 Good morning everybody and welcome to the Consumer Product Safety Commission's National Product Testing and Evaluation Center. My name is Dr. George Borlase. I'm the Director of Hazard Identification and Reduction here at the Consumer Product Safety Commission. And I would like to welcome all of us and all of you to the public meeting requested by WCMA to discuss window coverings and specifically the technologies that are currently available, what alternatives are achievable, and impacts on the end users. On January 16th, 2015, the Federal Register published an advanced notice of proposed rulemaking on courted window coverings because, and I quote, the commission has reason to believe that certain courts on window coverings may present an unreasonable risk of injury to young children, end quote. The commission approved an extension of the common period to June 1st, 2015 next week, and during this time WCMA, the Window Covering Manufacturers Association, requested a technical meeting to discuss window coverings, technology, innovations, and challenges. I'm thrilled today to have this panel assembled to discuss specifically the window coverings and the technologies. We have five technical experts from the window coverings industry and also CPSC staff here, five each, and so I'll just turn it over and we'll each go around and introduce ourselves, name, title, and affiliation please. Hi, I'm Mark Kumagai. I'm the Division Director for Mechanical Engineer at the CPSC. Good morning. I'm Jeff Stout and I'm the Senior Manager for Levenlor Kersh Products. Good morning again, George Borlase. Good morning, Tom Markersprings, Window Fashions, Director of Engineering. Good morning, I'm Joel Rect. I'm the Director of Engineering here at the CPSC. Good morning, Derrick Marsh, President, Roli Zakimita. Good morning, Rana Balgis, Human Factors Engineer and Project Lead for Window Coverings. Good morning, I'm Jim Anthony from Hundred Eglis, Senior Development Engineer. Good morning, Kevin Lee, ESME, Mechanical Engineering. And good morning. I'm Joe Kovac, Hunter Douglas Vice President, Product and Development. Thank you. So thank you all. We've got a pretty ambitious agenda for today, I'll say, and very pleased with the agenda that the Window Coverings Manufacturing Association put together for the meeting. We'll begin with introductions and opening remarks. We'll then go over some of the definitions and terms. I think doing that first will be extremely helpful as we have the rest of the discussions, so that at least we're using the same definitions to describe the same things. Next, we'll have an overview of the current technologies and Window Coverings. We'll talk about the innovations that each of the companies have brought with us. As part of that discussion, no doubt we'll be talking about some of the technical challenges associated with these Window Coverings, and then probably the part I'm looking for most to the next steps as we wrap up the meeting today. So before we get started, though, a couple of housekeeping and rules of the road, if you will. First of all, while we're having the meeting, if by some chance we do have an alarm, say a fire alarm that goes off, the fire escape procedures are to please exit through the doors that you came in, the front doors, go through both sets of double doors outside, and then we ask that you go left, and to the far end of the parking lot, where most people probably parked, that grassy strip between this building and the old strayer building, we ask everybody assemble there so that we can check in and make sure that everybody made it out of the room okay. During the meeting today, bathrooms need to freshen up. The bathrooms are right through these double doors here. They're not secured, so you don't need a badge to get through them. Right through the double doors there, water fountain, men's and ladies' restrooms are right there. Would also ask that if you do have a cell phone on you that you have it on vibrate or silent, please, so that we can, you can still know that you're getting a call, but everybody else won't also know that you're getting a call. We have a number of distinguished guests and members of the public here today, and I think everybody for coming in, I know some people have traveled some distances to get here. Mr. Ralph Asami, the executive director of WCMA. We have a number of representatives from the commission offices here at the Consumer Product Safety Commission, so welcome. We also have parents of children who have been killed in window covering accidents, and we thank you for coming today. We also do have some members of the press. With respect to rules of the road for today, the meeting was called by the window covering manufacturer, or requested rather, by the Window Covering Manufacturers Association, and all the parents or participants, rather, are at the table. I do ask that all the audience members respect WCMA's request for the meeting and hold all your comments and questions. As you can see, the session is being videotaped, and the session will be available on the CPSC website no later than this Friday. Finally, the comment period on the advanced notice of proposed rulemaking that was published in the Federal Register is open through June 1st on regulations.gov, and the docket number for that, you can find it by on regulations.gov searching CPSC window coverings, and it comes up. The docket number is CPSC-2013-0028. And I would strongly encourage anybody who has comments on the advanced notice of proposed rulemaking, the meeting today, or any other comments they have on the window covering efforts by CPSC to please submit comments into the docket through the regulations.gov website. Again, that docket is open through June 1st. And with that, I'm happy to have gone through the housekeeping and rules of the road, and we'll start. And I believe, Tom, are you going to start for us? Yes. I'm going to try to get this kicked off. And first off, the window covering manufacturing association, the technical committee, a portion of it is represented here, but this is only a portion of it. Our technical committee actually is about 25 active members. And so you have a smaller portion here. But we do appreciate the opportunity to come in and to share our knowledge of window covering products. These are products that in many cases may seem simple, but from a manufacturer's perspective, there are challenges associated with window coverings. And so we hope that that's part of our objective is to help people see that. So as we had already discussed, these are the members that are on the table from the window covering manufacturing association. And we've already done the introductions, so I'll go through this. So as we set up the agenda, these were the topics, the main topics that we wanted to discuss. And the first, of course, is to get grounded, is to understand the foundation of window coverings, just describing the market a little bit, the products, certainly, and the different types of operating systems that are available. We have some samples that we will be doing comparatives with, so corded versus cordless, so that we can see the, we can all see the complexity of the products. And then of course, we have samples of cordless designs and other products, other solutions. And then we'll have a discussion at the end around ultimate solutions, and the trends that are going on within the industry. So first, we just wanted to get grounded is, what's the primary purpose of a window covering? And what are the basic differences between blinds and shades, as they're often viewed as being one and the same. So the purpose of a window covering is to manage the light, energy, privacy within a home. And it's also a style element within the home that consumer can reflect their personal likes, dislikes, through the fashion of their, of their home. And then, of course, blinds and shades. The basic difference is that blinds are either horizontal or vertical. And they have louvers that you can traverse or you can raise and lower. In the case of a horizontal blind, you raise and lower it. And then the louvers are tilted through a second mechanism, either through quartilt or one tilt. And a vertical blind is similar in a vertical manner, the vertical louvers, you traverse the blind open closed, and then you rotate typically through a chain to rotate the louvers open and closed. Shades, on the other hand, are more common in that you have to raise and lower the shade in order to manage light, privacy, and energy is another element of that. From a historical perspective, the safety standard, national safety standard was first developed in 1996, with the cooperation of CPSC and WCMA. And you can see the years that the standards have been updated and the different items that were given focus in those standards. So dating back to the first in 1996 and our most recent in 2012. Along those same lines with the history comes product development. So the advances that have been made since the standard development had started was that there is now cordless product offerings in every product category. There's been new operating systems that limit accessibility, such as retractable cords or rigid shrouds, cord shrouds on Roman shades to prevent the access to inner cords and the loops that can be formed between the cord and the fabric itself. Hold down devices. And in some cases, more specifically locking style hold down devices that limit operation of the blind. And that's for continuous loop type products. Motorized and automated shading systems. Low volume or but small percentage of the industry. More common and commercial but rising and residential. And with each one of these options, there is a trade off around cost, application and utility. And those are some of the challenges that we're going to cover in a little bit. From a marketing consumer trends standpoint, a little further definition. So often when people think about blinds, they think of one inch vinyl horizontals. And that's what we would term in our industry as a stock type product. This is a product that you would walk into a retail center and you would buy off the shelf. So it's prepackaged. And if I'm allowed to, so this is an example of a stock type product, prepackaged on a store shelf. And in some cases, this product is what we would term grab and go, you can take it right out of the store, pay for it and go install it in your home. It can be cut down in the store. So the product is such that if this one specifically is 23 inches by 64. So if a consumer wanted this to be more custom to their window, they could have it cut down to 21 or 22 inches, not having it shortened. Does everyone understand cut down what that means and how that works? Yeah, we're clear on that. Just for my edification, please. So in the certain retail centers that would sell this, the you would approach a store clerk, tell them what your requirements are for size, and they would put the the blind they take it out of the package, put it on a machine and they would cut the headrail slats bottom rail to the width that the customer requires. And then they put it back in the box and the customer goes and pays for it. You take an equal distance off each side to keep it balanced in that regard. So if you needed two inches shorter or narrower, you'll take an inch off either side. So you have a semi custom fit for your application. And the approximate selling price of something like that just to give you a sense. Well, they range in size from this being one of the smaller ones. In the 12 to 15, and then they go up and it really depends. Some products are not intended to be cut down. And so they might be actually a lower price. And then as you start to get to 72 inch, which is usually about the maximum width, they could easily be over 30 to $35 for a vinyl blind. In addition to stock, and of course, it's stock, there's roller shades, vinyl shades as most people are familiar with. There are also vertical blinds as well that are sold at stock. And cellular type shades. From a custom standpoint, and try just trying to give some perception of cost, custom is is more expensive. And part of that is that you have so many more options available with custom, there's more colors. You could have a cellular program that might have 100 different colors and fabric styles. Whereas in the stock program, you're offered two colors, multiple sizes. And custom also has a wider range of product offerings, Roman vertical, horizontal blinds, wood, faux wood, draperies fit and custom. And so that's how we finished that point up there by saying available in both hard and soft options. So hard options are typically products like this one where it's a horizontal blind, soft would be drapes, or Roman style products that are more of the softer fabric, not not rigid products for custom window treatment buyers. So those that are going into retail centers or dealer decorators, franchise owners across the country buying custom window coverings. The most influential factor in their purchase decision is around the availability of the types of products, the trends as a color right, the fabric styles that meet with their consumer interests, their choice as far as the style within their home. And there's also features that