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CPSC Releases Product Profiles

Release Date: October 17, 1976

The U.S. Consumer Product Safety Commission (CPSC) today released 35 Product Profiles on consumer products selected by the Commissioners for priority attention during this Fiscal Year 1977. These Profiles summarize the basic data from which regulatory decisions on remedial actions can develop.

Product Profiles represent a new approach to CPSC regulation, and constitute a focal point for the development of the agency's operating plan and budget. They summarize in one document the currently available data, information and analysis developed by CPSC staff. Included are basic data on injuries and deaths, hazard patterns, exposure and causality, vulnerability of special population groups; analysis of the projected effectiveness of alternative remedies, and preliminary assessment of economic impact.

Speaking for the Commission, Chairman S. John Byington said, "The purpose of developing and making these staff documents available at this time is to stimulate greater public participation in our decision-making process by inviting as much comment, additional data, and analysis as possible from interested organizations and individuals. This is in conformity with our openness policy and the letter and spirit of the Freedom of Information Act. The Commission does not endorse the specific data, analysis, or conclusions contained in these Product Profiles, and their contents do not indicate any determination or foreshadowing by the Commission of a specific course of regulatory or other remedial action."

The Profiles were prepared by teams representing a cross-section of expertise within the CPSC staff. Profiles will be updated regularly, incorporating new or refined data.

The 35 Profiles released today are grouped into six categories: Fire and Burn; Poison and Chemical; Electrical Shock; Mechanical; Home Structures and Systems; and Special Population Vulnerability Hazards, such as children or aged.

The following is a list of completed individual Product Profiles:

GROUP I -- Fire and Burn Hazards
Matches
Wearing Apparel
Tents
Smoke Detectors
Ranges, Ovens, Stoves
Gasoline, Kerosene, Gas Cans
Contact Adhesives
Hot Surface - Contact Burn
Hazards - Generic
Upholstered Furniture
Gas Space Heaters
GROUP II -- Poison/Chemical Hazards
Aerosols
Over-the-Counter
Antihistamines
Household Chemicals:
Rust Removers and
Other Products Containing Hydrofluoric Acid
Ammonia
Household Chemicals: Sulphuric
Acid Drain Cleaners
Aspirin Substitutes
Cleaning and Maintenance
Household Chemicals:
Cleaning and Maintenance
Products Containing
Petroleum Distillates
GROUP III -- Electric Shock Hazards
Appliance and
Extension Cords
Christmas Tree Lights
Trouble Lights
Aluminum Wire
GROUP IV -- Mechanical Hazards
Power Mowers
Power Saws,
Non-Portable
Carbonated Soft Drink Bottles
Power Saws, Portable
Chain Saws
GROUP V -- Home Structures and Systems Hazards
Bathtubs and Shower
Enclosures
Architectural GlazingLadders
GROUP VI -- Population Vulnerability
Playground
Equipment
Pacifiers
Small Parts - Generic
Bicycles
Projectile Toys
Sharp Points and Edges -
Generic


Comments on the Profiles should be addressed in writing to the Office of the Secretary, U.S. Consumer Product Safety Commission, Washington, D.C. 20207.

An introduction explaining in some detail the purpose, scope, terms and qualifications to the Profiles is also attached.

Product Profiles
Consumer Product Safety Commission
October 1976


These profiles are being distributed to the public in order to stimulate comment, attract additional data and analysis from any interested organization or individuals, in conformity with our openness policy and the letter and spirit of the Freedom of Information Act. It is hoped that this effort will further stimulate public participation within the CPSC decision-making process. These specific profiles were prepared by the Commission staff and used by the Commission to make tentative selections of product/project areas for priority attention. The Commission does not endorse the specific data, analysis, or conclusions contained in these product profiles, and their contents do not indicate any determination or foreshadowing by the Commission of a specific course of regulatory or other remedial action.

I. Introduction, Purpose And Scope

The profiles included in this report are for products that were tentatively selected by the Commission for further investigation and priority attention in FY 1977. The profiles are intended to do four things: (1) indicate the kind of analysis being initiated to help support CPSC priority setting, (2) serve as a focal point for organizing and summarizing staff development of remedial program strategies, and thus aid as an input to the Commission decision-making process, (3) identify areas where further information, collection, research or consultation is necessary, and (4) serve as a vehicle for encouraging consumers industry, and other government agencies to provide comment and analysis that can assist the Commission in determining appropriate remedial action.

