 Good afternoon and welcome to this public meeting of the United States Consumer Product Safety Commission. We have one item on the agenda this morning, a public briefing on the subject of 3D printing. Before we begin, let me acknowledge that we're missing Commissioner Feldman on the dais today. Unfortunately, he can't be here in person, but he's participating by phone, I hope, and we'll try to check on that and make sure we have a clear connection. Peter, are you there? He's watching. Okay. Oh, that's fine. So he'll email you questions. Oh, okay, that's great. I think that works. This meeting is the first in what I hope will be a series of public meetings to provide greater transparency into the work of the Consumer Product Safety Commission and of our staff. And in particular, our staff in the Office of Hazard Reduction and Analysis, which we affectionately refer to as EXHR. 3D printing is not currently on our regulatory agenda as an active rulemaking, but it is an emerging technology our staff is paying close attention to. And I'll note is a newly active voluntary standard for Commission staff participation in the FY20 operating plan. Today's briefing provides a snapshot of staff's knowledge at this time, and I know there will be more to come in the future. We're going to start with staff's presentation followed by rounds of questions by the commissioners. I will call on each commissioner in order of seniority. We'll start with five minute rounds, but we'll aim to be flexible and we'll go as many rounds as needed. Today we're going to hear from Rick McCallion, Program Area Risk Manager for Mechanical, Recreational Sports and my favorite topic, Seniors. He's joined by Dwayne Boniface and who is the Assistant Executive Director for Hazard Reduction and Analysis. Thank you for being here this afternoon and you may begin. Okay, well, I'd like to thank the Commission for giving me the opportunity to come speak with you about 3D printing. It's a pretty interesting topic. With that, I'm Rick McCallion, Program Area Risk Manager for the Risk Management Group of EXHR. I'm one of five Program Area Risk Managers along with Susan Bathelon, Rick Kana, Doug Lee, and Dr. Trey Thomas. Unfortunately, Dr. Thomas is not able to be here today. He is in Boulder at NIST at a 3D conference looking at emissions. He's not snowed in. He may very well be. I haven't heard from him, so it's very possible. Okay. And our division is run by Patty Adair, who is just an awesome boss. Also in our group is Patty Edwards and Scott Ayers working on voluntary standard stuff. And we have our FOIA and Product Safety Assessment Coordinator, Dean LaRue, is also in our group. With that, I just want to later kind of the groundwork, no pun intended, on what 3D printing is and why we're, you know, why it's on our radar. So when we think about what 3D printing is, it's just basically another manufacturing process along with a whole bunch of others that have been around for a while. But the difference, what makes 3D printing different, and I'll use my cup as an example, is it's building products from the ground up, basically, or parts from the ground up. So what you do is you have a program, a computer program, that takes an image of a product and will slice it into a whole bunch of thin slices. And then it'll send those slices to a printer, layer by layer, one by one, and the printer will lay down a small bead that outlines that profile or that image in that layer. So it's basically a 2D image that eventually builds in through a 3D product. So there's a lot of interesting things that come, make 3D printing really desirable, really desirable manufacturing process. I think as of 2017, it was a $7.4 billion business. So it's pretty substantial. And that was up from about $6.1 billion in 2016. And they're expecting, and I think over the next couple of years, probably a 20 to 25% year over year increase. I'm guessing that'll drop off eventually as it becomes more saturated. But the products themselves are relatively cheap. You can get a pen and we'll have some images of them later. But a really simple, very basic 3D printer, which is in the shape of a pen. That's about $50. And the more traditional printer looking like printers that look like your home printer sort of the whole boxy shape, they start around $200. And then they go up from there, they can go way up to probably hundreds of thousands, if not millions of dollars at the higher end of those. As far as the design and one of the desirabilities of 3D printing, they allow for designs that aren't possible in any other way. So I have a prop here that I would be more than happy to pass around because it's a little small. I got it at a trade show. But basically what it is, it's four balls. This is about the size of a cat ball. Apologize to the size. But with any other process, you couldn't make this this way. So it was made all at once and all the balls inside each other as one piece. And because of the physical limitations of the traditional processing method, you wouldn't be able to make that just in that way. One of the limitations of it early on were the print speed. Now with new technology and new process. Actually, would you mind sharing that with us? I would like to see it. So print speeds are are increasing that one of the limitations of the technology was that print speeds are really slow. So you could make a really small product, but it would take a product, you know, have a really small product, say this cat, but it may take three or four hours. Anything bigger like this water bottle could take up to 24 hours to print. Now you can print out about 100 of these in probably an hour. The time has really come come come up come down fast. One of the other things that that that we're seeing is that it's being used in places like schools and libraries and we'll touch and we'll get into a little bit more because that has some other implications. And we're seeing that small businesses are adapting these due to the easy use and the cost of very portable, the reason to install the reason to use. And we're seeing that through things like bank loans that are being made available to small manufacturers for buying printing products. So overall, we're basically expecting, you know, to see a lot more consumer products show it up that use 3D printing technology and methods. So like I said, I think I mentioned earlier, it started kind of as a promotional and prototyping process, but it's grown to where just about anything can be 3D printed now. We still see a lot of promotional products and customizable gifts because you can write names and stuff on them relatively easy. But we're seeing other things show up in the market like bike helmets. And as we can see here, some other shoes and containers and stuff like that and toys, there are some special issues with toys that are definitely a concern. And things aren't just limited in size anymore, they can be basically printed in any size or any material. Basically, we're starting to see things like bridges and houses, which thankfully aren't consumer products. But the scale is not a limiting factor anymore. There's just about, like I said, anything that can be printed any size. So to get into the terminology a little bit, one of the things we're seeing is that there's different groups and different industries use different terminology. I think we took this from NIOSH or OSHA. I think we were using it for that. But our view is a little different. So I'll give you our kind of interpretation or my personal interpretation of some of these things. Starting with 3D printing and that of manufacturing, they're kind of interchangeable terms. For our purposes, for staff, for example, when Trey and I talk about stuff, we use 3D printing for the smaller home type environment and additive manufacturing for the more industrial. But that's not a hard and fast, it's just