference.
1 Federal Register/Vol. 67, No. 90/Thursday, May 9, 2002/Proposed Rules
2 Patient information is collected from each NEISS hospital for every emergency visit involving an injury associated with consumer products. From this sample, the total number of product-related injuries treated in hospital emergency rooms nationwide can be estimated.
3 Available at www.cpsc.gov/Neiss.
4 Available at www.nhtsa.dot.gov/
5 Available at www.ntsb.gov/speeches/former/hall.