The profiles represent data, information, and analysis for products and activities at various stages of investigation and development. Some are at very early stages; for others, development work has been underway for some time. While data and analysis for all the profiles require further substantiation through technical, scientific, legal and behavioral research and development, this is particularly the case for profiles representing products/projects at earlier stages of development. Broadening and deepening of the data and analysis summarized in these profiles, and strengthening of the assumptions on which they are based, will constitute a focal point of staff remedial development efforts for FY 77.

In publishing these profiles, CPSC particularly wishes to solicit from consumers, industry, and other interested parties, information, data, and opinion-that can assist the Commission in determining appropriate remedial action.

Product profiles in the CPSC system for determining remedial action are prepared when a product hazard is suspected. They serve as a framework for a decision to undertake remedial action, do further research, or to hold in abeyance, and thus constitute an essential element in Commission priority setting and selection of product specific activities for emphasis. They identify product specific injury, hazard and socio-economic data collection needs, and must be updated continuously as new information become available. ' They will be given a comprehensive review every six months as priorities are re-examined. They provide a foundation for evaluating the impact of CPSC product-specific activities, and provide baseline information for a CPSC project management system.

The role of product profiles in determining remedial action is given in Section II. An explanation of the content of the individual profiles and the basis for estimates is given in Section III. Section IV contains the profiles themselves.

The individual profiles have been numbered and grouped by major hazard category. They are listed here as a reference index. The location of individual profiles within a major hazard category is somewhat arbitrary and, in some cases, hazards associated with the product are appropriate to other major hazard categories.

Group I - Fire and Burn Hazards
Matches
Upholstered Furniture
Wearing Apparel
Gas Space Heaters
Ranges, Ovens, Stoves
Tents
Gasoline, Kerosene, Gas Cans
Contact Adhesives
Smoke Detectors
Hot Surface - Contact Burn Hazards - Generic
Group II - Poison/Chemical Hazards
Aerosols
Aspirin Substitutes
OTC Antihistamines
Household Chemicals: Cleaning
and Maintenance Products containing
Petroleum Distillates
Ammonia
Household Chemicals: Sulfuric Acid Drain Cleaners
Household Chemicals: Rust Removers and other
products containing Hydrofluoric Acid
Group III - Electric Shock Hazards
Appliance and Extension Cords
Aluminum Wire
Christmas Tree Lights Trouble Lights
Group IV - Mechanical Hazards
Power Mowers
Power Saws - Portable
Power Saws - Non-Portable
Chain Saws
Carbonated Soft Drink Bottles
Group V - Home Structures and Systems Hazards
Bathtubs and Shower Enclosures
Ladders
Architectural Glazing
 
Group VI - Special Population Vulnerability Hazards (Children)
Playground Equipment
Bicycles
Pacifiers
Projectile Toys
Small Parts - Generic
Sharp Points and Edges - Generic



II. The Role Of Product Profiles In Determining Remedial Action

Product profiles provide a single source for summary information on product characteristics, hazards, injuries, consumer interest, and alter- native remedial strategies. The development, status and socio-economic impact of the remedial strategies are also provided. Product profiles provide the baseline data from which the management decision-making process on remedial actions can proceed. Thus, the profiles are the focal point for the development of the Agency's operating plan and budget.

Product profiles have been completed for over 35productjproject areas representing the product specific part of the FY 77 Operating Plan. These profiles were created by multidisciplinary teams under six major product groupings listed below:

1.Fire and Burn

2.Poison/Chemical

3.Electric Shock

4.Mechanical

5.Home Structures and Systems

6.Special Population Vulnerability Hazards (Children)

These groupings were-'established to cover the extremely wide range of products under the Agency's jurisdiction. Five of the groups are organized according to technical discipline and one primarily according to vulnerability of a particular population groups (children and aged,. Multidisciplinary teams marshal1 all data and expertise relevant to the products/project area, both agency-wide and outside, and coordinate all staff efforts needed to obtain such data. Product profiles will be continuously reviewed and refined, and additional profiles will be created for products posing new safety hazards as they are identified.