are often related with the custom like bottom up top down, which may not be available for stock type products. Stock consumers, on the other hand, are more influenced by price and by availability. So walking into a store, their expectation is that it's going to be there available, they can buy it and they can go. So they're less concerned about color offerings and different options. Spending for window coverings is discretionary. It's not something that is done on a routine basis. And it's, it can be complex for many people. There's different categories of buyers, there's do it yourself or who have some sense of confidence in their ability to measure and install window coverings. And so they would likely go to a retail center like a Home Depot or Lowe's. There are others that they want assistance there. They may not be confident in their ability to choose trend right fabrics colors to match within their home. And so they may rely on a designer or a franchise owner that will will come in will do the measuring will will bring in books, give them show them all the options and and help them recognize what's best for their home. And so this process of buying window coverings is often tied to remodeling projects. Most people think that it has to it's more with new home purchases, but a high percent greater percent is done through remodeling. So somebody goes to paint a room or replace carpeting, they're most likely at that time to replace the window coverings as well. But with that, it only happens about every seven to 10 years for window coverings. And I skipped over the point, although I kind of made it before was the purchase of custom products is is pretty complex. And so that's generally a reason why people might not go to a retail center to purchase custom products. They may work with a designer who can help manage the process. Again, because it's something that's not done very often, they're kind of coached through the steps. Product life for custom and stock. Again, this is what often differentiates the two product categories. The target that most manufacturers build for is a 10 year life. Although the products remain in the home for 15 to 20 years, and the products themselves are generally durable and can live that life, survive through years of use. Stock products because they're viewed as an entry level type product in the marketplace. Their target for design is three to five years. And they're likely to be in the home for maybe around 10 years. It could be more just on the sorry to comment on expected life or the target. Most of the manufacturers do tests for 10 years. But the reason it remains in a home for 15 or 20 is that our typical life cycle test will do one cycle up and down per day. But most people don't actually operate their shades more than once a day or even once a day rather. So and even if it isn't functioning, it'll hang there for sometime depending on on where it is. So good. It's a good distinction to when it comes to the difference between blinds and shades. So blinds more typically are not cycled up and down or traversed on a daily basis. The louvers are typically tilted. That's usually how consumers would then manage the light and privacy within their home. Corgis options are available in every product category. So there's options that are available out there both from the entry level opening price point for stock is a vinyl roller shades have been in the marketplace and it's probably the most familiar cordless product entry level very low cost. And then of course up through motorized which would be the other end of the extreme when it comes to cost for the product and we'll talk a little bit more about that in a minute. So again just wrapping up on the different types of window coverings. Again blinds horizontal blinds often one inch two inch can be a little bit wider slat than that in wood PVC which can be embossed or printed fabric composite which is a more rigid polymer not PVC and and acrylic and vertical blinds are in that category as well and the similar style of louvers but again they hang in a vertical fashion. Shades which what's showing on there is a I believe it's a natural shade with a Roman style. And so there's all types of fabrics available shutters of course no cords very popular in the southern states draperies both traversing and cafe style as that's showing is a cafe. And then of course drapery hardware to support the drapery. So next we'd like to talk about cordless as to how do we define cordless because there there seems to be maybe I don't want to call it confusion but how we state it is is different is that does it mean no cords or does it mean no operating cords. So no cords the products that would be available under that definition is cordless vinyl roller shades as I mentioned before but on draw verticals and drapes where there are there are literally no cords whatsoever in the product. And so the products that would be impacted by defining cordless is no cords is cordless pleated cellular which has no accessible cords but cords are still used within the the inner cords running through the fabric. Roman has inner cords that are on the rear of the shade that helped to raise and lower it. Then of course horizontal blinds like pleated shades have inner cords that pass up through route holes or through ladders. If we define cordless as no accessible cords the products that are available would be products like cellular plus what's above because the inner cords on a cellular shade are not accessible and I'm going to grab a sample or two just to illustrate those points. So what I'm holding in my hand is a is a cellular cordless product. And so there are no cords front or back of the blind. There are cords that run down through the inner portion of the fabric that connect the bottom rail to the headrail. And then on the inside of the product is cordless spring motors. So a product like this has no accessible cords. What's still affected limiting the definition to no accessible cords is there's a pleated version a Roman version horizontal version today that exists but you can you can see the accessible inner cords you can touch them you can pull out. And so those products would not be within that category. So the next level to consider is no accessible inner cords that can form a hazardous loop. And so now this expands to products like pleated. I don't have a pleated cordless sample Roman horizontal where there are inner cords that you can see touch pull but they cannot create a hazardous loop. So within the safety standard there's appendix D that goes through how you you manage to grab the cord pull on it to create a loop that you would then have to force a head probe through. And if the head probe doesn't pass under certain circumstances certain forces then it would be a pass. And so the cordless products as the industry refers to them for those pleated Roman would have to pass that test. So our idea of what a cordless product a true cordless product is is it has no accessible operating cords. So in the case of a cellular shade this is a cellular shade that has a operating cord on the front. So this this is not cordless by definition because it has the operating cord. So just to add a little bit of clarification to that the operating cord would be a cord that the user would be expected to interface with operate the product and a the what inner cord is a cord that is can or cannot be accessible on the product. But the user would actually interface with the bottom rail or some other part of the product to actuate that product. So it's not intended for the user to actually physically use that cord operate the product. Another example of a cordless product this would be a vertical line. And it uses a wand control. You would have the vertical louvers would be attached to the stems. And by rotating the wand you can rotate the louvers articulate the louvers for open and closed. And then the one allows you to draw the product across. This is common in a stock type product you buy your your channel. And then you buy your you choose your louvers separately in a package. Pardon the color for this one. You can choose anything when it comes to custom. This is a horizontal an aluminum horizontal cordless. And that it has inner cords that you can see that can be pulled on. But not to create a hazardous loop that it's it's quite difficult to pull on that because the cord bites into the slats. And you just simply operate the shape by raising or lowering the bottom rail. So one of the things that as an industry that looking to understand is what's a feasible cordless alternative. These are products that that we're showing that we believe are available in all product categories. And so this could be a point of some discussion. So what's an example of a device that makes all window covering cords inaccessible is a is another question. And so the focus is based on the definitions that we've provided from the industry. Which cords are we talking about? Are we are we limiting this to the operating cords? Or are we expanding it to include inner cords? So we welcome any discussion around the table questions or no, we have more you and we have many more slides. I just was using this as an opportunity to engage a little bit. No, I'll I think we'll take it now. I didn't want to cut you off in the stream otherwise. So no thanks, Tom for coming through it. And I think this is a good place to stop because between the last slide 11 and 12. I mean, I think when we're looking at the discussion on the technologies and window coverings, focusing on the hazard, right, which is the hazard of strangulation to the young children from the cords. One thing for clarity and I was interested on the previous slide on cordless was you talk about at the bottom there no accessible operating cords as the definition. And one thing that we have pretty consistently talked with you all about is that if it's accessible that it's just not long enough to form a hazardous loop. And then when I so then on the next slide, when I was reading about clarity of either the cordless alternatives or all window covering cords inaccessible, I guess I would say and you know, Ronald will jump in also here that in terms of communicating in the past, we've talked about the window covering cords being inaccessible. But then if they are accessible, that they're just not long enough to form a hazardous loop. And so I guess I wanted to see how that fit in with what you have here. Maybe it is just semantics in terms of that's the unwritten part of what you're talking about there, or if that's something that we need to explicitly put down, because I know later on you've got different cord retractors and stuff that do exactly that, right, which which have an accessible cord, but then make it so short that it can't form a hazardous loop. Same thing with corded, the corded beaded cords, etc. for some types of roller shades where you've either got tensioning devices or something such that you can't form the hazardous loop. So I guess I would ask, how does that fit in here on between the last slide and this one? We do have in slides that are coming up, we do talk about the limited length eight inch operating cord, which is most typically associated with a retractable type device for raising and lowering the window covering. So that's sort of why we're asking this question that is again for clarity. So when we think about cordless, we don't think about that specifically as being cordless. That's that has an operating cord, as Jeff had kind of explained a little bit more that the user interfaces with that cord to raise and lower the shape. And there's different types of operating systems that follow that type of design. Hasn't this been pretty consistent since the standard has been initiated on what exactly is considered a hazardous cord, accessible cord? I think what you're asking is on the standard operating cords, this is the cord that I believe that most people are referring to. And what George has just brought up is the single cord type operating system that retracts. But there would be some questions about does that qualify as a cordless product or does that qualify within this definition in some way as an acceptable operating system? Because we have some slides that we want to share with some of the challenges. Maybe that'll maybe that'll become clear. There are requirements for that type of of device in the standard. And I just want to be clear that that we are in agreement that those are devices that that are in there to prevent to address the strangulation hazard. There are the standard does allow for retractable type devices. That's true. Had that for a while. Also, just following on George mentioned that we're interested in if the cords are too short to form a hazardous loop, but also if there's other ways that they're inaccessible to form a hazardous loop. So like you mentioned, if the inner cords can pass the probe test and not form a hazardous loop, again, I think we're interested in addressing the hazard. So if you have solutions that prevent the formation of a hazardous loop, that's what we want to right here. And I mean, seeking clarity, inner cords have been a known strangulation hazard and to the credit of the voluntary standard has addressed it. So