 I'm pleased to open this hearing to gather oral comments on the commission's proposed safety standards for window coverings. Before we start, let me take a moment to confirm all four commissioners are present. Commissioner Biacco. Present, thank you. Commissioner Feldman. I'm here, thank you. Commissioner Trumka. Here, thank you. Good to see everybody. The proposal we're considering today is made up of two separate rulemaking proceedings. First, known as a 15J rule would make the existing voluntary standard for stock window coverings mandatory and enforceable. The second rulemaking would require that custom window coverings meet the same standard as the stock. Window blinds and draperies are everywhere. And most of us don't get a thought as to how they're made and how they operate. Unfortunately, about eight families per year learn that the cords attached to these products can be deadly. The decision will make any attempts to protect children and prevent future tragedies. We have seven witnesses with us today, split into two panels. I look forward to hearing their testimony into the discussion that'll follow, particularly what acknowledged Linda Kaiser, who will be closing out our hearing today. She lost her daughter, Cheyenne Rose, to an inter-cord strangulation about 20 years ago. She's been advocating for window cord safety ever since. I appreciate your persistence and your focus. Each panelist will have 10 minutes for their presentation, and then I'll call upon myself and my colleagues to ask questions for 10-minute rounds, with multiple rounds if necessary. Witnesses, you'll receive a chat message from the staff when you have two minutes left in your presentation, and then again when you have 30 seconds left. I'd also like to remind all panelists to mute themselves when they're not speaking. Public comment period is open until March 23rd, and I encourage the witnesses who are here today, as well as other members of the public, to submit comments into the docket. We'll now introduce the first panel. The first panelist is Nancy Coles, who's Executive Director of Kids in Danger. Second is Rachel Weintraub, Legislative Director at General Counsel, also the Consumer Federation of America, and Ori Shen, who's Policy Counsel at Consumer Reports. Let's start with Ms. Coles, and you are recognized for 10 minutes. Thank you, Chairman, and thank you to the Commission for holding this hearing for discussion of the safety standard on operating cords on custom window coverings. This mandatory standard is a long time coming, too long by almost all measures. I'm the Executive Director of Kids in Danger, or KID. KID is a nonprofit organization dedicated to protecting children by fighting for product safety. I can still remember the first time I met Linda Kaiser and heard her talk about Cheyenne's death and the impact on their family. And to think that since that time, all those years ago, another family has faced the same experience every month or two is tragic and needless. KID agrees with CPSC's determination that there is an unreasonable risk of strangulation to children under eight from accessible operating cords longer than eight inches. We support this new rule, which will cover custom window coverings with the same requirements from the industry standard for stock window coverings. The custom exemption in the industry standard has not sufficiently reduced the hazard in addition to the fact that it is only voluntary. In the NPR, CPSC notes that 35% of all strangulations of children under five involved window covering cords. It is rare in public health that we can have such an impact on a whole category of deaths by regulating just one type of product. The first voluntary window covering standard was adopted in 1996. Decades have passed with attempts to change voluntary standards while the number of deaths and permanent injuries has grown unabated. The CPSC is required by statute to first rely on voluntary standards. This hazard alone points out the folly of that reliance in many instances. Dozens of children have died and more have been permanently disabled while CPSC waits for the industry to do the right thing. This is not a problem in search of a solution. Many cordless solutions are now available at comparable prices, no more waiting. We urge the swift adoption of this standard along with adequate enforcement of both this standard and the 15J rule for stock products to eliminate this horrific cause of child death. We support the addition of testing requirements for all window coverings in this standard as well as the third party testing and certification requirements for window coverings that are sold as children's products. I would like to add some comments based on the requests for comments in the NPR. First to the question of battery-operated remotes for cordless blinds. Both cords and button and coin cell batteries are hidden hazards in the home. It would be a mistake to allow the increased in motorized window coverings to reduce the number of cords but at the same time increase the number of hazardous batteries. CPSC should include requirements that any batteries comply with the requirements similar to the toy standard that requires a compartment that needs a tool to open and use an abuse testing to assure that the compartment stays secure. Then to the issue of warning labels even on compliant products. Many consumers will be unaware that the cordless nature of their window coverings is a safety feature. Therefore, if the system fails and a cord becomes accessible, they will not necessarily be aware that it has become a safety hazard. Warnings will help alert consumers to the hazard and steps to take if a cord does become accessible. The CPSC should keep the period leading up to the effective date as short as possible. The CPSC has estimated