Within each of these major product groupings, broad remedial strategies relevant to that type of generic hazard are considered, as well as specific solutions to specific product hazards within that category. It may be possible to cut across product lines and address generically a particular hazard such as thermal contact, i.e., the capability to cause a burn, or sharp edges and points, i.e., the capability to cause punctures and lacerations, etc. It may also be possible to address certain hazards inherent within a broad product category, such as household structures, or within an extensive area of activity.

( 1/ * Preliminary profile data sets have been developed and will be completed over the next several months for a number of other products. These will be candidates for future potential resource attention.)

Based on creation of a profile by staff, the Commission selects those for which further effort should be expended to refine the options, analysis and develop more completely the alternative remedial strategies. This decision is based on a review and analysis of the information on the original product profiles, and will either allay or substantiate concern about a potential risk of injury.

If Agency concern is allayed, the product profile is set aside for future use, updated and reviewed every six months. Such a product profile will be held in review until a periodic update or other action i.e. Section 10 petition, substantial new injury data, etc. reactivates the profile.

If Agency concern is substantiated, then the product profile identifies the data gaps and a concentrated effort is initiated to collect specific data and to refine the entire profile so that the Commission will have sufficient information on which to select appropriate remedial strategies. These strategies take into consideration the net effectiveness of potential Commission action, by precisely relating injury causality to nature of product use, cost, and availability. These analyses involve a multidisciplinary approach utilizing the engineering, biomedical, economic, legal, medical and behavioral resources available to the Commission. Through this approach, the Commission is able to develop and consider alternative remedial strategies from which the most effective can then be selected.

During FY 77, the Agency will commence a multidisciplinary project management system to implement its product and project-specific operating plan. This management system will involve systematic planning and evaluation, based on product profiles and priority-setting criteria.

The Project Management System will also allow for accelerating the priority of products/projects which cannot now be anticipated to warrant greater resource emphasis, but which may later be so designated. This might include, for example, a product revealed through petition to pose a substantial potential hazard problem; a new program initiative such as a research project on an acute hazard problem; or increased compliance effort required for an industry posing substantial hazard problems. Pro- gram plans, based on product/project profiles, will be developed for all accelerated priority items. The Commission will then decide whether projects would be transferred from accelerated priority status to the category of explicit priority development.

III. Explanation Of Forms And Definitions

This section describes the contents of a complete set of product profiles, consisting of the following forms:

-Product Profile Summary Form

-Injury and Hazard Information - Form A

-Assessment of Alternative Remedial Strategies - Form B

-Assessment of Socio-Economic Effects - Form C

A.Product Profile Summary Form

Purpose: The purpose of the Product Profile Summary is to provide an overview of the characteristics of the product and associated hazards and to summarize the status of development, alternative remedial strategies and socio-economic impacts.

Header: Product name , group and NEISS codes and names are given for all products included under the product name.

1.Assessment of Injury and Hazard Information

This includes a summary of the overall injury and severity of the product and a description of the hazard pattern and vulnerable population groups. More detail is given in Form A (see below).

2.Characteristics of Industry

This is a description of the size, type, and degree of concentration of the manufacturers, distributors and retailers handling the product. The number and name of trade associations, amount of industry covered and their involvement in safety regulation is also given where applicable. Data on industry characteristics have been obtained from the best available sources, including government publications, trade journals, contract studies and professional judgment.

3. Current State of Development

This part of the Summary contains a description of the existing regulations, if any, concerning the product and a description of current status of development of any mandatory, voluntary, information or educational effort. Past and current research efforts are summarized, if applicable.

4. Assessment of Alternative Remedial Strategies

This section includes a brief description of the mandatory, voluntary and informational and education remedial approaches that might be considered in developing a program to reduce unreasonable risk of injury. Depending upon the product, the remedies, in some instances, will be well developed because of some previous regulatory development activity, and in other cages they will be a preliminary estimate of remedial approaches for further consideration. Additional information is given in Form B (see below).

5. Scope of FY 1977 Activity

This section shows the scope of activity in the product area as reflected in the CPSC 1977 Operating Plan.

This is a summary of the expected impact of remedial action on consumers and industry groups. It includes estimates of injury reduction and costs, and estimates of cost and price increases, if any, experienced by industry and the consumer. Effects on competition, etc., and included where applicable and where a basis for an estimate exists. Additional information is given in Form C (see below).