kind of our way of determining. For the most part, it's their interchangeable terms. I think for the purposes of here, we'll probably stay with 3D printing, although additive manufacturing, if I drop that in, it's a synonymous term, basically. Large-scale and small-scale manufacturing, there's no clear differentiation between which the two. But I would suggest that small-scale would be something that would be able to fit on a desktop or a tabletop that's relatively portable. Large-scale being the ones that are the room size or something that's going to be taking up a lot more room. Small-scale are probably more likely to be used in the home environment, but that's not to say that large industries aren't using them. So what we're starting to see is there being marketed as a way of increasing production, number of production units. So you could have a large manufacturer dedicate a whole bunch of floor space and manufacturing floor space to small printers that are effectively the size of your home printer and just line them up down the floor so that they can print out more products at a given time. Large-scale printers, they're pretty much limited to larger applications and larger industries just because of the cost, the size, and the large-scale printers also have more capabilities and more likely to have the higher technology so they may have better surface finishes. They're probably more likely to have the more advanced techniques to use to print metal parts and that type of stuff. So they're more likely to be in that environment, but it is possible that we see them in smaller locations like a strip mall down the street from you. If a home user wanted to print them, there's a possibility that they could have what I call the Kinko's effect, where you print something, you have a design at home that you want to print, but it's beyond the capacity of what you have in your home. You could send it down to that business down the street and they have a larger printer and does that. So it's kind of like a shared application for that. So jump back to small-scale printing for just a second. What we're seeing is these printers popping up in schools and libraries and other public places where a lot of kids are being exposed to them. They're being incorporated into STEM education curriculums and anecdotally I've talked to, I think since I've been prepping for this and a little bit before that, every person I talk to that has knowledge of this that has younger kids or the kids in school say, oh yeah, my kid has worked on one or my child has been exposed to one or we know they're in the school. So they seem like they're really becoming a part of the school environment and we see them in libraries for general consumer use, but I would expect it to also be a child exposure in that area too. But I think it's fair to say that we would expect every child going forward, technology continues to go forward, continues to advance, every child we would expect to be exposed to 3D printing and then the potential hazards that are attributed with that. Distributed manufacturing is another area that's kind of big in 3D printing and it's basically moving the part of product, place of production, out closer to the end use. So what we see from the manufacturing, from the large manufacturing standpoint is they, I guess it's an economical, for economical reasons of nothing else, they can do their part production where they either need to assemble it or where the point of sale is going to be or close. It also gives them the opportunity to reduce standing inventory. So they're making it as needed. They don't have to have, they don't have to produce a bunch of parts that they hope they can sell, they can produce them as they need it when somebody orders them or when they need them to put them in to build a finished product. The other part of distributed manufacturing is the fact that these smaller local manufacturers don't necessarily need to be associated or to be part of the big industry. They could be home manufacturers that are contracting or small businesses. So somebody theoretically could be producing parts for a large manufacturer out of their basement or again down in the strip mall at a small business type facility. It's not just limited to a large manufacturer that has their own production, their own small scale production somewhere else, although that is very possible. And I would say that's probably where we're, how we're seeing it right now, at least again anecdotally. So I just wanted to touch on the actual types of 3D printers and printer technology there are. There's approximately 10 of them out there now. I may have missed a couple and admit that because it's changing so much, I'm not going to get into the specifics. I'd be more than happy to talk to them, talk to each one. But I just want to cover the fact that most of the decisions about which printer to use is based on the material you're printing. So you'd want a certain type of printer if you're, if you're printing metals or if you're printing stainless, there's certain type of printing that would use for that. If you're printing concrete, you wouldn't want to use a, you know, a small, small stereolithography type system. So that's kind of the first decision, the first point of decision making is what material you're going to, are you going to produce? And then basically what kind of product are you going to make it for? You have to have a good finish. It's going to be a rough finish because typically most of the printers give you a fairly rough finish, at least the mid-scale to lower-scale ones. They're not going to give you a nice clean surface finish or something, or durability product. You know, there's durability issues and all those other problems with it. So you may want a higher end or a different process that can give you a better, a better, a better part at the end. The speed of the, the speed of the production if you're actually, if you want to produce more than one at a time and you have a time and then then speed is, I touched on quality. Obviously the size is a problem, is an issue because most of the, most of the consumer grade printers are going to be the desktop size and the, the beds are about, you know, I would say less than 48 inches roughly. So 48 inches square, 40 inches cube. So that's probably on the big side. The more like probably 24. And all of that feeds into the cost. So all those, all those benefits come with the cost, the higher the, the higher the technology, the more advanced the technology, most likely the higher the cost. So with that, we can sort of get into the hazards a little bit. And we broke them down into two ways because 3D printing is somewhat unique in that we have hazards associated with actual or the printing process in 3D printers, especially when they're in the home environment or that type of non-industrial or small industrial environment. And then we have the 3D printed parts and what they're producing and the hazards associated with them. So we're going to break them down in each of the program areas by that. So the first is the fire and combustion hazards. And when we look at the printers, one of the problems we, we see with them is for just about every process in there, we're required to melt the material to a semi-liquid or liquid form to actually make it flow through the nozzle, to make it, to actually print out the parts. So we need relatively high temperatures. So there's, with that, with those high temperatures associated with those high temperatures is always at the risk of fire. We could have a fire. Also given the fact that these are kind of long-term processes and they're somewhat self-contained. So you put in your, you know, you design your, your product and you send it to the printer and you leave it. And there's no, I would say reasonably that there's no short turnaround. It's going to take a