I mean, there's no there's no fuzz on that. The clarity is that we don't want inner cords to be accessible. No, in place on misunderstand what this was intended to do was it was more focused around the operating cord versus the inner cord as to how narrow is cordless intended to you know, be the definition. I guess I just wanted to emphasize that cordless is not the only goal. And our goal is not to define the technology, but rather whether the appropriate performance requirements are incorporated to ensure that there is no hazardous loop or cord. That's understood. Just a point when, again, on inner cords. So the early standard sought to eliminate the risk of a freestanding lift which came from an inner cord if the inner cord was pulled out and that was the donut that was added to the outside of the cord lock on the operating cord. When the development for the hazardous loop was was put into the standard products had to be designed in order that you couldn't create that that hazardous loop even that we don't refer to that as a freestanding loop. That's more of a dynamic loop. But the product itself required some additional weight or some design changes in the product in order to be more resistant for that ability for the for the inner cord to pull out. And so that's that's not something that I think people recognize that that was a change, but that was a requirement as a product because some products wouldn't have passed that new test had we not redesigned product. So examples of cordless products which I've shown a couple here, but just to kind of expand on that a little bit is in the marketplace today there's cordless products and horizontals wood, faux wood, vinyl and we're talking about one inch, two inch, which is the width of the louver verticals of course as I showed an example of that as well. Shade, cellular pleated Roman, both natural materials and fabrics and roller shades which is people are very familiar with and the roller shade industry has grown significantly to include solar roller now into the residential area. And of course drapes, soft treatments both traverse, well not not traverse in this case, non traversing type products. Next area that we wanted to go to was to talk about some of the challenges that we we have with cordless and as we work down through this list, we're going to talk a little bit about the differences between a corded and a cordless product. So in the case that the first challenge of course is cost, the cordless mechanism is much more complex than a standard corded. And just as a sample, what I've got in my hand and I'll pass these around or just a simple cord box, each product that would have a cord operating system, an operating cord would have some type of a locking device that allows you to raise and lower and hold the product at any level. And so as you as you pass that around, you can just get an idea of the small simplicity of the cord lock. So I'll talk through the rest of the points on here is that's going around. So with a cordless mechanism, which is more complex, many more components to it, there's a higher labor cost, higher material cost to to make the product. Impact on stock is even more. So imagine that with a custom product, as you think about a percent, it can be for custom 20 to 40 percent or more of the cost of the blind is the cordless components labor, the cordless element. On stock, that's actually quite a bit higher because you're you're looking at an opening price point. And so the the percent cost for a cordless mechanism can be 40 to 60 percent of the product cost, total product cost. And an additional to just the labor and the cost of the material, there's also life cycle cost. So developing a cordless mechanism or a motorized system is far more capital intensive. There's many more components and there's more R&D that goes into developing and validating that type of product. The tooling, of course, I mentioned, there is longer term warranty costs associated with it. The more complex the system you have, the more risk there is of things going wrong. And then, of course, the inventory, you're you're inventorying many more parts. And so all these all these carrying costs are part of the cordless design. Consumers, when they choose cordless, cordless option is available, as I mentioned, in all product categories. So it's readily available, but consumers don't always choose cordless. It really depends on the type of product. So when I mentioned take rate, that's as an option, how often does a consumer choose cordless? And it really it's a it varies quite a bit from as little as 1% on commodity or horizontal blinds, which is again, they may not raise and lower the blind. Because they're more apt to tilt, rotate the louvers to manage light privacy energy. On the other hand, cellular shades, roller shades, that the rate of them choosing the cordless option is higher. 50% and sometimes even greater than that. I've seen some products as high as 60% for cordless. But that's again, with a shade, they're going to operate it probably on a daily basis, maybe even more often than that if they're concerned about energy that they might have the shade down during the day in order to prevent the room from warming up. Another challenge is based on the height. Generally, the maximum height with cordless products is 78 to 86 inches. And that's limited for two reasons. One, a high percentage of the of the blinds are in that range that are sold for most windows. You start getting over 86 and consumers would have trouble, you know, reaching the shade to pull it down or to push it up. There's also constraints within the headrail. So in the case this being a stock product, the cordless mechanism fits within the envelope of the headrail that is here. But you could imagine that if you wanted this to go 12 feet, for instance, the spring motor, the winding mechanism would be enlarged. And so for that you'd have to have a larger headrail. And that would be a small, very small percent of the of the population of product. And so it would be a very capital intensive to have to expand that for the very few consumers that would take cordless at that size. And then there's width restrictions as well. The next point around the cordless mechanism is that it's really about balance. So you're taking different fabrics or materials, rigid materials. You have the weight of those products. You have a spring mechanism that is the torque to wind up the cords. You rely on friction. Every place that cords pass is additive to the system and how it functions. And in the case of some fabrics like cellular fabrics, if you have a room darkening fabric, it's very stiff. And so you have to counterbalance that with additional weight in the bottom rail. And so all of this is really about balance. And so I'm going to step back up to the width. So when you look at the narrow width and side lights on either side of doors or just narrow windows, there's going to be limitations that you can accomplish in a corded product that you can accomplish in a cordless because you cannot get all the components into the narrow width that's required for that type of product. And so often that a challenge becomes very narrow, tall shades or very wide. When I say wide, I'm talking about 12 feet. It can be 12 feet wide on width, but then it can be an issue with the height of the shade. Tom, if I may, I'd like to add two points. One is, as you talk about having a very narrow shade as a side light, consumers typically want to have the same head rail system throughout the room. So if we see that we can't accommodate that narrow shade next to the window, next to the door in the side light because it's too narrow to work with a cordless solution, they typically don't want a cordless solution throughout the rest of the room because they want it to match. So in many situations, if we can't accommodate one shade with the system, we end up going with a different solution for the entire room. The other point I'd like to make is as you talk about the cordless mechanical systems, it's all about counterbalance, friction, weight. Realize that when you first build a product, the friction in that product is different than the friction is in that product after it's been installed in the window for several years. So that's where the warranty aspect comes into play. A consumer gets a product when it's first built, it's perfectly balanced, it functions properly. And then after a few years, that shade starts to drop because the friction in the system has reduced. The other aspect to that is when you have to perfectly counterbalance the weight of the fabric, it does take more fabrication time because we have to determine exactly what fabric is being used, what bottom rail is being used. And we primarily operate with the custom window covering. So for every shade that you produce, it's a different weight and a different counterbalance that we need to accommodate. Just to broaden the comment on friction, don't forget to the movements and temperature so you can get 120, 130 degrees next to the window and you've got a lot of plastic, metal, aluminum components that expand and contract at different rates and then it can drop into the low 40s. So the materials have to interact in a way that functions time after time, year after year and there will be some give and change in, in tolerancing over those years. It's just I guess a question for you all looking at some of these bullets. Based on your market research, what percentage of homes have windows greater than 86 inches or 78 inches high such that, that physical constraint would be an issue for that home? I, you know, I don't know that I know the exact answer for that. Certainly a high percent are within that. I'd say that the average window covering is about 36 by 60 I think is generally where I, I see them when I'm asking for data on window size. But average is a tough one because you're, you're looking at a grid of sizes that usually say on a pricing grid it tends to move about every six inches and it'll go from say 12 inches all the way to 144 inches. And so when you're talking an average, if you're, if you're plotting it, it's a line very flat along the bottom and just a tiny little blip in that, in that little range. That's correct. Okay. So the averages are very dangerous. All right. Because you've got a lot of big ones and a lot of little ones and they average out to 36 inches. Okay. I have a slide a little bit later on that, that explains a little bit about how volume of windows fits into that. Okay. Because I was just trying to get a sense for, I mean I can appreciate the challenges once the window covering is greater than 78 inches high or in side lights. And so my follow on question would be understanding that some houses may try and make everything consistent. What percent of houses looking at residential specifically have side lights where they're trying to put window coverings in? Because I'm just trying to get a sense of what portion of the market is affected by these, you know, constraints. It's also really regional. I mean in the northeast where we're located you don't have side lights often. But in Atlanta and the south you've got side lights on almost every door. So it's, and it depends on, you know, time when the home was built. More modern homes have much bigger windows. But the predominant stock that's in the market would be older homes for obvious reasons, since you're only building maybe a million new ones a year to a hundred million existing homes. So it's, you can talk averages, but you've got to remember it's very regional. It's time specific for when they get out there the homes. Yeah, I was just wondering if there is a scope for the sizes of the consumer grade window coverings versus the residential window coverings? Like, was there a size dimension? Not sure I understand it. Comparing residential to the industrial or commercial? Yeah, commercial. Yeah. Certainly I think people think of commercial as being large windows. And certainly in the commercial industry when we sell blinds or shades into that, we can sell very large window coverings. But keep in mind that what's the definition of a commercial business? Because residential homes or apartments are also viewed from our perspective as commercial. So if somebody goes in and they might be outfitting a large complex with window coverings, that actually passes through our commercial division. And so that's really no different than a residential type size. The commercial requirements too are a little bit different than residential in terms of the types of products that they take. And so I mentioned earlier too about solar type shades. That is taking, replacing a lot of horizontal blinds in the commercial markets. And we're seeing in residential that that's growing in that area as well. Another point that with the question that was asked about the size of windows and whether or not cordless would fit into that grouping. And again, we'll talk about this again in a couple of minutes in another couple of slides. But it's important to recognize that there are restricted applications for consumers. So there can be larger windows or there can be furniture that you can look at a living room seen in a large window. The couch is either going to