B. Injury And Hazard Information - Form A

Purpose: The purpose of this form is to provide a summary of product related injury data. It includes NEISS data on frequency and severity, demography and diagnosis; non-NEISS data from a variety of sources; other information including exposure to injury, consumer interest factors, imminent and substantial hazards, and in-depth investigations; hazard analysis data, if available from CPSC files; and a section on remarks, qualifications and limitations of the data.

Header: Same as Summary Form.

1. NEISS Data

a. Frequency and severity

(1) Total Injuries - This statistic is calculated from the estimated number of hospital emergency room treated injuries (NEISS) based on the assumption that 38 percent of injuries (those requiring medical attention or one or more days of restricted activity) are treated in emergency rooms. The estimate of 38 percent is an overall average derived from a special household interview survey conducted by Market Facts, Inc. The calculation for total injuries is:

NEISS estimate for product group / .38

It should be noted that the probability of a given injury being treated within a hospital emergency room is a function of the nature of the injury. Currently, there are no national data available on the proportion of consumer product-related injuries treated in hospital emergency rooms by specific injury diagnosis. Therefore, this estimate (which does not distinguish between diagnoses) should be interpreted as a crude measure reflecting the approximate magnitude of the total injuries within the nation.

(2) Injuries Treated in Hospital Emergency Rooms - These estimates are for contiguous United States derived from NEISS.

(3) Mean Severity - This measure is based on NEISS estimates and reflects the average severity of injuries associated with each product using the following values for the seven severity categories:

Category 1 = 10 least severe
Category 2 = 12
Category 3 = 17
Category 4 = 31
Category 5 = 81
Category 6 = 340
Category 7 = 2516 most severe

(4) Emergency Room Visits Requiring Hospitalization - This estimate is derived from NEISS and includes those emergency room patients admitted as inpatients or transferred to another facility for hospitalization.

(5) Number of Hospitalizations Per 100 Injuries - The estimate is derived by dividing the estimate in (4) by the estimate in (2) and multiplying by 100.

(Number Hospitalization / Number of Injuries ) x 100

(6) Cost of Death and Injuries - Injury cost estimates attempt to reflect total dollar costs (excluding pain and suffering) for each product associated with all non-fatal injuries. These costs include medical costs, foregone earning, and other costs, and are based primarily on data derived from CHAMPUS (Civilian Health and Medical Program for the Uniformed Services) and NHIS (National Health Interview Survey). Costs have been estimated for each NEISS case and are summed for all cases in each product category.

NEISS estimates the frequency of injuries reported through hospital emergency rooms only. These are thought to represent 38 percent of all treated injuries. Cost estimates are, therefore, divided by .38 to obtain total cost estimates. Also, data from NEISS have been supplemented by injury data from poison control and burn treatment centers since poison and burn injuries are thought to be under-reported through NEISS.

(7) Number of Deaths - These numbers are based on all deaths occurring in 1975 which were reported to CPSC through the Death Certificate project. The Death Certificate project receives from State and local Vital Record Jurisdictions all death certificates for selected external causes of death (those which are expected to have a significant number of product-related fatalities). Of the 54 jurisdictions which comprise the vital registry system of the United States and its territories, 36 reported overall for 1975, one reported for nine months, seven reported for six months of that year and the remaining 10 did not report during that year.

It should be noted that more than one product can be involved in a death. The number represented in this section is the total reported deaths involving the product under review. Therefore, deaths involving multiple products will represent a duplicated count of deaths.

b. Demography

In this section, injuries, hospitalizations and deaths are given by age and sex. A ratio of the representation of the group in the above categories compared to the representation in the U.S. population is also given. The ratio estimate presented in this table is calculated as follows:

- proportion of incidents occurring to the selected population group / proportion of the select population group to the total population

A figure of 1.0 would reflect that the proportion of in- juries for this group was the same as their proportion within the population. A figure of greater than 1.0 would reflect a higher injury rate relative to their proportion within the population.

c. Diagnosis

The distribution of emergency room visits by NEISS injury categories is given in this section.