while for that to print, even the smallest product. So there's a good possibility that you're just going to start printing it and do something else. You're not going to stand there and watch it. So you have the possibility of it being on, or the likelihood that it's unsupervised, an unsupervised process. When we look at that from the consumer side and in a home environment, you could theoretically or in actuality put it in your basement or someplace where you would normally put a printer that's out of the way that's maybe a little cluttered or some stuff around it and then just go off and do whatever. So there's certainly concerns about, about fire hazard and then if, if, if there's you know, fire protection available, if there's something to protect that, if there's a spoke alarm covering that to do any of that, because as far as I know, there's none of that safety stuff built in, fire protection safety built in. I would say that there's, there's safety protocols built in. If something goes south on the, on the print, that would probably stop. But it may not, it's certainly not designed to detect, you know, hazard events like that. The other thing to consider is some of the processes is use granules or powder. They are not just like the, the thread fed type printers. So you could be dealing with a, a process that has a powder bed basically in the process which could create dust that again with the elevated temperatures could, could become a combustion hazard or an explosion hazard. So we have all those, all those with fire and combustion and then when we start looking at the product we have the questions of how do we make sure that it's compliant to existing standards especially fire standards. There's material and compatibility and durability issues with how, how it's designed, who designed it and whether we withstand the, the rigors of actual operation in the fire, in, in the fire and combustion zones. So if you're making a product will it, will it provide that fire barrier or whatever that was designed to do based on the material you picked, based on the design and based on how it was, how the printer actually made it which we'll get into a little more about the, about that in the mechanical side. How the, how that, those have an effect. So the electric hazards are somewhat, somewhat similar. We definitely have the possibility of electrocution hazards because we think of the energy that it's needed to melt some of those materials especially when we start getting into away from the plastics into the more metals where we're looking at higher temperatures. I think that plastics probably were looking at, you know, 200 C maybe, 200 degrees Celsius. It's pretty substantially hot and then you go up from there and if you think about it, what it takes to melt a metal, a ferrous material, it's, it's pretty, pretty hot. So you need a lot of energy going in there. So the, the electrical circuitry and everything else that provides that in a, in a printer that is may or may not be enclosed, may have open size, may have exposure or accessibility to those electrical components is certainly a hazard. And those, those, those also those electrical components also could result in a fire, a file potential hazard. As far as the, the product goes in flame retardants, UV inhibitors and mechanical boundaries that, that keep you protected or deny an accessibility to the electrocution hazards or protect from fires. And it's like if we do think of like a covers for your outlets and stuff like that. If they're, if they're 3D printed, that's great. But they may not provide the, the protection in a fire to reduce the, or stop the propagation or whatever the thermal, thermal propagation would be. Chemical hazards. This is where I kind of mis-tray because this is his area. So Tray hopefully he's, he's, he's listening and I don't make him cringe. So the printers, from the printers, there's certainly a concern about the toxicity of raw materials and whether they're safe to use and handling. Because now we're looking at introducing an environment where it was traditionally isolated in the manufacturing environment when we're making parts for 3D printers, especially on the home side and the small scale side again. We have people that are being exposed to these powders, these raw powders and, and all kinds of other, other materials, raw materials that are being put into this and they're also being exposed to it while they're being printed. So again, where we may be off gaffeting stuff that may not be the greatest. How we store this stuff, it not only from a mechanical standpoint, but from the chemical standpoint is very important how we store this. You know, are they, are they going to be, are we going to have inhalation hazards because we're storing powder somewhere or something like that to chemical release and accessibility for children. And where, where are we storing this stuff? Is it a hazard? If they were to ingest it? Or if they were even to, to get it on their hands, is it, is it a problem? Because some of the metals, especially some of the metals when we get into the metals and I think plastics too, there's, there's stuff that, that is in, that is in that raw material that makes it functional. That may be inaccessible when it's a finished product, but may certainly be, you know, much more readily accessible when it's, in its raw form. So when we look at the, the product in parts again, it's, this is a kind of recurring theme, the durability of parts and how will they break down? Will they, will they, will they, you know, start to, start to fail in an unsafe way? Will they, will they start to degrade in a way that that's unsafe, especially things like UV and, and other stuff. So, so how they fail is certainly important. And will, you know, things like nanotubes, I think is a, is a concern. As far as children hazards, there's the obvious with the high temperatures of a burn ham, the chemical exposure, I think we covered with the chemical. And the fact that they're not fully enclosed, that they're again referring back to the small scale on home and, and those type of environments, they're not typically ventilated and not being enclosed. What kind of, what kind of off-gassing is that, that process doing? So when we're melting those plastics, what kind of fumes of it is it, is it presenting when we're melting metals? Same thing. What kind of stuff is, bad stuff is coming off of that? As far as the printed materials themselves, there's a whole host of issues that come up with that, not the least of which is producing small parts. How do we control small parts in, in, in products that are, that are being, being printed or made by, by, by the home environment? Specifically when we think about that is, you know, we see people making pacifiers, rattles, small balls and toys, especially our personal, our personal favorites of people, you know, making the little novelty toys and stuff. I see Star Wars figures that are really popular now with all the, you know, that type of stuff, Marvel Care. All those things that, that would, you know, would potentially be a children's, a children's product that would fall under those regulations. How would they, how would that, how would that fall out? We have concerns about raw materials and exposure to, to, to phthalates and especially when we're printing plastics, which is probably the most common materials that we're printing are, are, are plastics in the home environment right now. Metals are starting to filter down. I think we'll see those soon, sooner rather than later in, in, in every day printers that are for home use, but right now it's basically, basically plastics that are, are, are the most common ones. And then we have the, the, along with the, the toys of, of things that were, were, were producing replicas of unsafe products, specifically like toy guns would be an issue. So jumping