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Growing Together

ASTM Committee F08 and the U.S. Consumer Product Safety Commission

by George Sushinsky

ASTM Committee F08 on Sports Equipment and Facilities turns 35 years old in November, serves a diverse consumer group, and directly affects the products that those consumers use. Not quite as old at 31, the U.S. Consumer Product Safety Commission has a long history of working with Committee F08 to make products safer for consumers.

The CPSC is an independent federal regulatory agency charged with addressing unreasonable risks of death and injury associated with over 15,000 types of consumer products. One way that the CPSC staff does this is to work with industry and other interested parties to develop voluntary product safety standards. Since CPSC’s establishment, its staff has been involved in the work of Committee F08. CPSC staff attends subcommittee meetings and works with task groups in areas of interest to the commission. Currently these areas include bicycles, protective headgear, fitness equipment, playground surfacing, trampolines, and hunting tree stands.

What CPSC Brings to the Table

CPSC staff contributes technical expertise and data resources to the F08 standards development process. The CPSC representatives to F08 usually have engineering backgrounds, but they have access to other CPSC professionals in the Directorates of Human Factors, Health Sciences and Toxicology, Economics, and Epidemiology. As one of their most important functions, the CPSC representatives provide to F08 subcommittees epidemiological information on injuries, deaths and hazard patterns related to the use of particular product types. With an understanding of hazard patterns, tests can be developed or revised to address the hazard.

CPSC receives death and injury data from different sources. These include:

• Consumers;
• Manufacturers – required in certain cases under the Consumer Product Safety Act;
• Medical examiners and coroners;
• News reports and newspaper clippings;
• Death certificates;
• Hospital emergency rooms through the National Electronic Injury Surveillance System; and
• In-depth investigations.

National Electronic Injury Surveillance System

NEISS (sounds like “nice”) data forms the backbone of the injury estimates developed and reported by CPSC staff. A description of the system “NEISS: The National Electronic Injury Surveillance System – A Tool for Researchers”1 is available on the CPSC Web site.

In the fall of each year, CPSC staff publishes injury estimates for many products in its quarterly publication, “Consumer Product Safety Review.” This publication is also available on the CPSC Web site.

NEISS data is also now available through the CPSC Web site. This access allows the public to retrieve estimates of injuries treated in U.S. hospital emergency rooms for many consumer products. These data may be accessed by several variables such as the date of incident, product category, age and/or sex of the injured party, body part, diagnosis, disposition, and location of incident.

Other Information Sources

Not all injuries are treated at hospital emergency rooms. Some injuries may not be treated professionally and others may be treated at physician’s offices. Therefore, the NEISS estimates are lower than actual injuries associated with a given product or activity.

The CPSC also receives information about incidents and injuries associated with consumer products through the CPSC Hotline (800/638-2772 and 800/638-8270 TTY for speech or hearing impaired). About 4,000 complaints about “unsafe” products are received through the hotline. Newspaper reports also serve as a source of approximately 7,000 consumer product-related incidents. Death information is obtained through the Medical Examiners and Coroners Alert Project, which accounts for about 3,500 death reports annually. CPSC also purchases death certificates from each state – a total of about 8,700 certificates each year. There are an additional 10,000 miscellaneous consumer product-related reports from lawyers, physicians, fire departments, and other sources. All of the reports are included in the CPSC databases and used to assess hazards associated with consumer products.

Some reported cases are selected for follow-up investigations. These investigations can include a visit to the incident site, an interview with the consumer about the incident either in person or by telephone, and collection of incident and exemplar samples for evaluation and testing at the CPSC laboratory.

One of the primary tools used by the laboratory analyst is a product standard. Usually the CPSC analyst will review the incident details and applicable standards to determine the tests needed to evaluate the product. When there is no applicable standard or the existing standard does not test the product in a manner consistent with the reported hazard, the CPSC analyst may employ alternative tests. These tests might adapt procedures from related product standards, simulate the user’s actions during the incident, or specifically target the suspected problem area with forces intended to demonstrate the failure mode.

Mandatory or Voluntary Standards

The CPSC was formed out of the need to administer an existing set of safety acts that date from the early 1950s and to achieve safety in the use of consumer products. The Consumer Product Safety Act of 1972 established the CPSC with the authority to issue and enforce mandatory product safety rules. CPSC’s early years were marked by the adoption of industry standards as mandatory rules and promulgation of new product regulations.

Part 1031 of Title 16 of the Code of Federal Regulations sets forth the CPSC’s guidelines and requirements on participating in the activities of voluntary standards organizations. The Consumer Product Safety Act was amended in 1981 to strongly encourage the commission to take full account of voluntary standards in its consumer product safety efforts. Since 1990, CPSC staff has worked cooperatively with industry and other interested parties to complete seven times more voluntary standards than mandatory rules.

