 Good afternoon and welcome to this public meeting of the United States Consumer Product Safety Commission. We have one item on the agenda this afternoon, a public briefing on the subject of micro-mobility, a product category that includes e-bicycles, e-scooters, e-skateboards, and self-balancing scooters. Micro-mobility is a product category that emerged recently with hazards immediately evident in terms of self-balancing scooter fires and falls. More recently, other product types have come onto the market as well as new applications in a rideshare role. I'm pleased to welcome Doug Lee, the Electrical Program Area Risk Manager, who has led key initiatives in this product area. Mr. Lee is joined by Dwayne Bonfuss, the head of EXHR. We'll start with the staff's presentation followed by rounds of questions from the commissioners. We'll start with five-minute rounds, but again, I try to be flexible and we'll go as many rounds as needed. And with the concurrence of my colleagues, I will call on Commissioner Feldman first because I understand he may have to leave early. So, Doug, if you would, please proceed if Doug is the one who's going to proceed first. Thank you, commissioners. Good afternoon. I'd like to welcome commissioners, CPSC staff, and guests listening in today. Today, we are going to discuss micro-mobility, the potential hazards, and provide a risk review. Before we get started, I would just like to acknowledge the work of the micro-mobility products team, so mouthful there. Some of the initial work was done by Rick McCallion, who's the Mechanical Recreation Sports and Seniors Program Area Risk Manager. So that's another mouthful. And myself, the Electrical Program Area Risk Manager. I'd also like to introduce Lawrence Mella, I think is in the audience. He's a mechanical engineer in the Director for Engineering Sciences, and he will be leading a micro-mobility products multidisciplinary team of experts to address the hazard, along with Jacqueline Campbell. So I won't discuss everybody on the list in the interests of time, but all are very important to the project team. So first, we're going to talk about the product. What are micro-mobility products? As defined by the Society of Automotive Engineers, micro-mobility products are motorized, low-speed, small personal transportation devices or products for roadways, sidewalks, and paths. When we talk about motorized, it's meaning fully motorized or pedal assisted, or assisted by kicking. Low-speed is designed for 20 miles per hour or less. And small size, meaning it's three feet wide or less, an ability to fit on typical bike lanes and sidewalk paths. And typically the products are also lightweight. There are three basic categories of product which are defined in the info brief reference here and compiled by a DOT contractor. The info brief is entitled The Basics of Micro-Mobility and Related Motorized Devices for Personal Transport, of which CPSC staff provided comments on the document. So category one is essentially electric standing or sitting scooters. Category two is electric bicycles or e-bikes, otherwise known as e-bikes, and within that there are three subcategories. Class one is pedal assisted. Class two is throttle assisted. Class three is pedal assisted, higher speed e-bikes. And the third class is e-skateboards, including self-balancing scooters or hoverboards, including single-wheel products and variations. There are many variations of this product being developed. So here are some pictures of the products just to describe, that we just described. All these products fall within CPSC's regulatory jurisdiction. So you've all probably seen some of them are sitting one wheel, this one's a standing one, and there's also sitting scooters of course. There are many similar products on the market that might be considered micro-mobility. However, for the scope of this project, products that are not consumer products include mobility scooters for medical transportation purposes. Moped's and scooters for streets and motorized or motorcycles for streets also. Those are handled by DOT. Consumer mobility products that are not micro-mobility products include golf carts, which are of course operated on golf courses. Battery-powered ride-on toys, which is CPSC's jurisdiction, and is mainly handled by the ASTM F963 voluntary standard for toys, and also go-karts. So again, these are things that we're not considering micro-mobility for the purposes of this project. What are the new product trends? New battery development, mainly lithium-ion batteries, has made personal transportation products more affordable for consumer and commercial development. Shared-use commercial products have grown in cities and universities. Coexisting on streets and sidewalks with motor vehicles and pedestrians has been a major concern. Safety issues have developed from the new market trends. Documented mechanical, electrical, and fall hazards we have seen. Dockless products can be a public safety issue or a tripping hazard. As seen in the photo at the lower left, people have just left the e-scooters on the sidewalk right in front of a sidewalk. So this is of course a tripping hazard, and you've probably seen pictures of these devices left by the subway entrances as well. So it's not only an eyesore, but a safety issue that we're concerned about. On the lower right is a person that's gone around collecting the e-scooters for purposes of to make money. Some rideshare companies allow individuals to collect these devices and take them home and charge them. And that's been a charging of, hoverboards has been a serious concern of ours, of course, from the beginning. And these batteries are larger battery packs. Some other ridesharing companies