June 20, 2012
Chairman Inez Tenenbaum
Commissioners Robert Adler, Nancy Nord and Anne Northup
U.S. Consumer Product Safety Commission
4330 East-West Highway
Bethesda, Maryland 20814
SUBJECT: Agenda and Priorities FY 2014
Dear Chairman Tenenbaum and Commissioners Adler, Nord and Northup:
On behalf of the National Consumers League, I urge the U.S. Consumer Product Safety Commission to place the following issues among its top priorities in fiscal year 2014:
I. Table Saw Safety
On October 11, 2011, CPSC published an Advanced Notice of Proposed Rulemaking to consider whether to promulgate a mandatory performance standard to address the unreasonable risk of injury associated with table saws. The National Consumers League, joined by Consumer Federation of America, Consumers Union, Public Citizen, and U.S. PIRG, submitted comments urging the Çommission to move forward with the rulemaking.
Our comments noted that tens of thousands of serious injuries occur every year as a result of contact with a table saw blade while in operation. These injuries cost society well over $2 billion every year. The benefits of reducing these injuries outweigh the costs to manufacturers of re-designing their saws. The voluntary standard that has existed, with modifications, since 1971, now requires table saws to be equipped with a modular blade guard and riving knife. While the latest version of the standard is a modest improvement over previous versions, blade guards, riving knives and other anti-kickback devices alone are not effectively addressing the tens of thousands of serious blade contact injuries that continue to occur.
We urged CPSC to enact a technology-neutral performance standard that would require manufacturers to equip table saws with safety devices that would mitigate injury when the operator comes in contact with, or in close proximity to, the spinning blade.
The comment period for the ANPR has passed, and we understand the CPSC staff is currently reviewing the comments to determine whether to recommend that the agency published a Notice of Proposed Rulemaking. We hope that the Commission will publish an NPR soon, so that a standard can be enacted as quickly as possible. With every day that goes by, approximately ten more people lose fingers in preventable table saw accidents.
We urge the Commission to budget staff time and resources in fiscal year 2014 for what we hope will be the final stages of the rulemaking process for a table saw safety standard. It is long overdue.
II. All Terrain Vehicle Safety
We also urge the Commission to budget staff time and resources in fiscal year 2014 for All Terrain Vehicles. We recognize in 2012 that the Commission is expected to complete its 2006 rulemaking. However, we urge the Commission specifically to commit resources to continuing research related to ATV safety in fiscal year 2014 and beyond.
III. Fire and Carbon Monoxide Hazards
We urge the Commission’s continued commitment to technical research in the areas of fire and carbon monoxide hazards. CPSC’s own data indicate that there are annually 386,000 fires, 2,390 deaths, 12,530 injuries and $6.92 billion property losses related to fires. Cooking equipment and heating equipment account for the largest shares of these fires. We need federal safety agencies with CPSC’s jurisdiction to continue research into ways to make cooktops and space heaters safer and less likely to start fires.
Regarding carbon monoxide, CPSC’s own data indicate that there are close to 200 unintentional, non-fire CO deaths a year from consumer products such as generators and gas fueled furnaces. This does not count the more than 200 deaths a year CDC attributes to CO exposure from automobiles. We urge CPSC to remain focused on technological solutions that will prevent these useful products from silently killing consumers. Finally, both hazards can be mitigated by effective, and relatively inexpensive, alarms. We urge the Commission to make upgrades and updates to the smoke alarm and carbon monoxide alarm standards a priority in 2014 and beyond.
 Caroleene Paul, Briefing Package, Recommended Advance Notice of Proposed Rulemaking for Performance Requirements to Address Table Saw Blade Contact Injuries, U.S. Consumer Product Safety Commission (September 2011) [hereinafter – “CPSC ANPR Staff Briefing Package”] pages 2-3.