into mechanical hazards. Mechanical hazards are primarily related, related to the products that are printed. When the, when the printer fails from a mechanical standpoint, most likely would fall, would fail in a fail safe manner from a mechanical standpoint. It could present a, a fire hazard if, if it, if it failed in a certain way. I mean it could overheat. Some of them use lasers so that would certainly be a concern depending on how, how the, the laser is pointed. That would be an eye hazard or something like that. But I, I, I think primarily the, the, the, the areas of interest for mechanical are with the, the, the finished products themselves. And as I said before, that the, the great thing about 3D printing is it allows designs that you couldn't previously do. But on the other side of it is 3D processing because of the easy to process in the way it's done. It's also removes some of the expertise that's in the more traditional manufacturing process. So I think traditional manufacturing you get a lot of the, the, the materials engineers that, that certify materials and provide the right materials for the right job and, and make sure that they're the right grade of materials and those type of things may be removed from the process. You have your design engineers depending on where you get your design from. If you pull it off the internet, you know, you're going to take that out and then we get to the actual pro, the building of the product is how do you know the, the materials are any good and specifically the raw material, the properties of our materials are different from the final materials. So traditionally when we're using traditional manufacturing processes, we kind of know what the material properties are in the finished product because we've, we've kind of defined the, the initial block or whatever we're using to make that product so we're finding in, um, there's a lot of people doing research on this that 3D printed parts have different properties and specifically the build angle, the build direction also plays a factor in this and this goes back, this is what I had mentioned earlier about flannability, it figures into all aspects so if you were to build a product horizontally, so if you were to design, if you were to print this bottle standing up you would possibly have different, different functional properties and thermal properties and other things than if you would if you printed it on its side um, and that's a big concern especially when you have, when, when, with the ease of production if you take some of the expertise out of that, that may not be the most obvious thing it may be simpler to print it on its side because you don't have the vertical capacity in your printer so, um, all these, all these different mechanical things are, are, are, are kind of factor into this and the, part of the process of who's going to be, who's going to be responsible for that on the home end and who's going to be doing that and who's going to have the knowledge to do that um, not only to know about that the, the product was, was used the right materials, the right process, the right design but then that it was post-processed correctly because one of the, another one of the big areas that's coming up from on the industrial side is post-processing and how do you coat something to make it stronger to make it to, to heat treat it so that you don't have something that's really so there's all those type of things um, that, that come in from the mechanical side of it touch on some of the staff activities related to research engagement and voluntary standards um, most of the research activities that we're engaged in at the moment are related to emissions um, so we have some interact, interagency agreements with uh, NIST, EPA, OSHA and DOD and they relate to nanotubes, material toxicity and some of the other um, health effects. Um, there's a lot of research going on in other areas in mechanical areas um, but I think those are the, those are kind of the first issues we've got to we're just having we're, we're kind of it's kind of filtering down. As far as staff engagement um, so we're, we're working with um, SDOs and, and developing potential letters um, working with some international agencies and groups um, a lot of the, a lot of the stuff which will um, we'll get a little bit in on with, with um, couple of slides from now is um, a lot of the the technical, the technical side, the development of the technology is happening outside the U.S. so we're, we're working with some of the international partners specifically I think um, Treyas has been talking to our counterpart in Germany on how they're handling some of the, I've met with a couple of researchers from, from the U.K. who are doing some mechanical property, looking at mechanical properties uh, of, of printed products. Um, um, we hosted a, a federal interagency meeting in August and as recently I believe it was last week maybe in the week before that um, my, my schedule's a little bit squirrelly. Um, we had UL come in and speak with us about their polymer research and they did a great job that they've seen. Um, that's one of the big problems they have with thermal, thermal issues in, in 3D printed parts is how the, it's a big factor in how the, the part is made as far as how the beads are laid down and a lot of technical issues with the actual process and specifically how it's, how it's um, how it's oriented when it's built so they actually have um, they certify materials on with specifics of, of direction, specific product with a specific, um, um, material you have to tell them what direction you'd actually be building that in. So, voluntary standards activities there's a, actually it's, there's a lot of good work going on in the voluntary standard, standards worlds and we're working with the UL on various SCPs on emissions and electrical equipment so I believe that the emissions is specific to 3D and then we're starting to see things like filter in the 3D stuff, the 3D process like the electrical equipment because that's kind of where it's kind of popping up first in the industrial with like covers I would assume and stuff like that go out with covers and things like that. Um, in 2017 ASTM started the center of excellence for, that related to 3D printing and they're looking at 3D, standards that standardize the 3D printing processes um, and they're really heavily influenced by the aerospace industry, the COD where they're um, they're printing metal parts so a lot of their work is with specific with a lot of titanium standards and stuff like that but because the obvious concerns with putting um, a 3D part into an airplane, a commercial airplane they're really heavily involved with making sure that the standards for specific process are well defined and that's starting to filter down they're starting to work on they just recently started a group that's associated with the F42 which is a fatigue group the STM F42 ISO slash ISO it's a it's a joint group that I believe they're they're, they claim and I at Patty I was able to verify this that they have the first ASTM ISO standard joint standard which I thought was pretty interesting um, the ANSI America makes roadmap um, put out a report that we have the state of 3D printing where it was and identified the holes the research holes where we should be spending or where the um, the industry should be spending their time and the researchers are spending their time looking at what questions they should be trying to answer and what work could be done and I think that was it may have been as long as a year ago now I'm not exactly sure when that came out but um, as well developed as some of the other uh, manufacturing areas but I think there there's a lot of good work that's trying to get it to that point so, some of the challenges and opportunities that we are facing right now is, as I again mentioned a