that 39 million units of window coverings that would be affected by the standard are sold each year. Each month's delay means more hazardous units are installed in homes where they will last for decades. We have waited too long to fully address this hazard and there is no need for additional delay now. I wanna thank the commission for acting on this long-standing hazard. Kid, appreciate your willingness to move these items that have languished waiting for action for many years. Lives will be saved. Thank you. Thank you, Ms. Kohl. Next we have Ms. Weintraub. Thank you. Good morning, Chairman Honsarek, commissioners Bayoko, Feldman and Trumka. Thank you for the opportunity to speak today. I am Rachel Weintraub, legislative director and general counsel at Consumer Federation of America. CFA is a nonprofit association of approximately 250 consumer organizations that was founded in 1968 to advance the consumer interests through research, education and advocacy. Today, I speak in strong support of the CPSC's proposed standard to address operating cords and custom window coverings. An effective mandatory standard that addresses the strangulation hazard posed by all window coverings is necessary because the current voluntary standard has failed to address the key hazard pattern associated with all corded window coverings available on the market. For almost 30 years, the voluntary standard has repeatedly failed to address the issue in an effective way. The CPSC has been communicating with the manufacturers of these products for years. The voluntary standard had minimally changed over time until 2018, but then it didn't cover all of the products on the market. Unfortunately and consistently, the industry has not significantly addressed the issues posed by accessible cords in all window coverings. Significantly, the industry's voluntary standard has not significantly reduced the death rate. The CPSC is aware of 194 reported incidents, including 89 fatal strangulations and 105 near-miss strangulations from children becoming entangled by cords on window coverings from 2009 through 2020. The CPSC estimates that at least eight children die each year because of cords on window coverings. These are products on the market. There are products on the market that do not pose strangulation risk to children. Virtually every window covering type is available with a cordless operating system. The research and technology already exist to design products without strangulation risks. Manufacturers know how to do this. In fact, manufacturers stated to the CPSC in 2015 that cordless options are available in every product category. And yet, and yet, reported products still are for sale and are not prohibited from being sold. This is unacceptable. Although safer designs are available on the market, manufacturers currently sell some of them at a premium, making them cost prohibitive for many families. If the CPSC enacts a mandatory rule, it will ensure that the minimum level of safety is applied to all products for sale on the market. This will protect all consumers effectively and will strengthen the market for companies who want to innovate to protect children. A mandatory standard addressing the strangulation risk posed by operating cords on custom products is necessary. A mandatory standard that reduces the risks posed by operating cords on custom products will minimize the risk to children. Without a doubt, reducing the number of products with hazardous accessible cords that can strangle children will reduce risk to children. This proposed rule builds upon the incomplete 2018 voluntary standard that address operating cords on stock products and inner cords of stock and custom window coverings. The proposed rule will require that operating cords on custom window coverings meet the same requirements as operating cords on stock window coverings, as included in the NCWCMA 2018 standard. This would require that operating cords on custom products must be cordless, inaccessible, or eight inches or shorter in length in any use position. CFA also supports the separate concurrent rule making under section 15J of the CPSC that will, CPSA that will deem as a substantial product hazard, hazardous operating cords on stock window coverings, hazardous inner cords on stock and custom window coverings, and the absence of warning labels. This is especially critical since the CPSC found in unannounced visits to wholesalers, manufacturers, and retailers that four out of 13 locations did not comply with the voluntary standard for custom products. Thus, CPSC's enforceability of a mandatory standard of these provisions is critical. The NCWCMA standard fails to effectively address hazardous cords in all window coverings, even though it is technologically feasible to do so. In the proposed rule, the CPSC states that the voluntary 2018 standard, quote, does not adequately address the risk of injury associated with operating cords on custom window coverings because the NC standard allows operating cords on custom window coverings to be accessible to children and to be longer than eight inches, which presents an unreasonable risk of strangulation to children eight years and old and younger. We are concerned about some of the preliminary provisions in the draft of the 2022 voluntary standard, which proposes to give manufacturers the option to replace operating cords and custom products with continuous loop cords and chains. We are similarly troubled by a proposal to deem retractable cords inaccessible if, when at rest, the cord is less than 12 inches. Children can gain access to this cord, pull, turn around and be strangled by the tension of the cord. Retractable cords, as CPSC includes in the NPR, should be considered accessible cords that are prohibited to be longer than eight inches. The CPSC and WCMA