You Can Help: Voluntary Safety Standards Development for Consumers
Do you want to prevent injuries and deaths?
Of course! One of the best ways to prevent injuries and deaths is to make sure that voluntary safety standards for consumer products are effective.
Many voluntary safety standards are developed by working groups of interested people representing a variety of interest groups; thus, they are commonly referred to as “voluntary” standards, in the sense of having been volunteered by a non-governmental group as an alternative to governmental regulation.
Consumers like you can help develop standards.
What is a voluntary safety standard?
Consumers rarely see a standard, but standards are working behind the scenes to keep us safe. A safety standard is a set of product requirements intended for manufacturers and importers to help reduce or prevent injuries. These requirements are usually met by passing specific performance tests.
What is a performance test?
Performance tests are often conducted in a laboratory and are used to determine that a product can be used safely without dictating how safety is achieved by the designers of the product. Performance requirements do not typically rely on any specific design concepts to ensure the product passes the test.
For instance, an office chair should be strong enough not to break when you sit down on it, but a manufacturer can choose how they make the chair strong. The safety performance standard does not dictate any specific materials or certain size components, but the chair simply needs to be capable of holding the weight specified in the performance requirement.
Standards make products safer, without stifling innovation.
What does a voluntary safety standard look like?
Voluntary standards are technical documents, hardcopy or electronic, with illustrations and definitions.
Performance requirements and their associated test methods typically make up the bulk of a standard. Formatting and language follow certain style conventions across standards to maximize the standard’s utility.
Standards are technical, but they are often easy to understand.
Why make voluntary safety standards?
Voluntary safety standards are developed to reduce or eliminate injuries or deaths associated with products, ensure product parts fit together, and many more benefits.
Voluntary safety standards can have additional benefits from a business perspective, too. Manufacturers who are new to a product category rely on standards to learn from existing expertise about avoiding injuries. A good safety record, promoted by a voluntary standard, benefits an entire industry by enhancing consumer confidence about the safety of the market, so competitors cooperate to develop and continually improve standards.
Voluntary standards are an important contribution to society.
Voluntary standards are also useful and valuable for saving government resources to create effective requirements. If the government had to create every safety requirement on its own, the government would need to hire many more experts and spend a lot more money to achieve the same level of effectiveness that we currently enjoy with voluntary standards.
Other synonymous terms you may hear for “voluntary standard” are “industry standard,” or “consensus standard.” These refer to the same thing: a standard that is not mandatory. The concept of consensus is important for standards development. Consensus does not mean unanimity, but it means that every contributor has the right to be heard, and their opinions are to be considered.
What is a “consensus standard”?
A standard should be developed with input from all of the different stakeholder groups with an interest in a particular product. The federal government’s Office of Management and Budget (OMB) has provided guidance about consensus, and the American National Standards Institute (ANSI - (the U.S. organization leading standards development) and specific standards development organizations have similar requirements.
The concept of “consensus” is important for standards development in the United States. In 1982, the Office of Management and Budget (OMB) published Circular A-119, “Federal Participation in the Development and Use of Voluntary Consensus Standards and in Conformity Assessment Activities”. This guidance on agency use of standards directs agencies to use standards developed by voluntary consensus standards bodies rather than government-unique standards, except where inconsistent with applicable law or otherwise impractical. Circular A-119 specifically defines a “consensus standard” as a type of standard developed or adopted by consensus standards bodies, through the use of a consensus process that includes certain elements that ensure fairness among stakeholders:
Openness - The procedures or processes used are open to interested parties. Such parties are provided meaningful opportunities to participate in standards development on a non-discriminatory basis. The procedures or processes for participating in standards development and for developing the standard are transparent.
Balance - The standards development process should allow meaningful involvement from a broad range of parties, with no single interest dominating the decision-making.
Due process - Due process shall include documented and publicly available policies and procedures, adequate notice of meetings and standards development, sufficient time to review drafts and prepare views and objections, access to views and objections of other participants, and a fair and impartial process for resolving conflicting views.
Appeals process - An appeals process shall be available for the impartial handling of procedural appeals.
Consensus - Consensus indicates general agreement, but not necessarily unanimity. During the development of consensus, comments and objections are considered, using fair, impartial, open, and transparent processes.
Who makes voluntary standards?