little bit earlier the international collaboration we see a lot of the tech being developed in um, in Europe in Asia and a lot of the manufacturing adoption and use of the products that's being done in the US so the 3D printing is being done here in the country or whatever the scale is um, but the technology seems to be developing outside the US at least as far as we can say um, basically at this point in time we don't have a real good understanding of the the material properties from of 3D printed parts so they're different enough from traditional manufacturing processes that we don't exactly know how they're going to be formed so that kind of gives us a little bit of concern about everybody everybody else that would listen you know, if somebody was to make a bolt for their lawn mower blade um, how long would that last and if you didn't uh, if you didn't understand the properties it could fail the first time you turn it on and shoot that blade out from underneath and hurt somebody um, so that's one of the really important things and of course outside of our industry there's a lot of other groups that are going to bring the emissions of these products so it's, there's a lot of work going on I expect they'll get to that point sooner, rather than later but it's still there's still a lot of questions that we have about that um, and that kind of leads into the product durability how long products have been last I think I'd cover that we don't have a good idea how long they could is especially a big challenge because of the ease of production with things like toys and stuff and not understanding that the hazards that are associated with printing toys is how do we make people understand that if you print out a small part for a child, it could be a choking hazard that there are regulations that, you know, from when you buy one in the store that they are required to meet. And good manufacturing processes, we kind of lose some of that when we get to the home and small manufacturers is are they using good manufacturing safety processes? Are they, you know, are they ventilating properly? Are they, you know, making sure that the environment is clear and safe and if there's fire protection issues and they're properly wired this printer to make sure that it's not going to overload the electrical circuit or overload the product and cause a fire? So there's a lot of a lot of questions about that. One of the other the other things I wanted to touch on was the open software. The open software problem is that you can get designs anywhere on the internet. I think we've had a couple pictures of things that have come from open source sourcing most likely. And it the way it's possibly circumvent traditional safety and expertise. So you can just print you can print out anything you want back to that bolt. You could have somebody that has a small scale printer that prints metals. They can print out a bolt that was designed for a really high strong grade bolt and they can print out something that you know is not as strong as plastic and they may not know it because just because they think it's metal is going to be strong and that may not be their case. So that's certainly a concern. Supply chain for materials is an interesting one and how do we maintain that because there's a lot that goes into that that a lot of people may not understand. Do you know how do you how do you keep it how do you keep it at the right temperature at the right humidity? You know is it getting foreign materials in there because you're storing it out in the open and now all of a sudden something's got into it. And then all that stuff feeds into the finished part and it could have an effect on the finished part again. It becomes more of a concern the more the more we move from into the the plastics which are generally you know more less load bearing into the more structural structural I guess demanding materials such as metal. Yeah and I just wanted to one more time reinforce that the ease of this creates a lot of the problems the ease of the use of it. I mean everybody is really familiar with programs and everything and how they work and it acts pretty much very similar to a home printer. So it doesn't take much of a jump to to learn the software or to drop a product in there and to start printing out something. So with that I think that's it. Thank you very much. Rick thank you very much for a very exhaustive travel through the world of 3D printing and as you were talking it struck me that I can't think of a division within CPSC that wouldn't at some point have some relevance to 3D printing. In that respect it seems like something that presents the world in consumers with tremendous opportunities but it carries a lot of risks. One of the things I was looking at this morning was what they call UFPs which is ultra fine particles which is nanotechnology and the reason I mentioned that is I gave a talk yesterday to a group and I said I used to worry a lot about nanotechnology but I don't worry about it quite as much as I used to. We still have concerns but what 3D printing brings is new issues relating to ultra hazardous products. So I do find that as a concern. I guess one of the questions I would ask is how widespread has 3D printing come into the actual production of products that we buy and if so is that taking place in China or is it still a limited market that it looks like it's going to explode do you have any sense of that? I think there's a lot of excitement. Not sure how much it's actually percolated into the large manufacturing mostly because of the limits on production numbers. I think I've heard somewhere somebody say that 10,000 units above that it's not effective it's just not practical so anything that's below that so again I think there's a lot of potential. I think people are trying to find ways to use it. I think there's certain industries that are more suited to use that and to have started using that and I think there's certain areas that have come but I wouldn't say that it's kind of a niche but I would say that it's probably not totally saturated the market yet. There's certainly a wide range of industries that are using it from big to small but I'm not really sure and I don't know without them giving us that information because it's not easy to see finished product either so I think that it's growing. I think that it does represent part of the manufacturing world but I would say it's probably pretty still relatively small. One of the things you mentioned was 3D printers that use metal and concrete. Have those found their way into 3D printers that I buy from my home in other words you're actually buying a home use 3D printer that can actually use metal as part of its material? So I would say the short answer is yes you could probably buy one that that's metal. I think it's it's a little cost prohibitive they're a little more expensive. I don't exactly know what the cheapest metal printer you could buy with. I would expect it to be five thousand or five thousand dollars or greater so it's not it's not inconceivable that people have them especially the people that have a hobbyist or something like that have a specific purpose to doing that. As far as concrete I don't think so I think that is more large-scale type stuff for construction type work. I don't know of any applications on a small scale why you know for putting a you know building your own house or something like that or building a shed I don't think it's really practical. I think it would be cost prohibitive and I think it'd be the printer that they use is not really it's not the self-contained printer that you would see on your desk it would be more of a it'd be more of a different unique looking type of product. I guess I'd never heard of 3D pens until this presentation and that 3D pen I'm looking at page six of the slides looks to me a lot like a soldering iron although