have been engaging on issues of window covering safety for decades without an effective solution that minimizes the strangulation risk in all window coverings. This has taken much too long. Since 1995, the CPSC and WCMA have been working on the development of a voluntary standard. Decades have passed with eight revisions to the voluntary standard, but to this day, the standard fails to wholly address the strangulation risk despite the CPSC's repeated and emphatic requests for standard that eliminates hazardous accessible cords. The promulgation of a mandatory standard to address strangulation by window coverings is needed. Further, while the CPSC and WCMA have worked together to educate consumers through public education campaigns, this has proved ineffective in preventing strangulation deaths of infants and young children. We applaud the CPSC's determination that retractable cord devices, cord cleats, cord shrouds, cord condensers and wands are inadequate to address the risk of injury associated with operating cords on custom window coverings. The CPSC notes that all of these devices are currently available for purchase by consumers but are not sufficient to protect children from hazards posed by operating cords. An argument made for many years by members of the window covering industry is that window covering cords cannot be inaccessible on all window coverings due to the needs of people with certain physical disabilities. First, if that were truly the case, an exemption to a strong standard could absolutely be made rather than preventing the development of an effective rule. The CPSC identified numerous tools on the market designed specifically to make window coverings easier to operate for certain consumers. In conclusion, a strong mandatory standard for window coverings that effectively addresses the strangulation risk posed by accessible cords is necessary to protect the public from the irrisible risk of harm posed by these products. We applaud the CPSC for moving forward on this rulemaking and urge the process to continue as quickly as possible. Time is of the essence as these products pose risks to children every single day. Thank you, Ms. Weintraub. Next, Ms. Shen. Thank you, Chair. So Consumer Reports, the independent nonprofit member organization welcomes this opportunity to present arguments to the Consumer Product Safety Commission regarding the agency's notice of proposed rulemaking to establish a safety standard for operating cords in custom and window coverings. We commend the CPSC for proposing a rule that would ensure custom window coverings adhere to strong and sensible requirements based on a robust body of evidence collected over the last four decades. Consumer Reports also welcomes a CPSC's decision to pursue concurrently a Section 15j rulemaking that would deem the presence of hazardous operating cords found in stock window coverings and the presence of hazardous inner cords found in both stock and custom window coverings as substantial product hazards. The CPSC's actions to address both stock and custom window covering cords in parallel rulemaking efforts are appropriate and necessary to provide clarity in the marketplace and to protect children from the risk of injury, of serious injury or death. It's been nearly 40 years since the CPSC's first warning to parents and the public about the dangers associated with window covering cords. Despite the agency's release of regular warnings over the years, the voluntary standard development process for window covering cords has failed to sufficiently protect infants and children from serious risk of injury or death from strangulation. Since 1996, the voluntary standards process has yielded numerous iterations of a standard that has not adequately addressed the serious hazards associated with inner and operating cords found on window coverings. Repeatedly, the voluntary standard has placed the burden on consumers to keep hazardous and accessible cords out of reach of children with many of its updates to the standard focusing on tension devices that require proper installation by the consumer to be effective and updates to their instructions and warnings. As a result, fatal and non-fatal incidents related to window covering cords continue to be reported with at least eight children dying from strangulation every year. The CPSC identified a minimum of 194 fatal and near-miss strangulations involving children eight years and younger that occurred between January 2009 and December 2020. Frustrated with decades of delay and ineffective piecemeal attempts to address these hazards, consumer reports along with partner consumer organizations formally petitioned the CPSC in 2013, nearly nine years ago, to promulgate a strong mandatory standard that eliminates the strangulation hazard posed by accessible cords in all window coverings. In 2018, the voluntary standard was updated to include stronger safety standards for inner cords for stock and custom window coverings and operating cords for stock window coverings. While this update included the strongest safety requirements to be implemented in nearly three decades, it still failed to address hazard associated with operating cords on custom window coverings. Now, there is no good reason why operating cords for custom window coverings should not meet the same requirements as operating cords for stock window coverings. In today's market, custom window coverings make up an estimated 36 to 49% of all unit shipments indicating that a large share of the market falls outside the current voluntary standard safety requirements for operating cords. Without requiring custom window covering products to meet the 2018 voluntary standard, serious incidents related to accessible operating cords on window coverings will continue to occur. In addition, compliance