do have training and train their personnel to take these units and charge them to official docking stations. So that's a little bit safer. Micromobility products and the internet of things. Just about everything manufactured today is being connected to the internet. And micromobility products are no exception. Some consumer products need connection to the internet just to activate or use the product. Commercial rideshare products will need mobile access to the internet to unlock and use the product, although some may still use credit cards and a docking station. Since products are connected to the internet and involve the use of software, there is a potential for software issues. Cyber security hacking issues or remote updating issues, if it's not properly updated, can be issues. Connecting to the internet can also be a good thing as it allows for the product to be improved with software fixes, including automatic or manual updates. Just last week's staff were talking to some people at XFO and there's an incident in Sweden where it was connected to the internet and all of a sudden it lost connection and it just stopped the rideshare device. So that's, you know, needs to be worked out within the voluntary standards. Next we'll talk about hazards. You've probably seen many of these. We've addressed this, I guess it was 2016, incident from self-balancing electric scooters. As we mentioned, charging can be very dangerous. Products do not have good quality cells, good battery management systems or safety circuits to prevent cells from being used outside their safe operating region. As you can see here, it just takes one cell to go into a thermal event, thermal runaway it's called, and then it takes out all the other cells. And that's typically what happens with a hoverboard, it just takes out the area where the battery pack is. And we had many serious incidents, I've just pictured a few of them here to show how serious it has been. And the upper left corner, two little girls lost their life because of this charging incident. And the center is over a million dollar fire and one in the right was caught locally, but it did ignite their bedding and they did get out safely. Continuing to talk about the incidents, three deaths from two battery related incidents. We investigated more than 330 fire incidents up to March 2019 with non-certified product, over 9 million in property damage, and we've had two deaths from falls. There's been an estimated over 70,000 emergency room visits through 2018. 90% were fall related, 13% involved head injuries, 40% involved arm injuries, usually fractures, 38% or contusions were reported, and then 16% lower level hazards, sprains and strains. Incidents from e-scooters and e-bikes. We know that annual bicycle incidents include an estimated 467,000 injuries and over a thousand deaths. We believe that some of these incidents may include e-bikes depending on how they are reported. E-bikes does have a separate product code and there are an estimated 20,000 incidents annually. Since the number of micromobility products is increasing, we might expect to see a rise in injuries and possibly severe injuries involving e-bikes and e-scooters as e-bikes are faster, heavier products with more controls and features and things like displays, cell phones and other things can cause distraction while you're riding e-bikes. We know from reported incidents and seeing products used on the street that helmet use is very limited. Helmets may not be readily available when needed. Carrying a helmet around during the day is a problem for some. And we know that helmets use may reduce the severity of head injuries from other studies. An epidemiology report of micromobility product incident data will be completed later this fiscal year. So when we were classifying incidents with micromobility products, typically we classify them as either mechanical or electrical because different people usually handle the address and the hazards. The major categories of mechanical incidents include falls, motor vehicle collisions, frame or structural issues and braking issues. The electrical categories of incidents include charging issues, fires from batteries due to mechanical mounting issues and braking software related issues. The cause of micromobility incidents can be broken down to three areas, the product, the rider and the motorist. For the product, brake issues including brake failure, unexpected braking or just being unfamiliar with how to use the brakes has been reported. Structural resilience including cast or welding issues not being able to withstand the rider loads and impacts during use. Variability in operation and performance such as braking or steering has also been reported. We've seen lack of warnings and instructions for consumers and there have been also maintenance issues with the product. For the riders, the cause has been from being unfamiliar with local laws or choosing not to obey them. The rider is unfamiliar with the product or not able to avoid cracks, potholes or drainage grates in the pavement or sidewalks. Riders have also simply lost balance or have been thrown off products while trying to avoid obstacles. For the motorist issues, the cause may have been that motorists are unfamiliar with bicycle or scooter laws. The motorist may not yield to bikes or scooters if they're in a hurry or simply do not see them. Next we'll talk about hazard reduction efforts that we're doing. When we look at the regulatory landscape, the use of the personal or ride share product is regulated by the local jurisdictions and transportation departments such as city, state or universities. Helmet use is limited as we discuss because they may not really be available when