2. Non-NEISS Data

Injuly, severity and death information (and any other pertinent epidemiological information) is given in this section. Data sources include Poison Control Centers, National Center for Health Statistics, National Fire Protection Association and others. This section cannot be considered a representative sampling of injuries. The use of this data was as follows:

Group I: Fire and Burn - Due to the unique characteristics of burn and fire-related injuries, there is general agreement that the product-related injury problem within this category, relative to other types of injuries, is not adequately reflected in CPSC's data collection systems. This hypothesis is based primarily on the following assumptions:

a. The destructive nature of fire makes the identification of the involved products difficult or impossible.

b. Since a higher proportion of burns and fire-related injuries involve multiple products as compared to most other product-related accidents, certain types of products involving burns are under- represented in NEISS due to the limitation of including only one product within the NEISS record.

Therefore, Group I used the estimates from the National House- hold Fire Survey. This survey was conducted during the week of April 15, 1974, by the Bureau of the Census as a supplement to the monthly Current Population Survey (CPS) and included a sample of 33,000 households, representing all of the United States.

Group II: Poison and Chemical - For product profile analysis, it was assumed that poisonings, relative to other product-related injuries, are under-reported in NEISS. This was based on the assumption that the Poison Control Centers may not be adequately reflected in the NEISS sample and that poisoning victims treated in those NEISS hospitals that have a Poison Control Center may by-pass the emergency room and not be included in NEISS. These assumptions may not be as universally accepted as were the reporting problems associated with fire; however, it was decided to supplement the NEISS data with the information obtained from the National Clearinghouse for Poison Control Centers, The data used from NCPCC covered various time spans depending upon availability of the data. However, since the average annual estimate was computed, comparisons among product groups are possible. The raw reports received from the NCPCC are inflated by a factor of seven. This weighting procedure was based on a medical estimate that approximately six out of every seven ingestions by young children are not reported. It should be borne in mind, however, that NCPCC data is voluntarily reported from a varying number of centers, and should be used only as a general indication of the magnitude of poison hazards.

The injury information based on NCPCC data was calculated as follows:

-$ 227 was used as the average cost estimate for ingestion.

-$1720 was used as the average cost estimate for hospitalization.

Injury costs include all hospital costs, professional services, foregone earnings, transportation charges , product liability insurance, hospital insurance and litigation costs. Pain and suffering are not included.

3. Other Information

a. Exposure to Injury

This section includes data which are based on various years, depending upon the most current information available.

1.Number in use- Derived from published data, staff estimate or professional judgment.

2.How many per household - Staff estimate of number in use divided by number of households (est. 70 million).

3.Estimated useful lifespan of product - Average life span-staff estimate.

4.Nature and frequency of use - Two measures (estimated).
(a) Consumer involvement (range from negligible to intensive contact in use).
(b) Frequency of exposure (range from rarely to extensively exposed).

b. Consumer Interest

(1) Correspondence - The correspondence figure is the number of consumer inquiries, complaints about products and services and reports of injuries associated with products which were received in CPSC's correspondence unit during Calendar Year (CY) 1975. They covered an extremely wide range of subjects, many of which were within the Commission area of jurisdiction and required research within CPSC for response. However, many covered subjects not within CPSC's jurisdiction and were referred to the appropriate Federal, State, local and, in some instances, private agencies for proper handling.

(2) Hotline - The figures for hotline calls represent the calls processed by the hotline staff during CY 1975. They include requests for written materials, inquiries requiring additional information, complaints about potential hazards and complaints of injuries associated with consumer products. These figures do not represent those calls which were answered directly by the hotline staff over the telephone requiring no further processing.

(3) Requests for Information - These figures were arrived at by adding the total 1975 printing orders for information in each of the categories and subtracting the inventory on hand. This figure includes all written requests, hotline requests, Area Office requests, as well as the materials distributed from the two Washington information centers.

(4) Newspaper Clippings - This item includes those news stories received by the Surveillance Desk from various sources including TIPS Clips, Underwriters' Laboratory, and Area Offices.

c. Imminent and Substantive Hazards, Bans, Recalls This section contains a listing of such actions and reports of defects since May 1973, which were received under the provisions of Section 15 of the Consumer Product Safety Act.

d. In-Depth Investigations

An account of all available in-depth investigations is given in this section. An in-depth investigation is usually a personal interview with the victim and/or family or witnesses in which information is obtained about the brand and model of products involved, the role of the product in the accident, the accident sequence and characteristics of the victim and environment.