with the 2018 voluntary standard shows that it is feasible for manufacturers to address serious hazards and adjust product designs to better protect children. Moreover, sufficient data exists to demonstrate the continued presence of serious safety hazards linked to accessible window cords regardless of the window covering products categorization as stock or custom. As documented repeatedly over the years, operating and inner cords found in both stock and custom window coverings have been the source of too many preventable tragedies. Despite the updates made to the voluntary standard, the average number of fatalities each year has remained unchanged. CPSC's analysis of window covering incidents highlight the nonsensical categorization of stock and custom window coverings in the voluntary standard. The CPSC points out that in its briefing package that for most of the incidents, the staff did not have enough information to determine if the window covering was stock or custom. While the 2009 to 2020 incident data highlights the difficulty to discern between stock and custom window coverings, this data does make clear that operating cord systems are the single most hazardous scenario among the fatal incidents reported, accounting for 44% of the known fatalities involving window covering cords. Where the CPSC was able to identify the type of window covering, it identified 35 of the 194 incidents involved custom window coverings and 30 of these 35 incidents were related to operating cords, including pull cords and continuous loops. CPSC staff advised that 100% of these incidents involving operating cords on custom window coverings would have been prevented if requirements in the 2018 voluntary standard had been in effect for all window covering cords, including these operating cords on custom window coverings. Incidents involving window covering cords continue to show the inherent and persistent hazard that these products pose to children eight years old and younger. The compiled CPSC incident data shows how children have strangled on operating cords, including incidents where children have climbed on items like a couch and were able to access the cord. Operating cords that are accessible and are long enough to wrap around a child's neck can result in serious injury, including long-term or permanent vegetative states or even death. Such injuries or death can occur within minutes of window covering cords wrapping around a child's neck and applying pressure to their airways, vessels or nerves in the neck. Given the severity of these injuries, the hazards that accessible window covering cords present and the continued industry delay in fully addressing the hazards, the CPSC is well within its discretion and is correct to promulgate a mandatory standard under section seven and nine of the Consumer Product Safety Act. The 2015 window covering manufacturer, excuse me, in 2015, window covering manufacturer submitted comments to the agency's advance notice of proposed rulemaking stating that a mandatory rule would negatively impact the window covering industry. Since the 2018 updates to the voluntary standard, since the 2018 updates to the voluntary standard, industry has shown that compliance is feasible with manufacturers adapting product design to address serious hazards and to protect children. As a result, today the marketplace offers cordless models for most stock window covering categories as well as for some custom window covering categories. The February 2021 CPSC commissioned market analysis concluded that the voluntary standard has caused the US window covering manufacturers to design and offer lift operations for most window covering, for most window covering categories. The CPSC's proposed rule is necessary to address delayed and inadequate action by industry and to finally remove hazardous window covering cords from all units that are for sale in the consumer marketplace and to prevent future serious injuries and deaths. The CPSC should ensure that any custom window coverings on the market must adhere to strong safety requirements to protect children from serious risks associated with strangulation by any operating or inner covering, inner cord. We urge the CPSC to finalize the proposed safety standard for custom window covering operating cords in addition to the Section 15J rulemaking without delay. Thank you for your consideration of our comments. Thank you, Ms. Shen. With that, that concludes the first panel. We're gonna turn to questions from the commissioners and I only have a couple that I'm gonna start with. Again, thanks to the first panel for the testimony. Ms. Calls and Ms. Weintraub, understand that you're both taking part in the industry standards process that was kicked off by WCMA to update the 2018 standard. And WCMA has suggested pausing our rulemaking to allow that process to go forward. Maybe I'll start with you. Ms. Calls, do you think that that is a good idea? And do you think that the voluntary process will result in a strong voluntary standard for the custom lines? Just to clarify, I am not involved in the process. They kind of have a limit on consumers, but Rachel certainly is. But I can certainly say that I think as we've all attested to in your own briefing package shows that 20 years hasn't gotten as a strong standard from the industry. I don't think additional time will, especially when we have this alternative now that will protect consumers. Thank you. Ms. Weintraub? Yeah, I would say unequivocally, there should not be a pause. The processes can occur concurrently, but I think, and you've heard this morning already and you'll likely hear more that this process has already taken an incredibly long time and the CPSC's movement on a mandatory standard is incredibly important to keep going and to really happen and move