I'm guessing it's not quite as hazardous but they can are we prepared to say that the emissions from 3D pens are not necessarily of concern and that high temperatures not necessarily of concern or should people be at least extremely aware of the hazards associated with products like this itself of 50 bucks? I think I default to I would be be aware that it's potential again that's not that's that's more of Dr. Thomas's area so I I'm not really comfortable speaking too much about that because I don't know enough to speak intelligently about it but I would say that basic based on the fact that it's most likely printing out plastics there's the potential for emission hazards and the fact that as everything else I don't think in a pen because of the type of products they'd be printing they may not reach the temperatures that you would see in a traditional for a whole bunch of reasons at least which is the safety of touching it yeah like a like a set of sider soldering iron they may not reach those temperatures so they may not have the emissions problem but I I'm not sure I'd be comfortable saying that they you know they're totally there's that's something that we should totally just discount I'll just add in that it is an area of open investigation force to try to get at the different emissions from the different level of printers yeah and you're not from compliance but I thought I would at least throw the question out have we gotten any 15b reports from manufacturers of 3d products just out of curiosity no I was just curious because when you look at them and there's so many ways that you could have a hazard that pops up that it would be an interesting issue I think my time is right uh commissioner k thank you mr chairman thanks to the staff for the great briefing it's just incredible work that you guys are doing and I know that there's always a balance that the agency between working on persistent hazards that continue to plague American consumers and then also keeping one eye on the future and what's emerging and the staff has done excellent work in the past few years on trying to keep one eye on what's emerging and certainly 3d printing would be at the center of that as we continue to look forward and the chairman mentioned some of the work in the operating plan for fiscal year 2020 but as we continue to work forward I would be curious to know mr mccallion what research in particular that the cpsc staff would recommend be funded by the commission to try to accelerate getting answers on addressing some of the hazards that are of concern particularly as they would affect children I think that the the emissions would be the the primary one for now because the ones we're seeing in schools popping up in schools um I don't know if you can see it really well in the in the picture that we have is they're open to the environment there's no there's no external ventilation or anything like that and I think they're they're looking at ways to manage that um with filtering of some kind I think it's it's unlikely that should be able to or aren't impractical to to hook it up to external ventilation like you would in industrial environment so I think that's the that's kind of the leading concerns we have so the research that we had mentioned in those areas and is that something that could be potentially uh teed up in a mid-year project or proposal to the commission research related to that um I have to I again I'd like to talk to dr thomas I think some of it is actually already being funded but certainly we'll look at any accelerations as we get closer to mid-year do we have any census to the budgetary needs for to fund an ideal research project to get to this like a timing and an amount of money I think I'd have to get back get back to you on that because there are it's the different dimensions of this so the emissions is certainly one aspect the durability of the materials and sort of the full life cycle durability materials is something we just kind of we're just getting our heads around so it's uh I'd like to get back to you if it's as possible okay that'd be great and then there's nothing like the equivalent of NNI in the space I know that there's interagency work but is there anything even remotely as formalized as that of agencies really um prioritizing what needs to be looked at and assigning that out to the agencies with the best expertise or is it much more informal I think that may be sort of what trey is at right the moment um I'm not totally familiar with the conference he's at I don't think mechanically there is anything close to that and is it mechanically the mechanical standpoint it's kind of lagging a little bit behind the emissions is is that that area is a little bit more advanced I think they've picked up on those issues a little sooner mechanical people are just they're a little slower picking up on on the issues but I think they'll get we may get there okay that's great and you know we would continue to rely on the staff to have an ear to the ground to let us know what we really need to be paying attention to and funding and raising concerns about whether it's trying to push for more voluntary standards work because it sounds like there could be gaps in the voluntary standards as well as any other actions that the commission could take so appreciate it very much thank you no further questions commissioner bioco thank you um and thank you for the work on this I love this stuff and I really appreciated your briefing and I thank you for your for your good work and continued work on this and into the whole team I see this as having two silos if you will there are the printers themselves over which to the extent they're defined as a consumer product we have jurisdiction and the issues that are associated with the printer themselves printer itself and then all the products that are coming out of this printer so let me start there because my first question is do we have a an idea of how we are going to or how we're looking at this from which which printer or printers or should be classified as consumer versus industrial I read something along the way where there was some classification if it was above five thousand dollars it was considered industrial versus consumer I would imagine that that's going to develop into something more more substantive than just how much it costs yes I think it's a it's a really good question and it's a really hard one to answer because of the crossover like I said you got five thousand dollar computer printers or less that are that would fit on your tabletop that would be that are with the ease of use are certainly fit within the consumer's grasp of being able operate them and they're being put on on industrial manufacturing floors in a big line because they can then increase their numbers so I think it's it's an interesting question and how would you would do that cost I see that the cost or the size would be two two ways of trying to do that but again I because of the crossover that of purpose I don't know how that would really work out how certainly something that we I know is that that people are dealing with terminology and stuff we're looking at from that side because how do we do how do we differentiate the two we can't I mean it we it has to be a consumer product first before before we take steps right and I think it would be at some point on the ends of the spectrum be easy to determine well this definitely is not going to be industrial or at least right now but your point about the small businesses as well taken you could have a five thousand dollar if you will printer open up in your basement and print out a component part which then goes into a global supply chain that we then have maybe not over the printer or may or may not but then we have jurisdiction over what's coming out the component or the product so I I don't if you can direct me if you know