be placed in front of the window or looking out the window. And so there can be situations where tables can block where you would have access to the window covering. And so cordless may not be the right solution for that homeowner as far as how they want to raise and lower. And then there's user limits too. Again, this isn't intended to be the challenge that prevents us from doing cordless. We're doing cordless. But from a consumer choice, there are people that age or height, they're going to have some restrictions even to the eight inch device that we're going to talk about. And they may have dexterity issues as well. Tom, in terms of just the horizontal blind perspective, do you face the challenges more or less, depending on the type of the horizontal blind, metal vinyl versus faux wood or wood? That's actually a good question. Aluminum blinds, when it comes to balancing a cordless system, is different because of the materials versus a wood or faux wood. Faux wood is extremely heavy PVC. And so the limitations there are very different than they would be on a wood product, which is lighter. But again, wood where large windows can take a wood blind multiple on a heather rail. What just happened there? Yeah. Need a password. You have to yell it. Tom, if I may chime in also on that question, there is a difference between how you counterbalance a lift product or a horizontal product versus a roller product. For instance, when you have a lift product, as that shade raises, the weight actually increases because you're taking the load of that shade. So when we developed a cordless solution, we had to also develop a transmission that accounts for the load difference at the bottom of the shade versus at the top of the shade for horizontal products. In a roller shade product, the weight actually decreases as you roll up the fabric because part of the fabric is on the tube. So that creates different challenges. And those transmissions need to be different depending on which fabric or the weight of the product as it begins because your ratio is changing. Motorize is another category of cordless, which is certainly more expensive. In many cases, it can be cost prohibitive to the average consumer in that the cost can be two to three times the cost of the custom product. Another deterrent is just user experience. People imagine that somebody is already concerned about just the investment and making all the choices associated with custom window coverings and then to add the complexity of motorization, home automation into that. Not just from the consumer's perspective, but even from the people that are selling the products. It takes a lot of training to prepare people to sell well with the home automation, the motorized type products. There's lots of different options and considerations that people have to think about in those terms. So this becomes a limiting factor when it comes to the take rate, how often people choose it. Commercial tends to be a little bit higher take rate than residential, but it is growing. Right now, it's pretty limited at about 1%. It really depends on the type of product and how the business is selling and the markets that they're selling into. The technology is advancing, though, and the less expensive alternatives are entering the market. Sorry, Tom, if I may. When you're talking about cordless is, or I'm sorry, motorized, is motorized really to address on the previous slide some of the user issues with respect to accessibility, height, reach, et cetera. I mean, in other words, motorized isn't a different way you're trying to address the hazard, what you're trying to, is motorized then mainly to make it more user friendly? In a sense, that would be very true in that motorized can pick up where cordless, you know, in terms of size, widths and heights. And it can overcome some of the other issues around restricted applications. So being able to access product, maybe it's really high up and that's the only way you're going to sell that product is to make it motorized. But I think motorized is also being looked at as a alternative operating solution, not utilizing it for automation, but utilizing it as an operator to raise and lower a product. But right now, the cost with motors is very expensive, but as technology changes with motor development, I think there may be an opportunity to use motorized strictly for a safety solution as opposed to an automation solution because you could trim some of the cost out if you start to take away some of the controls, some of the infrared radio frequency and really expect the consumer to go to the window covering and operate a baton to activate the motor to raise and lower because that does satisfy some of the challenges, I should say, that we have with cordless solutions. Just to give you a visual, Joe referred to a wand. Most people, when they think about a motorized system, will think about a remote control unit or there'll be a panel on the wall that'll have presets on there or maybe it interacts with the sun and raises and lowers based on that or wind if it's on the outside of a window. But in order to really simplify a motor and to drive down costs and to make it really just simply, very simple for the consumer to interact with, this is the type of wand. I mean, they can come in any shape that you want, but basically you're dealing with an up and a down switch. You can recharge it very simply. You recharge it really like you would a phone. So most people nowadays are used to recharging cellular phones. That used to be a big hurdle how to recharge batteries. This is battery operated. So this tiny little motor you're looking at here can raise and lower a 10 foot by 10 foot shade, roller shade, for example. This just slides into a tube. You know, it's covered and the fabric's on the outside of it. So this is still quite a bit more expensive than the manual systems, but it's dramatically lower than some of the existing systems that are out there that are definitely not DIY products. This would be a DIY product. Derek just showed you a motor that fits into a tube. And this is a motor assembly that fits into one of our products that we produce today. And this one happens to work off of infrared and radio frequency. So it's a bit more expensive, but we're looking at is there options to reduce the cost of units like this to satisfy the need. Was that previous product? Is that a prototype or is that available? That particular one is a prototype that we're working on, but there are products to a limited degree available on the market right now that are starting to make their way out there. It's a natural consequence. Following on the wand concept, in terms of the user accessibility on the cordless, is that something you're looking at as well having just a wand to help with, you know, for the taller window or something like that? Yeah, again, it's really user acceptance because if you have a cordless product and you have a wand attached to the bottom rail, where does that wand go when it comes down into the sill? So is a consumer willing to reach over a couch, for instance, pull the rail out and if that wand were to flip into the bottom rail, for instance, to come down so you could raise it all the way up, would they be willing to accept that as an operation? And those are some things that we continually focus group and try to, just because you can do or come up with a solution, if the consumers aren't going to accept that solution, it may not make sense to develop that type of solution. Sure. On the user acceptance, I was encouraged by the comment, though, that you're seeing greater use of the cordless in the blinds where they're operated more, or in the shades, rather, where they're operated more than in the blinds where they're operated less. Do you see that inclination to acceptance to this product in an application where people actually have to interact with it commonly might lend itself to some of these answers? I think the answer is yes. When we first introduced our cordless products over a decade ago, the focus groups that we did to find out about the acceptance of cordless, safety wasn't in the top five, which surprised us, because we thought that'd be the first place that people went. It was more about no unsightly cords. And so when we started selling the product, the take rate, as I've referred to, was in the 10%, 11%. And we've seen it grow since that time. The last year on a particular cellular product, we saw take rates of 64%, which means that 64% of the time they chose the cordless option for that product, which is fantastic. So the next two slides, I just want to use to illustrate the apparent complexity between corded and cordless. So the corded product is on the right, and that's very similar to the corded product that I'm showing that I've got in my hand. The cord lock is up there, a little hard to read the numbers, I think it's number five. So on the right, the little bubbles with the parts are identified. Those are the parts that are most specifically related to a corded product. And you can see there's about five or seven items on the right side. On the left side is a cordless product, cellular. And again, the bubbles that are related to the cordless mechanism are highlighted in yellow. And you can see that there's many more. And even the rail, the head rail, the bottom rail components are marked because we have to have a different profile in order to larger envelope for the head rail in order to accommodate the spring motors, drive shafts, spooling mechanisms. There's many more components associated with that. And as I go to the next slide, this is just the bill of material for those two. Again, cordless on the left, corded on the right. And the parts themselves that are on the right are typically smaller components, lower value than the parts that are on the left. And there's some assembly parts, sub-assembly parts that are on the left when it comes to building the cordless spring motors as well. And then we have some storyboards that we can kind of walk through too that explain that. Yeah, please. I don't have a count on the number of fabric styles, but with the different spring motors, that's how we can accommodate different fabric types. So we have to look at what the weight of the fabric is, what the width of the shade is, what hardware system are we using, what bottom rail do we have on the product. And then in fabrication, the fabricators have to look at a chart and decide, okay, for this shade we need one of the black spring motors in conjunction with one of the gray spring motors, along with one of the green transmissions to actually build the shade. And there is situations where you may have three or four different spring motors to actually build a shade. As you start to add components, obviously the width of the product gets much wider and thus we can't go and produce those shades that are very narrow. For styles, and we have probably different thicknesses, and then the arrangement has to happen. We have to put that into our, well, thank you. We have to put that into our computerized system so that it'll generate a spreadsheet. This for horizontal for honeycomb shades, we took that same technology and moved it into horizontals, which is a blind. As Tom was mentioning, the blinds are very heavy. The metal blinds are a little lighter than the wood blinds and full woods are heavier yet. Again, we've got a modular spring setup. As you can see, the spring units got a lot bigger. All the components had to change. All the tooling had to change so that we could accommodate this whole product blind and then this product blind. Our transmissions, as you see, here's a constant force spring if you wanna look at it. The transmissions are all zinc diecasts and they had to get a lot larger too to handle the weight. And it's got the same drive shaft and spool mechanism that we use here to carry the inner cords. And that's just two of our products. So you can see later on. Thank you. It felt like a rock star. Yes. We have a silhouette product and that has, it's a shading and not only does it have to go up and down but it tilts also with a different mechanism. So we developed a spring unit that when it gets down to the bottom, there's, it's got a spring here because it's on a roller tube so that there's higher weight at the bottom than at the top. So we changed our spring from a constant force spring to an extension spring, but this one is a coil spring and we drive it along a screw. And at the very bottom, we've got a locking device so that as we tilt, we're able to maintain that tilt function. So we've got a lot of other mechanisms there that disengage the spring at the bottom in order to be able to do our tilting. So this was an entire new design to have silhouette be light rise and eliminate operating cords. And with this product, we also have to change the spring based on the width of the product. As you can see, the one that's outside of the product mounted to the board is about five inches in length but the ones that's actually in the shade for this side product is double that. And this is just a sampling. I've got different lengths here but we have six different springs to choose from based on product size. You can see how this would limit our width, minimum width