as quickly as possible. And you're comfortable working on that concurrently? Absolutely. Ms. Shin, in your testimony, you've cited a CPSC finding that custom window coverings make up an estimated 36 to 49% of all units shipped, indicating a large percentage of the markets, not covered by the same standards as the stock window coverings. Is there, from your perspective, is there a reason consumers who are buying stock products should be subject to lesser or different safety standards? I do not. When we're talking about operating cords, the hazard is the same, regardless of whether you're talking about stock or custom window coverings. And so this hazard is just so severe and so devastating to these families that we must ensure that all operating cords align with the same safety standard. Thank you. I'd like to hear from my fellow commissioner. So at this point in time, I'm gonna turn to Commissioner Biakko. Thank you, Chair. I actually want to thank everyone for their presentation and their well thought out comments. I do not have any questions. Thank you. Thank you, Commissioner Feldman. Thank you. And I wanna thank our witnesses for their testimony today. I also wanna thank the chair and staff for their work on today's hearing. Incidents involving operating cord strangulation are tragic as we've heard and have remained unresolved for too long. I would refer everybody to the statement that I made when the commission voted to issue its notices of proposed rulemaking that are the subject of today's hearing. Again, I wanna thank the witnesses for their testimony and I have no questions at this time and would yield back the balance of my time. Mr. Trump. Thanks. I wanted to thank the panel for their testimony and just share an anecdote that my family and I rented a house this weekend, just a few days ago. And before I was finished unpacking the car, I walk into the house and I see my son walking on the back of a couch, he's five years old and he's holding on to the window covering the quartz and he's going from one to the next to keep himself balanced. And if there's anything more dangerous than that, I mean, it was terrifying to see that and it was an opportunity to discuss this risk very recently in the moment. And we took that opportunity. And I hope that less and less families have to have that conversation going forward. So thank you. I have no questions from the panel. Thank you, Escher. And thanks again to the panel. I appreciate you taking the time to speak with us this morning. And at this point in time, we're gonna move on to the second panel. So I'd like to introduce the second panel. First we have Ralph Seming, who's the executive director for the Window Covering Manufacturers Association, WCMA. If Susan Woodcock, who's the owner of Custom Work Room Technical Center. Harold Pollack Nelson, who is with the Independent Safety Consulting. Linda Kaiser, as I'd mentioned before, is the founder of Parents for Window Blind Safety and been an advocate for a long time in this issue. Thank you all for being here. I'd like to start with Mr. Seming and recognize you for 10 minutes. Thank you, Mr. Chairman. Good morning. And thank you for the opportunity to provide comments on the CPSC's notice of proposed rule makings on stock and custom window coverings. My name is Ralph Isami and I am the executive director of the Window Covering Manufacturers Association. WCMA represents the interests of the window covering industry manufacturers, fabricators and assemblers. Industry products include blinds, shades, shutters, curtains, drapes, drapery hardware and other window coverings. Our members are a leading resource for the policy makers developing industry standards, rating systems and test procedures. WCMA is also the American National Standards Institute accredited standard development organization for window coverings. WCMA is aligned with the Consumer Product Safety Commission commissioners, staff and safety advocates in addressing the risk to young children from strangulation hazards associated with certain window covering cords in their homes. WCMA has a long record of working with the CPSC and safety advocates to eliminate hazards and drive innovation. Most recently, WCMA worked with stakeholders including CPSC to develop and publish the 2018 ANSI WCMA Window Covering Safety Standard. The updated standard, eliminated cord, corded stock window covering products by requiring that these products be cordless, have only inaccessible cords or have a short helper cord. These changes effectively eliminated cords on approximately 80% of all window covering products sold annually. For custom window covering products, the 2018 update to the ANSI standard created a default cord length limitation for operating cords and a default to a tilt lawn that eliminates the tilt cords. These defaults can only be overridden by an explicit decision by the consumer and only after seeing the appropriate safety information. The reports from our members suggest that there was minimal pushback on these product defaults. In addition, an ever-growing segment of the custom product market is selecting cordless products as the product of choice. WCMA continues to be proactive on updating the voluntary standard, requesting that ANSI reopen the ANSI WCMA standard on April 23rd, 2021 to further address the safety concerns on custom window coverage. ANSI requires that the standard be reopened every five years, but we have continually reopened it earlier than that as technology has warranted. On May 23rd, 2021, five months prior to CPSC staff releasing their briefing package, WCMA officially reopened the voluntary standard on custom products. Since then, WCMA has convened multiple technical committee and steering committee meetings with the goal of further eliminating potential hazards