The Practical Reality — A Few Examples

Subcommittee F08.10 on Bicycles
In 1978, CPSC established mandatory requirements for bicycles. At that time, ASTM F08 had not established a subcommittee to address this subject. By the mid 1990s, CPSC staff recognized the need for additional requirements for bicycles and bicycle components. Modern bikes have equipment and uses (e.g., suspensions and trail riding) that did not exist in the mid 1970s, and CPSC incident data was showing problems with fork and frame failures on bicycles that met the CPSC requirements. CPSC staff approached ASTM to establish a subcommittee to develop new voluntary standards for bicycles that could supplement the existing mandatory requirements, and Subcommittee F08.10 on Bicycles was born. Since then, F08.10 has produced four standards including requirements for Condition 3 bicycle forks (ASTM F 2274, Specification for Condition 3 Bicycle Forks). Condition 3 forks are for bicycles used on “rough trails, rough unpaved roads, and rough technical areas and unimproved trails.”2

In November 2001, CPSC staff sent a letter to the chairman of F08.10 requesting that the subcommittee address handlebar-related injuries through voluntary performance standards. The subcommittee agreed to that task but has struggled with issues related to scope and definition of the problem. CPSC staff continues to monitor and update the subcommittee on injuries associated with handlebars. CPSC staff expects a draft standard to be balloted in 2004. The draft will address requirements for handlebar end cap size, hardness, and the force to remove the end cap.

Subcommittee F08.17 on Trampolines
In 1997, CPSC staff approached Subcommittee F08.17 to address the trampoline-related hazard patterns seen in the CPSC injury databases. At that time the NEISS annual estimate of injuries was almost 83,000 and had been rising steadily over the years. Hazard patterns included falling from the trampoline, contact with the frame and springs, unsupervised use, and multiple jumpers. Since 1997, the trampoline standard, F 381, Safety Specification for Components, Assembly, Use, and Labeling of Consumer Trampolines, has been strengthened to include more specific warnings about supervision and multiple jumpers, and padding requirements have been developed to address pad retention under different scenarios.

The major hazard, falls from trampolines, was first addressed in the marketplace as manufacturers began production of enclosures to attach around the trampoline frame or mat to prevent users from falling from the trampoline. The first commercially available enclosures came out in 1997. As this item became a popular accessory to the trampoline, the subcommittee recognized the need for a standard. In 2003, ASTM F 2225, Safety Specification for Consumer Trampoline Enclosures, became a reality. During the period from 1997 to 2000, trampoline injuries continued to increase to a peak of 100,300. Some of the increase may have been due to the inclusion of trampolines in the 2000 Olympics and an expected “bounce” in trampoline sales. Since 2000, the injuries have fluctuated from a low of 89,390 in 2002 to 98,400 in 2003.

Subcommittee F08.53 on Headgear and Helmets
Bicycle riding, equestrian events, martial arts, ice hockey, football, skiing and skateboarding are just some of the diverse concerns of Subcommittee F08.53. In 1993, the subcommittee published F 1447, Specification for Helmets Used in Recreational Bicycling or Roller Skating, for bicycle helmets. In 1994, the U.S. Congress enacted the Children’s Bicycle Helmet Safety Act. This act directed the commission to establish a mandatory safety standard for bicycle helmets based on provisions of U.S. voluntary bicycle helmet standards. At the time of the act, there were three U.S. voluntary standards and other international standards. The CPSC safety standard for bicycle helmets, 16 C.F.R. Part 1203,3 became effective on March 10, 1999, and applies to all bicycle helmets manufactured after that date. The mandatory rule was based to a large extent on existing voluntary standards, especially F 1447, but with some significant changes. These changes included special provisions for helmets for children including more protective coverage, and the use of the curbstone anvil for impact testing. Mandatory labeling stating conformance with the CPSC requirements was also part of the standard.

Despite the existence of the mandatory rule, ASTM F 1447 continues to exist and to be upgraded to meet the requirements of the user community.

Subcommittee F08.63 on Playground Surfacing Systems
CPSC staff has been involved with playground issues since 1974 when the commission granted a petition from a school teacher who requested a mandatory standard for playground equipment. In 1976, the National Recreation and Park Association submitted a draft of a standard to the CPSC that contained a section on “Surfaces Under Equipment.”4 CPSC staff believed that the NRPA report did not adequately address playground surfacing issues and recommended additional research. A contract with the National Bureau of Standards (now the National Institute of Standards and Technology) resulted in a methodology to assess impact attenuation of surfacing in relation to head injury. Based on the NBS work,5 the recommended failure criterion was 200 g’s [1960 m/s2] peak deceleration. By 1980, the commission terminated the work on a mandatory standard and decided to publish a handbook of playground safety guidelines. The initial handbook had two volumes. Volume II contained technical recommendations and recommended the test method and requirement from the NBS report for the shock-absorbency of playground surfacing.