any background on how to make that distinction I've been struggling with that one myself but I find it incredibly just the whole thing fascinating so putting that aside for a second I wrote so many things down I'm just going to try to jump around a little bit and I could be here all day so I'm not going to do that so I'm going to ask the the basic questions because a lot of the things that you raise are issues that the CPSC deals with all the time right plastics and emission well not necessarily emissions but choking parts choking hazards and and so forth do you know of any injury data that's out there as far as products that have injured consumers that work that came out of a 3d printer and do we want to get an east code for that you know where do we start with getting that type of data I can't another interesting question I think that identifying 3d printed parts or products is difficult in itself you have to actually that's my next question right so that would be the first thing I don't think that we have any anything that specifically was identified as a 3d part or product that I know of that that came in as an incident and I think part of that reason is it's hard to identify unless somebody unless somebody was to physically print it and tell us that or that the printer hurt them or the printer right I think we I think I I think I have heard that we had a couple of printer related incidents with printers either fire or electrical hazards type of thing I've seen some sharp edges to here and there right right and certainly a concern with the roughness especially with the the less expensive printers are going to print out pretty rough surfaces so you could have it and again if you start printing out metal parts with rough with rough surfaces on it certainly going to have sharp edges and sharp points your point your example about the bolt was was a very good one do we have or I mean how do you put in best practices to determine the parts that are going to be mixed in how do you know I mean how do you know another hard question to answer it's it's with especially things like open source availability of designs it's just I don't know if there's a good way currently to do that my thought was maybe there's a a software or software with the you know we're doing that but it's more likely I would say if anything could be done it may be done with the printers kind of like a printer detecting if it's genuine he could not if there's something that's obvious then it would be but like just ask me that question it was there anything that like a printer doesn't recognize currency is there any type of program that could go into the 3d printer that would recognize you know you can program it for example to make sure that the bolt that's coming out whether it's plastic or metal is consistent with the standard I I wonder if that's available I think in in the future maybe right now I would say no that's not available the federal interagency meeting are you involved in that there was a slide that mentioned we hosted or somebody hosted a federal interagency meeting on on august 20th yeah that was dr. Thomas oh okay I would just I wanted to follow up with that and see what issues we're looking at specifically how about that I'm jumping around here explosion hazard is another one and back in my old days my old life I had a case that was a sawdust explosion that was sparked by a spark so I when you were given that example I can see that being a real hazard how do we prioritize these hazards okay I'm sorry so a great question so the as Rick kind of glossed over the beginning of presentation the risk management group was rebranded a couple of years ago and refocused on doing just that in terms of looking at some of these emerging hazards but also characterizing what the risks that we're seeing and so they've recently developed what's called p2 to help assess likelihood and consequence information risk reduction and get at what risk are we seeing in various consumer products I would just be interested in that because I can't get my little head around how many issues that I can see coming down the pike some that don't apply to the CPSC but there are definitely a lot of issues I'm going to go back to when you gave me so many good examples you talked about the temperatures and processes during manufacturing for example plastics do we know how a 3d printer processes let's just say plastics at a temperature how that's compared to traditional manufacturing in other words does a 3d printer have to raise the temperature to 100 degrees whereas regular traditional manufacturing only has to go to 50 degrees by those of that numbers but I'd say we got a pretty good idea that I don't have that information right here and I think it's I think we depend on the process as to how high they raised it but I think that there's a pretty good understanding of what that what those temperatures are okay and then we can compare that to a traditional manufacturing because I'm guessing I'm just guessing that the processes that are used you know when you change temperature and properties and so forth that gives you a different result and I I'm guessing that there could be safety related issues on one form of the additive manufacturing as opposed to the subtractive I think that's what it's called right subtractive manufacturer yeah so yeah I would I would say tentatively that that they were probably trying to keep the temperatures relatively similar but one of the problems again with 3d printing is that the local temperature and the cooling effect so that you have you have temperature related variables that are that are in 3d printing that you may not have with an injected molded part where they can keep the temperature constant throughout the whole you know around the whole mold basically where it's 3d printing 3d printing you have that temperature at that spot but it tends to cool as the the jet would move away so I would think that on the they would try to keep them the same what there was all I could find out we could talk specific processes but but there there also may be some differences based on the process okay I'm going to stop there because I like I said I could go on all day but this is fascinating thank you very much thank you I'm fascinated and I was hanging on all of your questions and found them incredibly interesting does commissioner southern have any questions that you wanted to pass okay great please weigh in and I want to thank everybody first for everyone's hard work in putting today's presentation together and thank Commissioner Adler in particular for making arrangements to for me to participate remotely uh I'm with specially you can hear you and would you can hear me we can it's terrific okay terrific uh otherwise I would I would very much like to be there in person um my question uh and I only have a couple of them the first one has to do with the discussion that that we were having about uh the application of defense and aerospace standards to home commercial uh 3D printing units has any thought been paid to the impact on price and availability of these types of units if these types of sort of advanced and industrial standards were applied to these particular consumer products I'd venture to say that a lot of the the processes they use are are fairly expensive and the material certainly because the the main focus I think from the aerospace not so much I don't think as much do d but aerospace is has a very big interest in titanium so I'm not totally sure if if the process is as expensive as the material is but I think those are again there because of the tight the tight specs that are required for for aerospace especially flight flight parts or flight directed apart parts um that that they're not they're certainly not looking at cost and I'm not sure that technology has really gotten down to where it's affordable yet I'm I