choosing to use a ride share device, thereby increasing consequences of incidents. The use of sidewalks or requirements for roadway use may vary by jurisdiction, sometimes confusing both the rider and motorist on the streets. Next we will look at the CPSC bike regulation and voluntary standards that are available. The CPSC bike regulation at 16 CFR part 1512 requirements for bicycles include mechanical requirements for bicycle and electric bicycles. However, there are no electrical requirements other than to limit the speed of the bicycle for mechanical structure of the bicycle. Similarly, many ASTM International, European Committee for Standardization, or CEN, and International Organization for Standardization, ISO, Voluntary Standards for Bicycles, both types and conditions, or there are multiple types of mechanical conditions, provide requirements for the mechanical requirements and safety. The voluntary standards for mechanical aspects include ASTM F2641 and ASTM 2642, which is the labeling or co-standard for the mechanical requirements in F2641. Staff believe these standards need to be updated to address new lithium battery products. Staff is involved with two F15.58 working groups, one on hoverboards and the other on commercial ride-sharing type scooters. The draft standard commercial electric powered scooters for adults has just been begun. We should note that there seem to be good participation in the early stages of the standards development from the ride-sharing companies at this point. Looking at the electrical voluntary standards, staff has been involved in UL 2272 from the start in 2016 when the peak incidents occurred with hoverboards. So the new 2272 standard is called Standard for Electrical System for Personal E-Mobility Devices. So it basically includes many of the products that we are interested in here. UL did publish a UL 2849 standard just last month and that addresses electrical systems for e-bikes. There is European standards EN15194 that covers electrically powered assisted cycles and there's ISO standard which is in draft form for e-bikes. So next we're going to talk about what we see as the path forward. As we look at regulatory clarity, the use of the product is defined as we said by the Department of Transportation and the local jurisdiction. And CPSC of course has the product safety jurisdiction. So there is some work to coordinate on addressing the safety hazards. We need to better define the hazards and how we can improve safety. In the fall of 2018 staff worked with Worcester Polytechnic Institute students to take an initial look at hazards and use for ride-share devices. This was a limited study in the Washington D.C. area that we needed to expand to other markets. It provided a limited data set. We need to identify hazards better within each product group on consumer and commercial levels. To address the hazards, CPSC staff will be holding a Micromobility Public Safety form later this year in June. And we hope to bring multiple stakeholders here and get the hazards on the table and then look at potential solutions for those hazards. For risk assessment, the risk management group staff is tasked with drafting a summary report hazards associated with Micromobility products this year. It basically will be a written summary of what we're presenting here today. We also discussed that there will be an epidemiology staff report on all Micromobility products later this year. Detailing more of the previous incidents that I briefly discussed earlier. Like other consumer products, staff continue development or improvements in the relevant voluntary standards to address incidents. For ASTM, staff is currently working on commercial scooters and self-balancing scooters with industry. Recently, staff also sent a letter to ASTM to provide incident data and encourage further development of the standards. For UL electrical standards, staff will continue to seek improvements where needed. Just note for the compliance, there are involved in some cases as reported incidents and will continue to address those incidents as they arise. For outreach efforts, the Office of Communications is planning safety alerts and public service announcements in conjunction with a Micromobility team to better educate consumers. Collaboration with stakeholders. Staff has been and will continue to collaborate with the many stakeholders. We'll just name a few here. Interagency-wise, staff is coordinating with the Department of Transportation, the National Highway Transportation Safety Administration, and the NTSB to address safety of products combined with use on streets and public areas. Staff is also working to coordinate lithium battery safety and transport a product with the Department of Transportation Administration, the Pipeline Hazardous Materials Safety Administration, and the Federal Aviation Administration. Through interagency agreement, staff has been collaborating with the Naval Warfare Center Carderock Division locally, leveraging their battery expertise with CPSC's product safety knowledge to address safety hazards as seen in the field. Staff is also using NSWC Carderock to also review new technologies that could be used for consumer products. Staff collaborate with manufacturers and trade organizations to improve voluntary standards. Staff work with safety advocates to address hazards. Staff have shared safety information with safety counterparts in various countries and will continue to do this on emerging hazards in this area. So in summary, staff believe that the key points to advancing consumer safety include improvements in voluntary standards, educating consumers on understanding of safe operations, and improving product design and maintenance