associated with corded custom window coverings. The steering committee, which is made up of representatives from industry, consumer advocates, CPSC and test labs, has reached consensus on eliminating prehanging operating cords, tilt cords and cord connectors, plus the addition of rigid shrouds in a new standard. Plus, there have been proposals which have gained consensus on retractable cords, having no cord showing from the headrail. And as was mentioned earlier, proper controls for battery operated remote control systems that would match the requirements of the toy standard. WCMA supports CPSC's proposed rule for stock products under 15 J of the Consumer Product Safety Act. We hope that the rule is finalized expeditiously. WCMA, however, opposes the proposed rule related to custom window covering products. We believe that the CPSC's proposed mandatory standard is unreasonable. The proposed application of all requirements for stock window coverings to custom window coverings is not supported by the CPSC's own data, nor is it technically feasible and will ban safe products while unnecessarily increasing costs for consumers. The proposed standard does not recognize that custom products, which are a small segment of all window coverings require more flexibility than stock products to allow for a product that can serve as a variety of size, weight and location constraints. For example, it is necessary that some corded products remain on the market based on the location of the windows they are covering. Custom products with compliant cords are also needed for segments of the population that may be unable to effectively operate a cordless product. Those with disabilities or other restrictions who are unable to afford a motorized product will continue to need a compliant corded product so that they can operate the window coverings in their home. In addition, commissioners voted to reduce the effective date from two years in the briefing package to 180 days should the mandatory standard be approved. The CPSC's proposed standard would eliminate product categories for custom window coverings with no viable replacements and would require a significant transition of product lines with impacts along the value chain affecting manufacturers, distributors and retailers. This lead time makes it impossible to design and implement suitable replacements meaning that there would not be product available by the end of this year. In addition, the proposed standard has not considered the cost impacts of the 180-day effective date. Manufacturers have already designed their custom products for fall 2022 based on the ANSI WCMA safety standard. Many of these products, though safer, would not comply with the CPSC's proposed standard. These products would therefore need to be redesigned with significant loss of product and time. One product alone takes many, many months to design. A complete product line is impossible within 180 days. Effective data side, there has not been an adequate amount of time to judge the effectiveness of the 2018 ANSI WCMA safety standard as it relates to custom products. In addition to the time required for implementation of the standard, custom products have a lengthy lifetime and are not regularly replaced by consumers. For these reasons, CPSC's determination at the standard is not effective as premature. As the CPSC staff acknowledges, a majority of firms affected by this proposed standard are considered to be small businesses and these small businesses will incur the majority of the costs, including eliminating a significant portion of their product lines, which could lead to many having to shut their doors. In conclusion, WCMA members strongly believe that the NPR related to custom window covering products is unnecessary, duplicative, and would divert important resources that are needed to accomplish the objectives that are set forth in the ANSI WCMA standard development process. WCMA respectfully requests that no action be taken to advance the custom window covering proposed standard. Instead, CPSC should continue to support the voluntary standard revision process as the fastest way to allow industry, safety advocates, and CPSC to achieve our common goal of addressing the risk to young children of strangulation for window coverings in their homes. Thank you for your time. Thank you, Mr. Vasemi, and sorry for mispronouncing your name earlier. Ms. Blikow, I recognize the 10 minutes. Thank you. And thank you for the opportunity to speak today on behalf of small business owners on the custom market. My name is Susan Woodcock. I am the owner of Custom Workroom Technical Center located in Trion, North Carolina. Workroom Tech is the only trade school in the United States specifically for custom sewing professionals who make window coverings and other soft furnishings. Before opening Workroom Tech, I owned a custom drapery business for over 30 years and my husband and I produced Custom Workroom Conference, which is an annual educational event and trade show for the custom drapery and upholstery professional. I've been a Workroom Educator since 2003 and I'm the author of the book Singer Sewing Custom Curtains Shades and Top Treatments. Our in-person and online training programs educate the hobbyist and the professional about cord safety and window coverings. I've helped window covering manufacturers learn how to fabricate and sell custom products that comply with the WCMA and see window covering safety standard. I support continued development of safety features and product innovations that make window coverings safe. The past 10 years, we've seen a huge amount of new innovations and I know this will continue and I'm excited about that. I am alarmed by the proposed changes to the custom product category in such a short timeframe. It will have a negative