shape. So these samples that you're showing, these are typical, are they very high end product? Yes, these are high end products. We've got a product that's vignette. It's a soft Roman shaped style product. And initially we did a roller version so that it rolls up on a tube. We've got a tubular shaped mechanism here. People like the fact that it's a soft rise as it goes. So we've got a governor mechanism on here. It's a planetary gearbox that has throw out weights so that it slows down the speed as it raises up. It's good for consumers. Constant force spring and a latching mechanism. And we don't have an exploded view of that latching mechanism but I think it has about 12 parts inside. So those all have to be preassembled. Those are preassembled and like these ones, this is a black spring on here but we've got four different other springs that we can put on for various sized shades. Got a limit stop here so that people don't overextend the springs. So it just shows some of the complexity. Bottom rail handle, that's the extra part. And then these, as you pull the shade down, if the roller tube stays in one location, you get a big gap up top so that what we've done is allow that to pivot back in closer to the window for light control in privacy. Because if you have a blackout shade, people don't want that light leaking around the side. Then when they went to a horizontal for that soft product so that it stacks like the honeycomb product, then we had to go back to the stacking springs, across the four springs and transmissions. These ones we use the same spools but we use this limit stop device so that we don't overextend it. The last one is, yeah, the last one just to make a point is we've got six different spring units, breaking units, and it's a balancing act when you're going up or down so that you can balance all the different, I think we have 135 SKUs of material. Thank you, Jim. So we just went through quite a few different samples and I had showed my samples earlier. I think I have just one more. As cordless has become a more popular, one of the options within cordless is bottom up top down as another option and so you're actually gonna have, you can hold on to this blind and just feel the weight that's in this blind but this is, so you have a bottom rail, you can have it, the fabric so that you can manage light and privacy and then there's a mid rail that comes down that has magnet touches to make sure that it stays up so that the consumer can still maintain privacy. These are all, so there's a double, this actually has a double cordless mechanism in the head rail because each rail system has to operate on its own independent system. And so knowing that this is just a very small blind, I thought just hold on to that and you can feel the weight so it has additional weights inside to manage the forces required to balance that shape. And then the other, actually I think is, I'll save this one, this is a single cord retractable system, I'll save it when we talk more about single cords. For the top down, bottom up, cellular shade, is it possible to get a single lift cord for each of the exposed cords instead of two per side? Because one set of cords operates the bottom rail, one set of cords operates the mid rail. So you have to have two in there. The point was, I didn't bring a screwdriver in but I think I can get it off. So the system that's in there, I mean I can explain it a little bit right here. So in here we have two spring motors, one operates the mid rail, one operates the bottom rail, and then there's a double set of spools. So having a front and a back spool, one spool is winding the inner cord for the bottom rail, one spool is winding the inner cord for the head rail. Rather simple system. So the question was brought up before about the size of windows that are being sold into. And so this is just looking at a cellular product and the range, the total range that's available. So if you think about this in terms of the width from minimum to maximum and the height from a min to a max, the green, so the entire area that's yellow is the shades that we produce. So from our minimum and max sizes. So you can get anything within that yellow area of shades. The motorized and continuous loop are limited in terms of width but they can go to the maximum height. And then cordless, which is the green shaded area that's subset in the upper left hand corner, that's the range, the width and height range for the cordless. Now the black line that's on there to the left is within that area from there up to the minimum numbers is 90% of the products that we ship are in that range of terms of height and width. The dotted line is 95%. So think of in the opposite terms of that of 5% of the product is sold from the dotted lines out. Now looking at that, certainly one could assume then that well you can do cordless already and it's true but keep in mind that not all consumers choose cordless. That there is applications, utility, there's different reasons why they would prefer to have corded or continuous loop or motorized for their application and for their products. So this last weekend, if you opened up the newspaper you would have seen lots and lots of advertisements for sales, for cars, window coverings and a lot of those are promotions for free cordless upgrades. And consumers don't always even take advantage of the free cordless upgrade. So as Tom said, it's not a cost issue alone. It's utility application. So on this Tom, 90% of shades shipped both the residential and commercial. Is that, or is that strictly one or the other? This would be all inclusive. All inclusive, okay. But just cellular doesn't sell a lot into commercial. If this was looking at roller shades there'd be a higher percent of commercial within that category or verticals or horizontals. But cellular just simply isn't sold in the commercial area like the other category so. Thanks. Yes. Now switching to talk about the eight inch single cord system and for the longest time this was always seven and three quarters of an inch. So at least we've rounded to eight inches. So the CPSC has proposed limiting the cord length to maximum of eight which is what was brought up earlier. And it's intended to be to our understand regardless of the blind shade height and throughout all phases of operation. So just for reference sake this product that I'm holding right now is a retractable cord system. It's a single pull to get the shade to drop. So by gravity it rolls down and then you pump to raise it. Now you can see that I although my cord here length is relatively short in order to pull the shade I have to pull the cord out in order to get it to ratchet up. But when he's pulling it out it's always under tension so it's not hanging loose. But it's very awkward obviously just to pull eight inches. So in thinking about if it's intended to be that it's eight inches regardless of the blind shade blind or shade height. If the cord length was set at four inches and allowed a pull length of four inches to get to your eight consumer would have to pull and retract approximately 30 times to raise or lower a shade through 60 inches. So that requires the consumer to actually stand at the window for 30 seconds which is a strong deterrent to operating a shade with that short a pull cycle. Certainly if you're able to pull out more cord as I did when I operated that shade I doubled or tripled the length of the cord that allows the shade to go up at a faster rate or in some cases the design is you pull and retract to go down, pull and retract to go up. Some are single pull to go up and you cycle to go down. There's all different types of designs. But Tom wouldn't that time actually go up if you had a very heavy shade and you had to put a gear ratio in your mechanism to reduce the pull force required by the consumer. You now may be at the window for a minute because you may have a two to one ratio or three to one ratio built into the gearbox. It also depends on the size of the spool that you have and many of the spools to try to accommodate the smaller head rail that the consumers want we try to use as small of a spool as we can which would further create more problems with the consumer at the window. Which is similar to the continuous loop style with systems which rely on a clutch. And on small shades you can usually get away with a low gear ratio but on large shades it could be five to one, six to one, 10 to one. And so that means for every inch that you try to raise you have to move the operating cord 10 inches. And so the consumer then is committed to standing there for a long period of time to raise or lower their shade. When it comes to the operating cord length of eight inches there are some user limits that should be considered. Age, height, reach, dexterity, these are all situations that or circumstances that can cause the limited length of eight inches to be out of accessibility. And then of course there's applications so it can be furniture or counters that can further restrict that. It's 1120, we wanna show the video? Okay, not sure how that'll work on here. What's that? Oh, oh, we can just show the video. Okay, so it's not length through here. I don't think we can get there. Oops. That could, oh. All right, so we'll have to, why don't you show the product? We've got four inches of accessible cord here and we've shortened our cord stroke up inside the head right on two four inches. So the point on this is that this is, for instance, that first bullet point up there is that if eight inches was the absolute limit that you can't go more than a total of eight then you only allow for about a four inch pull and it's gonna be extremely difficult for somebody to reach to that height. Couldn't you use sort of like a straw and a rod that way it lowers the accessible cord? I think we're just to be clear, we're certainly interested in operability where while it's under tension under the user's use that the length could extend beyond eight inches but that when retracted there would be no freestanding eight inch length that would pose a strangulation hazard. I don't think we envision that while in use by the consumer that anyone would be strangled. Right, and as the author of the letter that had the eight inch in there that I'll clarify from August, and to take a step back, when we're talking about the eight inch length I wanna make sure we come back to the bigger picture of what we're trying to address. And just to get a check that maybe head nods are fine, I mean the hazard we're trying to address is the strangulation of young children in window coverings, is that correct? Okay, so in addressing the strangulation of young children in window coverings, what we were talking about was how do we keep either the operating cords from being accessible which has been a lot of the discussion so far today, or if there's an accessible cord, how do we keep it from forming in a hazardous loop? And the eight inch length came from the maximum length such that you're not forming the hazardous loop either circumference over the head or wrap around the neck. So that was the context for it just so we don't lose that. And to clarify in the phase of operation it wasn't meant while you're actively pulling on it, what it meant was that at any position of the bottom rail, at any position of the rails for the window covering that then the, if you will, standing length of the cord was no more than eight inches. So you're saying in a static state. Exactly, in a static state. The phase of operation meant that it wasn't just measured when the window shade was fully extended or fully retracted. It had to be at all different lengths between the minimum and the maximum. So in terms of the slide I'm really glad you brought this up because I just wanted to make sure that we clarified that because if that's been a real area of concern we want to make sure that's clarified and also put the eight inches in context as to why we were talking about the eight inches and bringing it back to if it's an accessible cord, one that just can't form a hazardous loop. Thank you. I think that was really important for us because there were obvious as you saw limitations there. Just to give you another visual then based on what you're saying, Tom had a system there that was is single cord but the cord is loose. And so this is the same general idea. You can just go in the other direction and I'll explain why in a second. So here you've got the cord inside of a wand or attached to a wand up here. And as he said, you can do, you can go one of two directions you can use gravity and release a break of some sort that lets it drop and then ratchet it up. Yeah, or you can maybe go this direction where what I'm doing, see how long that is. So we figure a user needs at least 18 inches of pull for it to be field normal. I mean, otherwise it's just a very unnatural action. So you've got almost 24 inches here but it's under a lot of pressure and as soon as you let go, it snaps up. And then what I'm doing is as I'm operating that I'm actually doing exactly what I think a prior sample showed, which is a spring roller system, the old fashioned spring roller with some modern twist to it and all you're really doing is loading a spring that then allows it to raise on its