to address field incidents. So with that, we'll take questions. Doug, thank you very much. Commissioner Feldman. Thank you. Acting Chairman Adler, I appreciate the courtesy in letting me go forward and also for some help with the scheduling of the meeting this afternoon. I appreciate that. Thank you all for being here and for the overview. I think that when you look at micro-mobility and e-scooters in particular, this is an innovative product category. It's arisen, as I understand it, to meet consumer demand to fill the so-called last mile problem where legacy transportation systems are inefficient in delivering people to their final destination. And I think that's one of the reasons why you tend to see a number of these products clustered around, for instance, metro stops. But I think it's important that CPSC proceed with some humility here and that we avoid the precautionary principle so that at the same time we leverage all of our resources to make sure that there's safety in the product category and that we're maximizing innovation and competition in this particular product segment. That said, in listening to the discussion today, does it make sense to bifurcate e-scooters in particular, the agency's approach to focus on commercial and fleet applications, ride-sharing apps, versus the product devices that we're seeing available directly to consumers through retail that are docked at home? I guess we're collecting the data later in the year. I think we need to see where the incidents occur. So I think how do you separate that is often difficult. Some of these devices are essentially the same. And then commercial use will be a little bit more stringent on that. So I think the ride-sharing companies are in at the voluntary standards and will provide input, and we will provide input based on what we see as our data. I think that that's going to be a critical piece of getting this right to make sure that we avoid, to the extent that we're talking regulation and standards, holding certain applications to a standard that's just inappropriate and doesn't sort of fit the fact pattern that we're seeing in the real world. But Dwayne, it looked like you wanted to jump in there. Yeah, and I think that your point is well taken. As a matter of fact, staff's letter to ASTM really focused on encouraging work in the commercial electric powered scooters arena, just because there is what we're seeing is a significant difference. We're seeing many more incidents with these commercial devices, and so your point is well taken. But that could also be due just to exposure rates. It certainly is. I think and what our letter to ASTM is focused on, let's try to sort through, is there a differential product hazard pattern, or is it just due to the exposure? Got it. Can you talk a little bit about the competitive landscape of the e-scooter market? Well, I guess we can say it is very competitive. I've just seen them grow in many cities and there's often two or three companies in cities and they have to usually get approval from the local jurisdiction. So there is competition and there's competitions as we showed there to grab a hold of these devices and charge them up. So I don't know if you want to add? Yeah, certainly there's been a growth in the number of the entities providing the commercial service. They are often locally regulated, so there may be a limited number that are allowed, but there is a healthy competition. I got it. When staff participates in voluntary standards development, one of the things that the commission is supposed to consider is, among other things, whether the voluntary standard excludes requirements that would be anti-competitive or that would create a restraint of trade. Have you conducted that analysis? So as we discussed in other forums, we have and continue to look at anti-competitive as an element. I think we have the benefit of the ANSI standard umbrella and the essential elements, which do have a pretty strong competition component in there, but it is an element that we continue to look at. Okay. Has the UL 2272 standard, has the scope of that been expanded to include handlebar scooters? Has that been validated yet? 2272 is for the electrical system, so it does include powered handlebar scooters. I noted on the slide that it hasn't looked at the ride sharing, but the basic safety of keeping the cell within the operating region, all that should be the same. I mentioned an incident with Sweden that the internet connection issues could be a concern, so that particular item hasn't been addressed with that particular standard. Okay. I appreciate the attention. Thank you all for being here. My time's expired. If you feel the need for additional time, feel free to take it. I may have additional questions, and if it's okay with everybody, I'd like to follow up in writing. That sounds fine. Thank you very much for the presentation. I did want to address the notion of competition, and this is one where I suspect Commissioner Feldman and I are on the opposite sides of the street with respect to that, because one of the concerns I've had is that this seems to be a product where at least the players feel first mover is a major advantage, and to me that has suggested that sometimes they're a little slip shot in producing and manufacturing their products. Do you have a sense one way or the other? Again, we're asking economics of folks who are not necessarily economists, but do you have a sense of whether that is a great dynamic within this industry, or am I just mistaken in my assumption? Yes, certainly we have, as I noted in an earlier response, there's significant competition at the local and national levels between these services, and we've seen kind of ebbs and