4. Hazard Analysis

A description of the hazard pattern is given here. This is based on CPSC staff Hazard Analyses, case summaries of in-depth investigations, or other studies and data sources as available.

5. Remarks and Qualifications

Selected observations concerning the data given and certain qualifications as to its use and representations is given here. Other qualifications and caveats may appear elsewhere as well.

c. Assessment Of Alternative Remedial Strategies - Form B

Purpose: The purpose of this form is to state succinctly for each remedial strategy--mandatory safety rule (MSR) or amended rule (AMD); voluntary standard (VS); or independent information and educational efforts (I&E)--the highlights of the strategy, including the hazards addressed by strategy, developmental efforts needed, possible remedial actions, follow-up (compliance) effort indicated and the advantages and disadvantages of the strategy.

Header: Same as Summary.

1. Hazard Addressed

For each major strategy, the type of hazard addressed is described and an estimate of the total hazard addressed is given. For example, if a candidate remedy would address about half of all lacerations and punctures, and this type of injury amounts to 60 percent of the total injuries, then the estimate of hazards addressed would be 30 percent. Since this is a judgmental estimate, it is expressed as a range of values. If the proposed remedy would also reduce the severity of injury, then the estimate might be raised based on a judgment as to how much the severity and cost of injury might be reduced by the candidate remedial actions.

2. Development Effort

The current status of development is shown with the requirements for additional research and strategy analysis and any anticipated development problems. For I&E strategies, the current I&E status is described with proposed new approaches. The time to develop the strategy, from its current state to effective implementation, is given. The time to reach peak effectiveness is also given. For mandatory and voluntary strategies, this is usually assumed to be the average product life. For the I&E strategy, it is the time needed to reach peak influence on the public. These estimates assume an "average", non-accelerated work schedule for development. However, the real time development would be directly subject to Commission priority decision and could be substantially greater or less, depending upon the priority assigned by the Commissioners. Development time is especially dependent upon such priority assignment by the Commissioners.

3. Possible Remedial Actions

In this section, candidate remedial actions are described, and an estimate is made of the probable range of effectiveness of the action in reducing the hazards addressed. The proposed remedy may be well defined if a product remedial strategy is already under development. In other cases, the remedial action may be conjectural, pending further investigation. For I&E campaigns the type of approach, media and target population are given.

4. Follow-up (Compliance) Efforts

This section gives an estimate of the types of follow-up action or compliance program that might be conducted in support of a mandatory or voluntary standard or independent I&E campaign. The relationship of the follow-up effort to the manufacturer - distributor - retailer - consumer chain is described where feasible. The role of industry groups and trade associations in monitoring voluntary standards is described. For independent I&E campaigns is, the need to follow-up initial efforts, through various media and approaches is also given.

5. Advantages and Disadvantages

In this section, an objective statement is given of some of the advantages and disadvantages of the candidate strategy. The desirability of a given type of strategy for addressing injuries is treated together with a comparison of the advantages and disadvantages of the other strategies considered. All strategies will have advantages in reducing injuries and injury costs. For some products, the range and severity of injuries addressed will be extensive and for others less so. The complexity of the remedial effort will also vary from product to product. Some efforts, like labeling, may be easy to implement, but may be less effective than performance or design criteria. Mandatory efforts may require more CPSC effort than voluntary ones, yet voluntary efforts may take longer and in the long run may be less effective. This will depend, in part, on the nature of the industry and the ability of industry groups to support a concentrated voluntary standards program., Some remedial actions may be easy to undertake and enforce because of a focal point in the manufacture - distribution - retail chain. In other product areas, a greater compliance effort may be needed because of the dispersed nature of the industry. For some products, information and education efforts can take advantage of industry and consumer groups to help extend the effectiveness of the effort. For other products, the advantages of a media campaign might be offset by the danger of encouraging risk taking.

D. Assessment Of Socio-Economic Effects - Form C

Purpose: The socio-economic effects were presented in a condensed format to provide information describing the overall impact of various Commission remedial strategies by assembling enough cogent quantitative and qualitative data to enable a reviewer to consider certain key costs and benefits of the potential Commission strategies. Not all costs and benefits were considered, e.g., pain and suffering and various second and third order effects for which data were not available.