own and you can pull on it like that and operate it like an old fashioned product or you can if it's, if there's a curtain say on the side or you've got the couch or a lamp there you can operate it at an angle like this. So you're not so restricted anymore and you can use this to release. So directionally, this is something say our company is very excited about but an issue obviously is we don't. We can't limit it to eight inches. So I think that's been cleared up. Derek, if you could continue to show that sample. Now, one of the challenges with this product is from a child safety standpoint, it's a good solution but it won't fit every application because the amount of edge gap that he has from the edge of the shade to the mount. So if you envision that shade as being a room darkening product that you want to put into a bedroom, one of the major problems that we hear from consumers is light leakage around the edge of the fabric. So when you start to put wands on products and it's right in line with the edge of the fabric those consumers are not gonna buy that product for that installation. This product is similar in that you can see that the edge gap to my left side is pretty minor and you've got over almost three quarters of an inch on the right side and that's a detractor for this product from the consumer's perspective because it doesn't fill the window. So the engineering challenge for us, I know it seems like it's not a big deal but just trying to get a 16th of an inch out of this because it's a 16th of an inch times feet, not just a little bit. And then if it's in a room it's a 16th of an inch times as much as say 40 or 50 feet of sidewall where the window is. So it all adds up and it really matters and the consumer's not interested and they don't like asymmetrical products to begin with. Over here you've got virtually no light gap and over here this one has a smaller light gap than that which will matter but it's still very noticeable so you will get leakage coming in. And so we sell channels that you can use say to stop the light leakage but then now you're adding cost and complexity to the product. Just doing a quick time check, it is 1130 so we have about 30 minutes left on our schedule. And I don't think we're gonna turn off the lights at noon so as much time as we need to go. All right so furthering with the cord length, the eight inches even if you had the device that was at eight inches a challenge for certain consumers could be that it actually exceeds the height that they're reaching. So there's where the question about the wand comes into play that without having such a device it puts it out of reach. And just doing a comparative so the two bodies to the left are 95 percentile male and 5 percentile female. So anthropometric studies, this is the range or the scope of who the users are so you're covering the from the largest to the smallest in the population the majority of the population. And so the female 5 percentile is short in her reach and her force that she can manage when raising lowering shades as shown there on the right. Little difficult to see the values but her maximum height reach is about 63 inches. And then you complicate that with an application where she's gotta be able to reach over a sink or a counter and that reduces to 57 inches. So these are the types of things that is engineers we have to take into consideration when it comes to designing products. Because the marketing side of our business is gonna wanna sell to the maximum number of people and engineering has to then develop products that can meet the requirements of those populations. Single court operating systems we just walk through those so we can go beyond this. So now just switching to industry direction and trends. So the businesses around the table and throughout the industry and not just here in the United States but into those countries where they're producing products they're shipping into this country. The real focus for the past number of years has been on how do we reduce cost? How do we increase product sizes to meet the requirements of consumers? How do we increase reliability and durability? And the standards has reflected that with the most recent 2012 hold down devices were not new to the standard but making sure that they were durable was added to the standard. Now increasing options for cordless and motorized and single retractable so a lot of the products that we've shown you today cordless you may view that and say well that's been around a long time but in order to expand it so there are limits to the widths and the heights that we've talked about every business is looking at how do we push this further go bigger and how do we manage the cost around all those different components to make it more affordable? Increase stock product options so we know through the public announcements that IKEA and Target are going with cordless style products very similar to what you see here so a cellular type of cordless product and so showing stock in certain retail centers is relatively easy to do because they're limited to what they're gonna put on the floor but when you think about custom products there's a much broader array of the product offering that has to be managed in cordless. Certainly increasing consumer awareness is another area continuing to try to train all the way down to the person that's selling the blind to qualify the customers that it's understood what's the best product for them in their home and continued commitment on cord safety is you're seeing not just from again those that are around the table but from others within the industry looking at different ways how do we cover cords, how do we limit accessibility, the retractable cord systems. I can honestly say that it's a month doesn't go by that I don't get calls from people not that are normally within our industry that are trying to solve the problems with cords and traveling too looking at other manufacturers or designers in other countries and coming up with bright and innovative ideas as to how do they limit accessibility or develop cordless or retractable cord systems. Any comments from anybody else around the table on innovation, industry direction? Yeah, I think certainly we're in the same situation as you and we're reviewing that on a continual basis we're evaluating products across the globe and certainly we put a great deal of effort internally into that as well. So just to second that. Yeah, and I agree. We also are working with our counterparts internationally. We have international summits where we get together and talk about what's going on throughout the rest of the world regarding child safety and consumer safety and how can we combine some of those efforts and continue to move this forward as quickly as we possibly can. Our company is a little different than my other colleagues around the table. We're an engineering company that makes components that are used in operating systems sometimes by the folks around this table but by thousands of other customers around the world and so a lot of our development efforts are going to be driven by what this customer base wants and I can tell you that 18 years ago when I started with Rowley's the standard was just being talked about a bit but no one was interested in safe products. 10 years ago no one was interested in safe products even though they were talking about it a little bit more but that world's changed pretty dramatically and it's not limited to the United States. That's I can say it's in full swing in virtually every part of the world where we sell. So it's a strategic theme for our company and has been for a number of years. So furthering the discussion around limiting accessibility I brought a rigid cord shroud with us that is available commercially now. It's not manufactured by our business. I'm not sure if you've had an opportunity to work with it at all but I brought a sample I had some extras so I brought one for the lab to go ahead and use and one of our blinds and I was hoping I could show it but the product when you buy it doesn't come such that it fits our product as I found out when I got it so I can't actually mount it. It's all strung up. So unfortunately I can't operate the shape because what's supposed to happen is that this device so the cord is in this tube and so this would connect to the headrail and there's a kit that connects it but it's not sold that way. You have to get the mounting kit and our headrail is a little bit different so it doesn't just slide on but the intent here is that you have a there's a cover that goes up and down in a block and tackle type system that you use to raise and lower the shape. So not being able to mount this it doesn't do me a lot of good to be able to try and show how it operates but you pull on this to get it to raise and lower and disconnect from the cord lock. Is that a commercially available add-on or is that a prototype that was? No that's commercially available and that's why I've got the box there so it purchased a number of them so that's why I'll, it's okay I'll just leave it. Sure is there something similar that your company provides or? Well we had many years ago we had actually invented something that was similar along those lines but you're very limited in terms of the height of the product because of the way that you're cording at that point and so it's a solution that has a very limited application in terms of blind size and it can be a challenge to raise and lower the shape as a result of it because of the system, the cording system that results between the friction and the block and tackle type system it actually requires more force to raise and lower so it becomes a little bit cumbersome. That's why I leave it with the lab and they're free to use it. Yeah to Tom's point it's got a block and tackle system that's a four to one ratio I believe on that model. So if you have a shade that would typically take 10 pounds to lift, it's now gonna take 40 pounds to pull it up. I think we're familiar with the system. You are, okay. I didn't know if you, okay. But I appreciate that. I'm getting a sort of overall theme that some of the stumbling blocks in developing safer blinds to address the strangulation hazard is that you can't apply it across the board throughout your entire product lines. Is that the feeling I'm getting? Is that what you're trying to tell us? I don't think you're gonna have a single solution that's gonna work across the board. I think that the consumers needs are different. I think their utility is different. Some people have different strengths. Some people have different grip strings. Some people couches and things like this. So I don't think you're gonna have a single solution. So what we're looking at is how can we create products that are safe that satisfy the consumers needs whether it be a motorization solution in one application whether it be a cord restraining device for an elderly person that likes the use of a loop cord, an ultra-glide solution for that consumer that that fits. Is that your question? I think it, yeah, it helps. But from, thank you for showing all the samples and all the products. I admit I haven't seen them all. And I started 18 years ago too on the original standard and I, and it seems like your engineers are capable and imaginative enough to address the strangulation issue. Would that be true that it's not that really that it can't be done. The design and engineering is out there and it can be done. Is that what I'm seeing today? I think, well, as Tom said, there's a cordless option for every product category that is sold in the industry. And that's kind of the point that as I showed you in that one graph and I'll go back to it again. So again, this is just looking at cellular. You could do a similar chart for roller and verticals and all the different product categories. We can make cordless. We make cordless today for a high percentage of the window coverings. But there are many things that consumers choose because of applications or because of reach or because of any number of things that they choose not to have cordless because of the application. In custom window coverings versus stock. Again, going into a store, there's gonna be limited options what a consumer would choose and they're looking for low cost. I mean, that's their primary motivation going into a retail center to buy a blind that's already assembled. And so having discrete sizes premade works well there. But when you think about custom, custom is a much broader category and it's infinite isn't the right word because that's really unfair, but it feels when you've got five or 6,000 discrete SKUs just for fabrics and operating systems and the componentry that goes in there and the colors that are required because it all needs to be color coordinated. This just tends to grow. And keep in mind too that consumers buy window coverings for custom, primarily because of their thinking about a room scene. They've got furniture, carpet, however they're trying to show or display their unique design sense within that room. And so that's why they turn to custom and that's what they're looking for is those types of options first. Just to give a perspective though, isn't it true that about 20 or 21% of the products sold are