flows between them as the market has evolved. One of the things I've also noticed about the e-scooters is there just seems to be a fixed notion about how wide the handlebars are, and that makes sense because if you're riding them down a street and the handlebars are too wide, you're going to whack somebody as you drive by. But I do note that bicycles have wider handlebars, and it always seemed to me that when you have these narrow handlebars, that makes them incredibly unstable. Is there any movement or interest or voluntary standards activity towards addressing whether wider handlebars would make for a more stable product? We'll have to check with the mechanicals and get back to you on that issue, but I think just from riding them personal, I think it's more a stability thing. We noticed the scooters, you know, the self-balancing. No, that's actually what I meant. I meant that they're making them narrow so they don't hit people as they ride by, but the fact that they're so narrow makes them unstable is my thought. Well, what I was trying to get at is like the self-balancing scooters don't have any handlebars, right? And so that's a different story, is the riders trying to maintain their balance. It is. I see some guy going across the bridge. It looks like 30 miles an hour just holding this briefcase or reading a newspaper, and that just scares the daylights out of me, but they have them and if you make a product, I suppose somewhere you'll find somebody who's willing to use it. Again, I apologize for interrupting. Yeah, so I think the width has to do something with, you know, you want it narrow so it is not, you know, snagging obstacles or other people on the sidewalk, but the stability, I think there's some work to do there, but my feeling is that the wire it is may be more of a comfort thing to riders and stuff, and it's kind of related to, you know, biking and speed, and they had the old racing bikes where you were narrow to draft, and, you know, so it's not necessarily related to stability on the bike or the... What about a wider wheelbase? I see little kids on scooters that have double wheels on them and I'm wondering if that makes them more stable and has anybody come up with a wider foundation to any scooter? I'm guessing the answer is no. Are you talking about the self-balancing scooters? Yeah. No, no, I'm sorry. No, I'm talking about the ones with handlebars. Okay. Well, the wider tires actually help because of the cracks on the sidewalks. Yeah. And so that being stable, but there are different lengths and stuff according to their intended for smaller children. Generally, they're a smaller wheelbase to accommodate the rider and balance of the rider. I just love playing mechanical engineer. I did want to ask one other question, Doug. Do you have a sense about the scope of the battery problem? Is it pretty much fixed? Is it still growing because there's new technology that's coming on the market? In other words, how serious is the battery fire problem at this point? I think with the... The battery problem is going to be different for e-bikes and the self-balancing scooters. The self-balancing scooters had a lot of inrush currents, starts, and stops, so your temperature of the cells continued to rise and rise. Whereas the e-bike use and scooter use, you're going to... Like a car, you start and you start going, so it's not as extreme. And then the cells and capacity have meant, you know, especially for ride sharing devices to last throughout the day. So there's not as much stress. That being said, though, there are incidents. And if I alluded to earlier, if the battery is not carefully... where the cells are not carefully maintained with their proper voltage current and temperature, you can have incidents. So we've had incidents. And, you know, what happened with the hoverboards is we enforced meeting the voluntary standards. And that all but, you know, reduced the incidents. Thank you, Commissioner Kay. Thank you, Mr. Chairman. Thank you to Mr. Lee, Mr. Boniface for the presentation. And Mr. Boniface, this might be better answered by you. I just don't know, or maybe Mr. McCallion needs to jump up to at least supplement the answer. So I'll start, I guess, with Mr. Boniface. To what extent has staff prepared changes to specific changes to the voluntary standards or additions to the voluntary standards, technical changes, test requirements to address what we've seen so far with these products? So if you look, for instance, at scooters, clearly there have already been a number of issues. We've seen battery issues. We've seen fire issues. Well, those are the same thing. We've seen fire issues with batteries. We've seen the boards themselves breaking. We've seen breaking issues of the tolerances and as well as maintenance issues. So we've already cataloged a number of the hazards and the design flaws associated with these. And so have we already prepared what we want to see in terms of changes to the standards, whether it's UL or ASTM? A good question. We have not prepared specific changes to the standards. However, earlier this month staff did send a letter delineating actually those very same list of issues. The structural resilience of the products, particularly given the heavier use, user interface usability familiarity with the products, warnings and instructions, breaking systems and commonality thereof. So the letter that we sent included that a list of here are things that we believe need to be looked at and potentially worked on, but we did not delineate specific changes at this point. I see. And thank you for that. We not only have a test rig now at 5RP that's capable of at least testing some of these aspects. Are we including in the current year's