The data found in most product profiles represent for the most part a preliminary estimate. Unless the Commission had been previously engaged in substantial development work on a product hazard, it is unlikely that extensive and reliable data were available. On the other hand, in several instances the information is up-to-date and known to be reasonably accurate.

Header: Same as Summary

1. Overall Effects

The section that deals with the overall effects contains a statement, where appropriate, that compares relative costs and benefits of the strategies under consideration. The benefits were taken to be the expected reduction in the costs of accidents associated with the products involved. The costs of accidents were estimated by the sum of injury costs and death costs as discussed previously in Section Bl(6) of the introduction.

The Commission has not endorsed any quantitative expression for cost of death. However, for purposes of the preparation of these profiles, where data permitted two estimates of death costs have been used by staff. One, at $250,000, approximates an average figure frequently employed in accident cost calculations as an indicator of the value of foregone life-time earnings. The other, $2 million, provides an indicator of the sensitivity of certain total injury costs to death cost estimates that take into account other factors in addition to foregone earnings. Since the death costs encompass a range, total costs do also. In the fire/burn and poison/chemical profiles, often the exact number of deaths is difficult to estimate and is also given as a range. In these instances, total injury/ death costs represent a combination of the range of the number of deaths and the range of death costs.

In addition, where appropriate, costs associated with property damage prevented were estimated as a supplementary benefit factor.

The annual total costs of accidents/deaths prevented and property damage foregone may be thought of as the universe of potential benefits of a Commission remedial strategy. To the extent that Commission actions address hazards and effectively reduce injuries, these benefits are actuated. The combination of addressability and effectiveness of technical solutions, as discussed in Section C of the introduction, provides a measure of net effectiveness. Net effectiveness was then applied to total injury/death costs to arrive at benefits. Since net effectiveness was also reported in a range, this combined with the range of death estimates and death cost values widened this range of benefits further.

The costs of a Commission strategy were difficult to assess accurately in many cases because limited information was available on what the technical features of the remedial strategy would be. Therefore, in many instances, cost estimates based on the strategy recommendation should be considered only as approximations and are thus frequently presented as a range of percentages.

Given the cost information available, an attempt was made to estimate the price effect to the consumer. In some cases, change in price to consumer was estimated by applying a percentage mark-up to total retail sales and in other cases by applying a unit price increase to an estimate of units sold annually. In some instances, retail sales were estimated by applying a mark-up to the value of shipments. Full compliance by industry was assumed for the most part in estimating cost and price impacts.

Costs and benefits of remedial strategies were then contrasted. Because of the preliminary nature of the data, no attempt was made to perform a series of formal cost-benefit analyses, i.e., streams of costs and benefits based on years to full conformity discounted to compare present values.

In comparing benefits and costs, adjectives such as low or small were used to describe situations where costs were felt substantially to outweigh benefits, medium or moderate where benefits correspond closely with costs, and high where benefits were felt substantially to outweigh costs.

2. Effects on Producers and Sellers

This section considers outlays necessary for capital investment, testing costs, materials, changes in distribution, administration costs, etc., needed to comply with recommended strategies. Where possible and relevant, other parameters of supply such as the state of technology, market expectations, and other factors were discussed. Conditions influencing exit and industry concentration were considered where possible.

3. Effects on Consumers

This section deals with the effects on consumers in addition to price impacts. Where appropriate, impacts on utility, convenience, availability of substitutes, and other factors relevant to the parameters of the demand for the product were considered.

Neither the scope of information contained in these profiles, the complexity of analysis, or conclusions stated are to be considered complete or as accurate as would be possible were an in-depth impact analysis conducted in each of the product areas. Further intensive work is planned in each area as an integral part of the development process for each product/project area represented by these profiles.

 

Release Number
76-067

About the U.S. CPSC
The U.S. Consumer Product Safety Commission (CPSC) is charged with protecting the public from unreasonable risk of injury associated with the use of thousands of types of consumer products. Deaths, injuries, and property damage from consumer product-related incidents cost the nation more than $1 trillion annually. Since the CPSC was established more than 50 years ago, it has worked to ensure the safety of consumer products, which has contributed to a decline in injuries associated with these products. 

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