Industry representatives such as engineers, designers, inventors, and supply chain managers tend to do much of the work to develop standards within standards development organizations that provide physical and electronic collaboration spaces and publication assistance. Professional consumer advocates, victims of injuries or their survivors, government employees (federal, state, and local), testing laboratories, academic researchers, physicians, lawyers, and other expert consultants also contribute.
Consumers just like you help because they care about their community and want to prevent pain and suffering. Often, a consumer or someone they know has experienced an injury, and they want to make sure that it does not happen again.
Everyone has a place in standards development for consumer products.
Why are consumers needed?
With all of the experts at the table discussing the incidents associated with a product, the consumer perspective is essential. Without the consumer represented, the discussion can be unbalanced. Having a balanced group of stakeholders is one of the founding principles of developing safety standards for consumer products.
You are an expert on how you use consumer products.
Where are voluntary standards made?
Standards are created in a series of meetings and conference calls organized by a “standards developing organization,” a non-profit business that hosts the meetings, activities, and procedures needed to propose, discuss, and make decisions about the draft standard before a vote is taken on the final version. The organization does not write the standards, but it organizes the groups of volunteers who do. Most standards developing organizations charge fees for membership and sales of the published standards, to offset their expenses. Often, standards developing organizations will waive membership fees for consumers, when asked.
Standards organizations provide a welcoming forum for making standards.
Are there rules for making voluntary standards?
Standards developing organizations set up rules for governing discussions and drafting new requirements. Schedules and decision-making rules are carefully defined to ensure a high-quality draft in a reasonable amount of time.
Rules ensure that all stakeholders can contribute their individual expertise in an equitable manner.
How much work is it?
Consumers have options for the amount of time and effort that they give to these tasks. Most standards groups meet two to four times per year, plus any additional task group conference calls or virtual meetings that may be needed. Meetings are typically from 1 hour to 4 hours long, and conference calls tend to be an hour or so. Ballots are sent to members about once or twice a year. Attendance is not required to maintain voting rights. If a consumer chooses to participate at a more active level, such as leading a task group on a special project, or acting as a chairman, then, obviously, the time requirements increase with the level of responsibility.
Standards participation is flexible, and your level of participation is up to you.
How do I participate?
The following standards development organizations may be contacted for more information about contributing.
General Consumer Items:
For example: toys, playground equipment, highchairs, strollers, jewelry, pool covers, bunk beds, furniture, soccer goals, scooters, brooms, costumes, laundry packets, and many more
Furniture - AHFA - American Home Furnishing Alliance
Heaters and Air Conditioners - AHRI - Air Conditioning, Heating and Refrigeration Institute
Business and School Furniture - BIFMA - Business and Institutional Furniture Manufacturing Associations
Fire Prevention - NFPA - National Fire Protection Association
Flooring - NFSI - National Floor Safety Institute
Athletic Equipment - NOCSAE - National Operating Committee on Standards for Athletic Equipment
Pools and Spas - PHTA - Pool & Hot Tub Alliance
Window Coverings - WCMA - Window Covering Manufacturers Association
Machines - OPEI - Outdoor Power Equipment Institute
Generators - PGMA - Portable Generator Manufacturers Association
Off-Highway Vehicles - ROHVA - Recreational Off-Highway Vehicle Association
Vehicles - SAE - Society of Automotive Engineers
All-terrain Vehicles (ATVs) - SVIA - Specialty Vehicle Institute of America
American Oversight Organizations:
International Oversight Organizations:
Why make a voluntary standard instead of making a regulation?
Voluntary standards can typically be made faster than federal rules. Besides that, the Commission is legally required to give preference to an existing voluntary standard, if the voluntary standard is determined to be adequate to address the risk of injury associated with a product and the industry substantially complies with the standard, meaning that it is widely adopted.
The CPSC is empowered by the Consumer Product Safety Act (CPSA) to promulgate mandatory rules that improve the safety of consumer products. Federal rulemaking is not always the most efficient or cost-effective pathway to safety because it requires government resources expended with strict oversight rules that can be time-consuming. Congress amended the CPSA in 1981, as well as two other acts, to mandate that the Commission give preference to voluntary standards, as opposed to promulgating mandatory standards, if: (1) the Commission determines that a voluntary standard would eliminate or adequately reduce an unreasonable risk of injury, and (2) there will likely be substantial compliance with the voluntary standard.