work plan going out and either purchasing or renting these units, using them and doing sort of a cross-sectional in essence PSAs on these to try to gather the type of intelligence that we would have so that we would be able to be better armed when we go to the voluntary standards? We do have a healthy degree of testing that we have been doing. Part of that is in support of compliance for four cases. We also have another project that we initiated at the end of last year, getting assistance with testing these software aspects. That was a capability that we felt could be buttressed. So as part of that we've also been testing. We don't have as yet a program of going beyond that. Quite frankly, we've been doing a lot of support to compliance in this area. So we've been doing a fair bit of testing. So is the hope that we're at least getting enough of a cross-sectional look at these products through the compliance testing that maybe that is good enough for this round? I think at this stage it's certainly between the testing that we've done, the incident data that we've reviewed, whether it's from consumer reporting or manufacturer reporting, has given us a solid basis for here are some of the hazard patterns that need to be worked on and given us some preliminary insights. So that gets us to a stage where we think we can have a good focused dialogue with the voluntary standards organizations to try to address that and we may need to pick up additional testing to work out some of the finer details. Got it. Thank you. And then you mentioned software. One thing that we haven't really talked about much is hacking because there's been at least one case of a scooter being hacked. And so I was curious to know where that fits into this, whether that is Mr. Lee or somebody else to answer. I recognize that there are separate ASTM and UL efforts as well as others underway for connected devices. But I'm wondering how that all ends up coming together to make sure that we're not missing that component as the connected part intersects with safety. I'll try to. We're doing a number of things with the Internet of Things project. So it does tie the hazards do tie together. So we're working with NIS as part of an interagency agreement. And so they're combining consultation expertise to help us understand that. And then Dwayne also mentioned the contracting work that we have is also looking at that aspect of it. So that is on our radar screen. There are UL voluntary standards that do presently address some of that stuff. The thing that needs to be put together is the requirements to get them into this standard and how do we address those getting those requirements in. Great. Thank you very much, gentlemen. Commissioner Miyako. Thank you. And thank you for your presentation. It's incredibly thorough, which shows us, I think that there are a lot of issues here. And I can't help but wonder if we're really going about this the right way. And when I say we, I don't mean the CPSC. I mean everybody who has a hand in this because there are so many issues that I think some of the things that Chairman Adler raised today are questions that I have. But to answer them, it depends on the use of the product. I'm uncomfortable candidly with using the same type of scooter that you would buy for your kid in the driveway as you would use in these commercial scenarios. So when Chairman Adler raises issues about how wide the handlebars are because we're going to use them on the street and try to get between, you know, whatever it is they get between, that's a different scenario than if you're using them in a much more controlled environment. And some of the standards here I think are not universal. I just can't get my little head around how a commercial scooter used on the roads by people who just pick them up, put them down, throw them down because they're not theirs. In conjunction with bike lanes and cars, which I see as a free-for-all and using the same scooter that I would buy from my son or daughter at Christmas time how those standards could address that straight across the board. And I'm wondering if whether we're all, not just the CPSC everybody's running around and making determinations that aren't really going to serve safety at all. Thoughts on that? Yeah, if we go back to the mechanical voluntary standards. So there is a voluntary standard in place for powered scooters for commercial products already. We need to update. So let me stop you because I did circle that. Okay. What exactly defines a commercial scooter? Okay, so that's going to be defined by this new working group effort which includes the rideshare manufacturers. It includes CPSC staff and other consensus. Okay, I'm sorry. Let me try again. Okay. Tell me how a commercial scooter, the product itself differs from a consumer scooter because if I look at the two sitting side by side, it's the same darn scooter. Yeah, in some cases right now they are the same product on the market. We believe that for commercial use, they're going to see more cycles of battery charging, typically heavier loads or a wider variety of loads. You know, you may buy a scooter for your child who only weighs a certain amount, but the ones on the street may see large individuals. And I want to stop you right there. That's exactly my point. Okay. It's very difficult to make a voluntary standard that addresses both of those scenarios straight across the board because we leave out use. So if my center daughter who's going to be using it in the driveway or the neighborhood weighs a certain amount of pounds, how the scooter itself is designed, the distribution of weight, the center of gravity, the size of the wheels, the size of the hand board, the speed, the brakes, very