custom in the United States? In units. In units. Yes. Yes, that is true. Which is, oh there's the box. So that's a vinyl blind, so that's a high volume type of product that you'll find. And you can find those as cordless as well. I just didn't have a sample that I could get my fingers on before I left. I also had one more question about the single retractable cords. Do you have size, weight, limitations for that technology? Yes, yeah, there are limitations to sizes. I don't have those on a slide to show. But it probably wouldn't be all that different from what you're showing there. I mean a single cord retractable system would cover the 90 to 95% of that grid. Yes. The last thing we wanted to touch on briefly was just a recent press release on the Best for Kids initiative. And the purpose of this was intended to further the communication around safety for children in window coverings. And the program is intended to work alongside the safety standard because we rely on the appendix D testing that goes on. And so you're basically asking three questions to qualify a product to meet this certification. And the first question of course is does the product have any cords? If it's no, then it's certified safe. If it has accessible cords, if it has cords, are they accessible? And again, if the answer is no, like the cellular shade that I showed you, the cordless cellular, then that would qualify. And the third of course is that pleated or horizontal shades, similar to the cordless one that I showed, that you can actually see and touch and pull on a cord, it would have to go through the appendix D test to ensure that it doesn't provide a wrap around or a strangulation hazard. So if it meets those requirements, it's considered cord safe. And then I've got the products listed below that are examples of those types of products. I have a question on the last slide. For each of the companies, what you can tell me, how have you had to change your processes to gain certification? In other words, how's the WCMA best for kids program impacted you in terms of being able to get product certified? I could speak first on this. Just the press release was just recent within the last couple of weeks. And I personally am working with InterTech, which is the lab. They have to still develop the protocols. And so when I return, we'll start working with them on developing what those protocols are. So it's still gonna be 60 to 90 days before this program is actually available from a public standpoint. Again, we just make the components so we would provide the customers making the finished product that are seeking certification with the various components. So it doesn't impact those of us one step back in the supply chain. To Tom's point, we are fairly early in this process. We will certainly be accelerating our efforts to get products that we fill meet this certification through the testing in the retail environment. But the end purpose of this program is to actually inform the consumers and to help drive that consumer choice if the consumer finds that that is one of the requirements that they need. So assuming that drives consumer choice, that obviously drives our innovation and our desire to supply more products that meet this certification. Again, it's early in the process, but we will definitely submit product through for testing certification. And if I understand the flow chart, right? If you have operating cords, you automatically can't be in the program. So coming back to the previous discussion we just had about how you're making operating cords inaccessible. According to this program, what's the incentive to make operating cords inaccessible since they still wouldn't be certified as best for kids? So maybe I can just highlight where I think you're headed with that, with an example, just so you're sure. Something that fails. So this is a system that we currently sell not in the United States yet, but it's going up for sale soon in the United States. So here, you can't form a hazardous loop ahead, can't fit through there, right? But you can touch it. And because you can touch this operating cord, it wouldn't qualify for the best for kids initiative, okay? I'm fine with that right now because if you think about it, what this is designed to do is to make it simple, clean, straightforward. Because right now, what this would require is yet one more test. And that is the pull force required to separate the cord that you can touch and can you push a head probe through there? And that complicates the program. That doesn't mean that there won't be, it's an iterative process in that down the road as it gets up and running and we see how it's working that a product like this won't qualify. But this is clearly a safe product right here. It's extremely robust. It performs very well. I'd stand behind this any day, but it's not for the best for kids initiative because it's a little more complicated, okay? So that to me is an easy way of thinking about it. Yeah, we're gonna miss out on some products and operating systems that won't qualify. But I think that's okay to get this program up and running and get wide acceptance and then we see what's working and what isn't, how to modify. And the other similar model you provided wouldn't either write the, you had the other previous roller shade with the, similar to the single cord system, right? So now you're operating this and you can touch that cord. So it doesn't qualify, okay? Yeah, because we need standard, because some of these, I mean, as people develop these, there might well be when you're pulling on this cord, depending on whether you're relying on gravity or relying on spring tensioning, what is, how much tension is on that cord? How much should be on that cord to avoid a wrap around hazard? So you introduce some more complexity to the process. Again, down the road, absolutely. But initially there are lots and lots of products that would qualify for this program. So why hold it up? Excuse me, are you saying the first product he showed would not certify? Because point three. That's my understanding. Even continuous loops with tension devices would not qualify into this program. Even when you state that do not, on the third step, do the accessible cords create a hazardous loop or wrap around? So in my opinion, that. Actually, yeah, actually. Only in. Just recognize that this particular flowchart is an older version. It actually reads, do the accessible inner cords create a hazardous loop. But the intent here was that no operating cords because it was intended to be simple, straightforward communication as to what would be best for kids. Thank you. A follow up to your point, Derek. On the voluntary standard, since you all are on the technical committee, you mentioned about developing standards for the operating loops then that would be, because I could understand you need the standard written first, you know, appendix E, shall we say, so that you can add another diamond in there somewhere. Could you give me an update on where you are with developing those standards, those requirements if you are as a, you know, part of the technical committee to get an appendix E analogous for that? Just so I'm clear, I mean, in that, you're saying the next phase of this, which would include other operating systems where you can touch the cord, but no hazardous loop is capable of being formed? I was following up, because you mentioned a voluntary standard in making the requirements when you were talking about how it's not in there now, but it would be. Oh, I see, right, so, no, I mean, our goal there is let's get this up and running and working. We've got to qualify the protocols, we've got to make sure we understand how it works, how people are using it, like any new launch of a system. And then right now, you know, we all acknowledge that there will be a new phase because we've got to address other safe systems that are appropriate for a program like this, but that is an underway today. The effort today is let's get this up and running and working and accepted, but we know it's going to happen. We're going to look at it. The standard development process right now where it stands is the last standard was published in 2012 and effective in 13. Next update, simple update that we're trying to do is get this US standard aligned to the Canadian standard in those that are consistent with other jurisdictions. And so the update with cord cleats is what we're working towards. The standard itself has not been reopened yet, but it's the intent of the WCMA to open the standard soon, but the first focus is getting it aligned with the other jurisdictions. Sorry, now I think I understand the confusion because that's the standard he's addressing. I was addressing the best for kids initiative, which is outside of the standard. It's not formally a part of it. It's being referred to as a certification. The intent here is that we are working with third party labs to be able to validate that certain products meet these requirements around best for kids. Tom, just to clarify further again, it came up here with what Joe was saying and you were saying that there were different versions of this flow chart. And the one referred to the inner cords in some of the boxes and the one you have here just refers to cords. Can you clarify that in either case, is it that if there are accessible operating cords, are they not eligible for the best for kids? They're not eligible. If you have accessible product like this, it's not acceptable. It even challenges products like this because it has an operating cord. So no operating cords is the intent of best for kids. Thank you. So I'll go back. We were on questions. So we have any additional questions that? Following on Mark Kumagai was talking about themes and going back to slide 11 and 12, there was a lot of discussion today about cordless and the limitations of cordless. And I think that everybody would agree that there's limitations on cordless, that there are real technical challenges with once you get to a certain size. I guess I would also just wanna say it again so it's clear that from our position, we're not focusing only on cordless. And I wanna make sure that maybe one of the outcomes of today is that you all don't focus only on cordless also. And with respect to trying to respond to CPSC and what we've sent you so far from staff and letters, et cetera. At the end, what we're really talking about are no accessible cords that can form a hazardous loop. And if the next discussion, that's how we wanna define cordless, completely fine with that. But what I wanna make sure and urge you all is to not focus solely on cordless and miss that whole other piece of it, which is an operating cord that doesn't form a hazardous loop. I think it's clear, everybody would acknowledge you're probably, you're gonna end up with window covering types that would have operating cords. And nothing that CPSC's put out there, talked about, discussed, participated in, have we talked about cordless as any sort of design requirement or even a performance requirement? And so I just wanna make, and so that's why I've been pushing so hard in the discussion about operating cords that don't form a hazardous loop. Frankly, I was hoping to see a lot more examples of innovation from industry on operating cords that don't form a hazardous loop. I mean, we had two or three examples here, but I think out of the time, we probably spent an hour and 40 minutes talking about cordless and the limitations. And I guess I just wanna make sure that we kind of keep our efforts focused on the bigger picture and don't get too wrapped up around cordless specifically. So as an action item, I would say the next step, I definitely wanna make sure that we keep this dialogue going and the discussion going. I can tell you that RANA is going to be fully committed to any voluntary standards development. I mean, I know the addition of the cord glee to align with the Health Canada Standard is coming soon. It has been, we've heard updates on that, but in terms of following on from on the 2012 standard was also published, which was we're gonna reopen the, or WCMA was gonna reopen the standard. I can tell you from CPSC staff, we're fully committed to participating in the voluntary standard process. And RANA and whoever else we need from the CPSC staff will be fully engaged on that. And I mean, I think today was a good start in terms of the discussion. And I think if anything, it also helped clarify, perhaps we were too narrowly focusing on solutions to a hazard vice taking a step back and looking at that broader view. Thank you. I think I could speak, excuse me, for everybody in the room that's representing manufacturing and yes, cordless, you may look at that and say, well, that's old news. And it's true cordless has been around for a while, but it doesn't mean that the development has stopped on cordless. And we agree, I believe that we can all agree that cordless is not the only solution that's part of our point is that we continue to develop around cordless and motorized systems, but we are showing some samples of a single cord type retractable devices. And those things are being reviewed on a business level. Being a large group like this, we had worked with each of the