In September 1986, ASTM F08.52 held an organizational meeting for a task group on Playground Surfacing. The task group eventually became ASTM F08.63 on Playground Surfacing Systems. CPSC staff provided input to the new subcommittee in terms of participation in round robin testing (1988) and support for the evolution of F 355, Test Method for Shock-Absorbing Properties of Playing Surface Systems and Materials, into ASTM F 1292, Specification for Impact Attenuation of Surfacing Materials within the Use Zone of Playground Equipment.

In 1990, CPSC staff published a report on impact attenuation of playground surfacing materials for seven loose-fill materials using the then-draft requirements of ASTM F 1292.6 This work was used in the development of a table of critical heights7 of these materials. In addition to using a peak G less than or equal to 200, the value for critical height was also dependent on a head injury criterion (HIC) less than or equal to 1000. A CPSC staff report recommended the use of HIC because it accounted for the time duration of the impact.8 The table eventually became Table 1 in CPSC Publication Number 325, The Handbook for Public Playground Safety. Subcommittee F08.63 adopted the head injury criterion as part of F 1292 in a 1993 revision to the standard.

In 1998, the National Program for Playground Safety provided data to the CPSC staff on materials similar to those in Table 1 that yielded consistently higher critical heights for materials. One of the primary differences in the NPPS-sponsored testing was the use of a larger box to contain the loose-fill materials. CPSC staff revived its surfacing project and retested some of the same types of materials that were in the 1990 report. This testing produced values that were generally between the 1990 CPSC data and the 1998 NPPS data. CPSC staff concluded that box size, material handling and instrument set-up were variables that affected the test results.9 In 1998, CPSC staff summarized its work to ASTM F08.63. The resulting efforts of a subcommittee task group produced a significantly revised standard in 2004. The new standard addresses all of the issues raised by CPSC staff in addition to many other issues raised by the task group in examining the standard. The revised standard is expected to reduce interlaboratory variability by an order of magnitude.

Continuing Growth and Cooperation

In terms of age and experience, Committee F08 on Sports and Recreation and the CPSC may be considered fledgling organizations compared to the ASTM committees tenured at 100 years and the mature industries they represent. Yet, though just in their 30s, ASTM F08 and the CPSC serve a valuable purpose. For F08 the mission is the reduction of the inherent risk of injuries and the promotion of knowledge as it relates to sports and recreation safety standards. This is also one of the CPSC’s missions as it promotes safety in over 15,000 types of consumer products. Both organizations have much to offer each other as their staffs work together on product safety standards. //

Acknowledgment

The author gratefully acknowledges the comments and injury estimates provided by the staff in the Directorate for Epidemiology at CPSC.

References

1 NEISS, The National Electronic Injury Surveillance System, A Tool for Researchers, Division of Hazard and Injury Data Systems, U.S. Consumer Product Safety Commission, March 2000
2 ASTM F 2043, Standard Classification for Bicycle Usage
3 16 CFR Part 1203, Safety Standard for Bicycle Helmets (2004)
4 Buecher R.D., Proposed Safety Standard for Public Playground Safety, National Park and Recreation Association, May 1976
5 Majahan B.M. and Beine W.B., Impact
Attenuation Performance of Surfaces
Installed Under and Around Playground Equipment, NBSIR 79-1707, National Bureau of Standards, February 1979
6 Ramsey L.F. and Preston J.D., Impact Attenuation Performance of Playground Surfacing Materials, U.S. Consumer product Safety Commission, March 1990
7 Critical height is an approximation of the maximum (fall) height below which a life-threatening head injury would not be
expected to occur.
8 Collantes M., Evaluation of the Importance of Using the Head Injury Criterion (HIC) to Estimate the Likelihood of Head Impact Injury as a Result of a Fall into Playground Surface Materials, U.S. Consumer Product Safety Commission, September 1980
9 Sushinsky G. and Preston J., ASTM F 1292 — Impact Attenuation of Surface Systems Under and Around Playground Equipment – Should the Standard be Revised?, Proceedings Playground Safety 1999 — an International Conference, Christiansen M. (editor), 2000

Copyright 2004, ASTM International

George Sushinsky is a mechanical engineer at the CPSC Laboratory. He is a member of ASTM Committees F08 and F15 on Consumer Products. Sushinsky is currently involved with research on playground surfacing and the application of test methods to indoor surfacing.

These comments are those of the CPSC staff, have not been reviewed or approved by, and may not necessarily reflect the views of the Commission. Because Mr. Sushinsky prepared this material in his official capacity, it is in the public domain and may be freely copied or reproduced.