think as they use it more as it as they kind of moves along moves down the line and make it cheaper but I would say right now it's probably not in the realm of the general consumer but no one's talking about applying standards that may have a preview of pre appropriately placed in terms of that kind of specialty manufacturing that that that no one's suggesting that that it may in fact be appropriate to apply do d or aerospace standards to a consumer home unit this is dwayne bobbas no that that was not uh that is not the intent I think when we were talking about the do d and aerospace we were looking to learn from their application some similar lessons learned uh they've been sort of the leading edge of some of this technology but we're not okay I appreciate that because one of my biggest fears and and one of my biggest concerns that was raised during that that that conversation is that we yet not take steps that needlessly raise costs on these units that provide for sort of fewer choices of 3d printers in in in the marketplace because of the impact that that that these units are having on STEM and participation in in in these types of activities by you know school groups and and children and and because of the sort of various benefits that that these devices offer I think I think I think it's something that we would view skeptically and and with an extreme amount of caution that we uh that we not apply standards that are appropriate for other applications the consumer application uh the next question that I have has to do with discussion about uh emissions um how does the cpsc make a determination about whether whether we would be the appropriate agency for being an emissions regulator with respect to 3d printing in these processes versus for example the the epa if I might that sounds like a legal question uh in addition to a technical question I'll leave it to the technical staff to help us understand uh where you draw the line on those but at some point probably is a legal question in addition uh so this is Dwayne Boffas I'll I'll start with that uh certainly is uh as we noted many of our efforts in this area have been joint with epa and others and uh really we're all kind of working our way around this rather new problem uh our focus is very much at the specific consumer product level epa typically takes those at a broad kind of cross cutting approach but it would really kind of be more at a case by case basis and I'll turn it over to give I'd be happy to discuss that question uh but I think that um it there are uh there are some statutory rules that limit our jurisdiction in this area um a lot of times though I would agree 100% with what Dwayne just said that we work out cooperatively with the other agency how we will deal with things and uh there are there certainly is uh an area of jurisdiction for us in this we're not prohibited from regulating emissions in appropriate circumstances so it's a it's a I would just put on the table for consideration that epa has perhaps more history and more familiarity with regulating emissions in the cpsc uh and therefore I think it would be important that we sort of keep a clear eye on where that that that uh jurisdictional line exists including if there are actually statutory prohibitions on on where we can go and pay attention to emissions I can agree with those questions appreciate it thank you uh thanks very much peter and I don't have too many questions I did want to just raise a concern that I think commissioner Bianco put her finger on and that is and then you did as well and that is my nightmare is uh consumers acting as manufacturers and somebody's producing stuff that they get downloaded from open source and they're not warned about don't use these kinds of materials and don't make it with sharp edges and sharp points uh it would be a fascinating exercise just to look at the definition of a consumer product and see how far our jurisdiction would go but I'm not so much worried about that as I am just worried about the hazards that would be out in the marketplace um how widespread if you have any idea is the amount of open source materials that people use to download to use with their home 3d printers is it voluminous is it growing exploding I would say generally it's pretty widespread um as far as growing I'm not sure it's it's growing any faster than anything else but I think well it scares me yeah it's yeah it's but I think it's if you wanted something a part you could probably find it um there may be some areas that are more that have that have more interest in doing stuff like that I mean there um the novelty stuff is probably pretty common um there's there's specialty interest stuff I heard anecdotally that um model railroaders have a lot of interest in this so there's probably a lot in that area automotive for old cars there are a whole bunch of those type of areas but I expect any specific areas that are growing or anything and I would say generally that is you mentioned the possibility of somebody hacking into a connected device that's a 3d printer of how common do you think they they are in the market that are actually connected 3d printers and is this something that's likely to expand I can think of other devices I'd rather have connected than my 3d printer but you tell me so I would say I would venture to say that they're virtually all connected in some way shape or form right that's just the way things operate like a printer would be um so they're they're have some kind of connectivity because they they will need to communicate between your computer or your programming oh it's the printer so they're they're doing that as far as being vulnerable to attack I'm not sure what kind of security they have on there or how how if anybody has found it but hackers are pretty creative I wouldn't be surprised if they decided to for my guess would be something like a denial service type of thing because there's probably not enough to to warrant somebody to go after individual ones I'm not an IT person but I would definitely go with their most likely connected at least I could see a horror movie of somebody taking over printer and printing out the killer robot that attacks everybody in the home but hopefully that's a that's far away those are all my questions at the moment Commissioner Bianco back to you thank you um I don't have any additional questions um for this here I as I mentioned I have a bunch going forward if just on the on your point about the connectivity I might be wrong about this but it's my understanding that the anything that's wireless that provides the mechanism to hack into something that's connected if you will um so I I think that that's one issue but I think that of all the things you can hack into because I don't I don't want to create the robot that kills somebody in the middle of the night it would seem like it's wouldn't be a this day and age it wouldn't be the the biggest target but certainly along along down the road it certainly could very well be Commissioner Feldman do you have any other questions I have no additional questions okay thank you um this does strike me just thinking out loud about we probably ought to be thinking about doing some kind of fact sheet for the world given the array of hazards and with the rapidly expanding use of these devices just something general to say think about what you're breathing think about what you're plugging it into think about your fire potential think about the nature of the chemicals that are put into it it's just a broad array of issues so I hope we never get to this but I could see this becoming as big a concern in some respects as the IOT issues that we have but I'm keeping my fingers crossed that this will not rise to that level I do want to thank you so much for a truly outstanding presentation and thank you again and I'm going to wish the Nats well in their game tonight