commissioners when they came out and we shared more directly the type of development that was being done at each of our respective businesses. That's not something that my business was willing to share in an open forum like this because intellectual property, our development is important to us and to our customers. I mean, that's part of the point of being in business is to be able to market product. I was gonna say, thanks, Tom. And to follow up on that point, we do have mechanisms to receive business confidential information. So don't view because it's an open meeting in this forum. I mean, we work with the office of general counsel and we do have mechanisms though where if you have pertinent information that you would like to share with us, we can set up the appropriate agreements so that you can provide business confidential information to us so I wanna just make sure that's clear too because I know oftentimes that's perceived as a barrier. I mean, certainly for an open meeting like today, it's all public information. We videotaped it, it's gonna be posted on the website. However, outside of this meeting, if you feel you have pertinent information you wanna share, reach out to Arana, reach out to myself, Joel Rect and we work with the office of general counsel and get that set up. So I just wanna be clear that's not a barrier for any of the industry members to at least come in and talk about it. Yeah, that's a good point, George. Having said that, maybe you can give me some insight. As an engineer, it's obvious that your engineering has worked on this and have developed some pretty innovative devices. My question is, do you think your engineers can develop an inexpensive blind that can address the strangulation hazard, whether it's a cordless, whether it's something that Derek had showed with his shrouded continuous loop? I think I'm trying to be as general as I can so that you don't have to worry about the confidentiality thing. So my question is, can that be done? Is the engineering there? Is the technology there? Well, that's definitely our goal and I've got several engineers that work on child safety full-time and we're working towards coming up with a simple solution that addresses child safety but as I said before, I don't think it's gonna be a single solution that's gonna fit every application and every installation. And cost is always one of the top few drivers in driving choice and so as a business we are clearly focused on delivering more value, better performance and lower cost. That's always one of our key focuses. I mean, we've looked at lots of different technology that and invented enough of our own that you might consider to be inexpensive. You know, the issue is for us always is a robust enough to handle the kind of abuse that you get. Because I can sense there's an interest to try to define commercial versus or delineate commercial versus residential and I can tell you that there is a huge blurred line in between because it's a hotel room commercial and yet it's a space that everybody wants to look like home. So you've got a new user in there every day and a lot of them aren't used to using some of these types of operating systems and sometimes the answer when it doesn't move if you try it one way is to pull even harder. And so breaks and then when it breaks it either forms other hazards or you have a very unhappy hotel room guest for example. So we have to always design for expected abuse, frankly. You know, use is probably the politer term but things just get mishandled over time and what that means is you've got to look at higher grade materials. You've got to look at extra support in there. So I can give you something that costs pennies that looks like it'll work today and if you operate it according to instructions. But once you start to say, okay, well how might a user use this thing or abuse this thing at what angles and what temperatures, what kind of pressure is gonna be put on these tiny little springs, pieces of plastic and all of a sudden it gets more and more robust. And for us we've got to design to that standard otherwise we can't stand behind the product and our customers would have a one time purchase. So then it gets more expensive. I guess just following up on that and the theme of the multiple solutions that Joe talked about and the multiple uses. To the extent you can provide us comments whether confidential business information or better yet if you can provide us public comments on where the limitations are. Where can't you, you're on the graph that showed the sizes is more than 95% for the cellular shades. What size is that that you can't make above what weight, whatever those limitations are. It's not so much that we wanna know whether it's commercial or residential, but if we can know where you can operate, where you can operate within cost, within durability. To the extent you can share us that information for the variety of solutions. Maybe with a single cord retractor can cover this portion of it, but the cordless can cover that portion and things like that. But over here, we just don't, we have a gap or something like that. That would be very helpful to us. You know what you're kind of describing is the nature of our business. Is I think there's very few industries, maybe I'm wrong because I've been in this industry for 28 years, where there is so much and I'm trying to think of the right word that you give up. So you can't go out and just say for all the products that are available, it goes from this width to this height or this width and this height. And so you're always giving up something and that's part of the complexity about our business because fabrics are different than wood, it's different than PVC, it's different than vinyl. All these things are different so every product category has its unique limitations and compromise was the word I was looking for and so as a consumer, they want nothing more than easy to buy, the customers that sell the products want it easy to sell. And it would be perfect if we had a grid that covered everything and it's just not that simple. And you're seeing that through the discussion that was the reason why we wanted to make sure that it was understood about the challenges associated with this because cordless, single cord pull, everything has got some level of compromise that people wind up having to accept and we want as a business more than anything to provide the simplest solutions to our customers because we all benefit from that as the customer benefits from that. And so that's why you see that we continue to develop, yes cordless has been around for a while but the point is that we continue to refine and redevelop those types of solutions because we wanna go bigger, wider, different fabrics. I mean that's really, and again, I get the point about it. It's not just about cordless, we understand that. And so to add on top of that, the question was asked about what are we doing? Are our engineers capable? Yes, absolutely. And not just our engineers within our businesses but engineers across the world. So we're all looking in different locations. And I had said that in all honesty, sometimes it's more than one a month. People approach me, wanna have their new idea that they think is gonna be the solution and many times these are solutions that they're gonna be very limited as to their application. And I'm always welcoming these people to come forth to us because one of these days you're gonna get that one in 10 or one in a hundred that's gonna be the home run. That's gonna be a really grand idea. So I just don't rely on my internal engineering staff to be able to do development. I do look outside of our staff for opportunities and innovation in that. I was just wondering if you guys, or if anyone has created an aftermarket or an add-on for the horizontal blinds to make those accessible operating pull cords not hazardous. So for all the people who already have the horizontal blinds installed, is there something or will there be something that consumers can add on? Yes, I'll leave you with the sample of that. I mean, there's an example of an add-on aftermarket. And the developer, the challenge that they would have is for all the different styles of rails. Unfortunately, our rail was different than the one that they used to design that. So I didn't have the retrofit kit to apply it. So there's those types of products that already exist. We offer cord cleats, which I know is not the solution that you're looking for, but that does provide limited accessibility. I mean, that's the point of using a cord cleat. We also have a cord winder type device, which is very simplistic, that allows you to wrap the cord up and get it out of the way of children to limit accessibility. Those are the very simple type solutions that are out there to help limit accessibility of those operating cords. But the solution that I showed you before retail, I'm thinking is in that range of $14 to $20, and that's a solution that's out there. I haven't seen other solutions that are similar to that. From my experience. Any other questions or comments? So we've overrun our two hours. I'll, if you have any closing remarks, I'll let, actually I'll go and then I'll let you all go. Give you all the last word, it's your meeting anyway. So I do want to say I really appreciate you all coming in today. I know how much preparatory time it took to get ready for today. All the physical samples you brought, the presentation today, plus the discussion. I do appreciate coming in and especially being frank about the challenges with the cordless. I think it was very productive discussion to kind of scope what the solution operating envelope looks like, because I think it is broader than perhaps we were looking at before. And as I said, from staff's perspective, we're definitely committed to working with you all either individually. I want to honestly, do want to keep this conversation going such that individually as companies, if you have things you want to discuss with us, staff will listen and certainly as a group, if there's additional information that you want to bring forward, we're going to be listening. And Tom, I will say to your point about trying to find the different solutions. One thing that we've also talked about when we're addressing the hazard is where are we seeing a lot of the incidents? And anything that works with horizontal blinds first would probably be a great step in advancing the safety with respect to where we're seeing the accidents. I definitely can appreciate that there's no one size fits all. And you don't want to try and address all of the window coverings all at once because it's a phenomenal industry in terms of the breadth of products and the different product types. But certainly looking back to, I mean, and you all have reports that you get to looking at the reports that come in. When we talk about where would we focus the efforts first? The horizontal blinds is one of the first places to focus if that helps as an industry in trying to decide where to put the resources first because I could understand you can't solve all of it all at once. And again, I really appreciate everybody in the audience that sat through this for a little over two hours. I know a lot of you have traveled the ways and I'll turn it over and give you all the last word. Well, I would just like to thank the CPSC staff for having this meeting. I think it was good to talk about where the industry is. And I wanted to thank you, George, for clarification on a couple of the items. One with the eight inch pool cord being in a static state and also regarding the cords, not just inner cords, but operating cords regarding inaccessibility or the creation of a hazardous loop. So I think those two clarifications will help. Thank you. Again, I echo the sentiments that we appreciate the opportunity to come in and speak directly with the CPSC and be able to have our voice to be able to show and help manage a level understanding around products, cordless, and operating systems. Yeah, and to everybody's point, I'd like to reiterate the fact that we are putting quite a bit of effort and focus on this issue. And we're glad to come here and meet with everybody and clarify terminology, understanding, basically help us set the foundation for a way to move forward more united on this issue. Yeah, and thanks for having us hospitality here. Looking forward to working with Rana, I think Joel, right, on future standards development. So thanks a lot. Well, I guess I have to say something. But the part that I would like to take advantage of, and I think it'll be helpful all around, is to bring together some ideas and show them to you on a more private basis from around the world so you can see the types of solutions that are out there a much broader range than you might see in the US market, how different countries have addressed the hazards and why it is that a company like ours would make the decision not to move forward with it. I think it's really important that you understand that. And some of it really comes down to how Americans differ in the way they operate shades than non-Americans, as odd as that is. Seems like they'd all be the same, right? Well thank you everybody, and that concludes today's public meeting.