different from the voluntary standard if I, in my high heels, God, for God, don't let me on these things. Can you picture Bob's description as prissy as I am standing on something like that in my high heels with my designer bag reading the paper? That is a disaster waiting to happen. And it's a funny sight, okay? You cannot have the same product voluntary standard to accommodate for that as you would effectively the same scooter that my kid would ride. Do you follow me? We could talk about batteries. We could talk about some things are, they cross the lines. But how it's used makes a difference in what the standard should be on the scooter itself. Duane, do you follow me? Yeah. And I think we wholeheartedly agree. And as I noted, we had a letter to ASTM earlier this month to basically get at that specific issue. And I do note that ASTM has two, it's behind. So we already have ASTM standards in place for the, what I call the private use, the consumer, typical consumer, where they are starting to work and our letter pushes them on that regard, is on the differences associated with these commercials. Because it's, as you noted, it's a different use pattern, different users, less familiar users, potentially larger users. There's just a range of differences. And I think the product needs to be different personally. So, and I think that that's what the intent of this standards effort is, is to define what the product, what the standards that that product should meet. And so, should it have a more robust platform? Should it have a more robust braking system or so forth? That's what we're looking to work through. Okay. All of my questions stem from that and I'm out of time, so. Thank you. And actually, the image that you just presented is when I see from time to time as I'm walking downtown, I'll see a young lady in a business outfit, no helmet of course, high heels just blazing down the sidewalk and it always gives me a moment of concern. I only had one question and one remaining and Commissioner Kay basically asked it and that had to do with hacking, but one of the things that a nightmare scenario and maybe it's about as common for appliances as it would be for scooters, but how easily could somebody hack into an entire system, hit a button, and all of a sudden every e-scooter that belongs to a particular product stops immediately or is it because they're calibrated for each separate scooter that that is an unlikely scenario to occur? They might stop one, but would they stop hundreds? And I see Patti Adair there and I'm sure she could just come up and give us an instant answer. I think that concerns us as well, you know, hacking and one minute we don't have any incidents and then all of a sudden there's potentially millions of incidents. The good thing is people are generally not hacking consumer products, they're hacking to get financial gains. So that's one thing we've learned. That's reassuring. Yeah, so we do want to make sure that, you know, and working with NIS what we would recommend to consumers and getting the level so that we're not concerned that there are multiple products out there that can all of a sudden have issues. We have seen reported hacking issues that people are affecting the brakes, but have not been able to confirm that yet. I mean the one thing that's clear is that the manufacturer certainly knows how to invalidate or inactivate all of it because when we had the cell phone issue, if you hadn't returned your cell phone by a certain point, they were all inactivated or deactivated. So it is a concern. Anyway, thank you very much for that. I don't have any further questions. I would encourage us because there's so many issues and because we talk often about resources, this is one area that I think we ought to narrow our scope to make sure we're addressing our issues, consumer product safety, as opposed to being part of something that is so big and has so many issues that really don't pertain to us. That's why I'm concerned with just setting standards that go across the board. I wonder if we shouldn't start and look at whether, you know, we could carve out the batteries I get, that makes sense, but whether we should be carving some of the stuff up and putting safety standards in place that, you know, I'm going to come back to this and maybe someone could talk me out of this because I have not researched it and I haven't talked to either of you about this, but having a different scooter manufactured, a different standard, if you're going to manufacture a consumer scooter, it looks like this, ABC&D, and if you're going to be using it in this, it has to have, it's going to look differently. You can't roll off the line the same scooter and then put it in a docking station or my house and say that it's commercial versus consumer product. Yeah, I think, you know, that's the intent here. There is a separate standard for consumer products and industry, including ride-sharing manufacturers, is getting together to address the commercial. So there will be two separate products. Okay. Right now. There's just one. There could be one. I'm not saying all the manufacturers or ride-sharing companies are using the same. They kind of look the same and may actually be manufactured by the same company. Inside, it may be totally different and may actually be more robust. So I'm not sure that eases your concern. So you're telling, we're just not there yet. Right. Okay. Okay. Thank you. So thank you to Mr. Lee and Mr. Boniface and to your impressive and large team that's working on this project. I'm delighted to see all these talented staff working on it. This concludes this public meeting of the United States Consumer Product Safety Commission. Again, thank you.