impact on custom manufacturers and interior design businesses. There needs to be time to research and purchase components and systems, retrain employees on new operating systems and a retrofit work rooms for new fabrication methods. More time is needed to order replacement displays and samples, update showrooms and educate the sales force. Please consider the extreme cost that such a short timeframe would impose upon small businesses throughout the United States. I respectfully request that the CPSC reconsider and if changes are made to the custom product category to allow at least 12 to 18 months before the changes are implemented so that small businesses can better prepare. Thank you very much. Thank you Ms. Woodcock. Next we have Dr. Paul Nelson, please. Chairman Hunsaric, Commissioners Biaka, Feldman and Trumpka. Thank you very much for this opportunity to present comments regarding the NPR for custom window coverings. I am here to express my support for the CPSC's development of a mandatory rule that prohibits hazardous accessible window covering operating cords on custom products. I am a human factor psychologist specializing in consumer product safety and I am one of the authors of the window covering petition that was submitted to CPSC in 2013. As you know, the petition sought to prohibit accessible window covering cords when a feasible cordless alternative exists and when it does not, we've requested cords be made inaccessible by passive guarding devices. I have participated in the ANSI WCMA standards process off and on for the last 10 years. The 2018 standard for window coverings is a huge stride for product safety in that it effectively addresses the strangulation hazard posed by operating at inner cords on stock window coverings by requiring cordless operation, inaccessible operating cords or operating cords shorter than eight inches in any use position. However, these same protective requirements do not apply to operating cords of custom window coverings. Rather, the standard for custom products has inferior safety requirements. For example, for operating cords, the 2018 standard requires a default cord length that is a maximum of 40% of the product's length when fully lowered. Operating cords longer than eight inches can encircle a child's neck and cause strangulation. Children can access cords by climbing on windowsills, chairs, couches, et cetera. The window covering data contains 14 incidents where a child climbed on such an object to access the cord. And in other cases, the child's elevated position on a sleep surface, like a crib or a bed, enable them to access the nearby cords. Children's motivation to seek out household objects that are off limits to them and their ability to climb in order to reach these items is a hazard pattern we have seen repeatedly over the years. We've seen it with portable pull drownings where children climbed the ladder. We've seen it with furniture tip over incidents. And prior to the standard for utility lighters and cigarette lighters going into effect, we saw horrific burns and deaths caused when children as young as two and three years of age climbed on chairs and counters to reach lighters. In many cases, caregivers were and are unaware of their child's interest in these objects like window cords and lighters. That the industry standard does not impose the same requirements for custom products as it does for stock defies logic. Children who interact with the product do not know or care if the product was purchased as a stock or custom item, nor does this distinction affect the hazard pattern. Operating cords that are accessible and long enough to encircle the neck for zen astrangulation hazard, it's as simple as that. This is confirmed in CPSC's incident data shown in table 1B of the NPR. In cases where the type of window covering stock or custom was known, 41% of fatal and non-fatal incidents involve custom products. Moreover, and importantly, the technology exists to eliminate or guard against the strangulation hazard for every type of custom window covering product just as it does for stock. And one more thing I'd like to mention, consumers who purchase custom products will reasonably expect these window coverings to be not only as safe but safer than stock products. After all, one does not expect to get lesser quality or lesser safety from a custom product. However, that's actually the case. Safety devices for custom products that comply with the 2018 standard are inadequate to protect against the hazard as their effectiveness requires specific actions on the parts of consumers that they understandably may not realize are necessary or may not be willing to take. Cord cleats are wholly dependent on consumers' frequent wrapping and unwrapping of cords around a small cleat. Longstanding published research finds that low rates of compliance with safety measures with safety measures that have a high cost and that cost can include the time we're in convenience required to comply. If any of you have done it, you know that wrapping a long cord around a cleat takes a lot of time. Even well-intended consumers may forget or fail to wrap the cord for every window fully, particularly if their child has not shown prior interest in playing with the cords. Another example of an inferior safety device permitted by the 2018 standard for custom products are cord tension devices. These devices are attached to continuous loop operating systems and are intended to prevent entanglement in loop cords. However, some consumers, particularly renters, are not willing to install the tension devices because doing so requires drilling into their walls. And this is the same concern we've seen with consumers not wanting to anchor dressers to the wall to prevent tip over. Further, it is my understanding that failing to attach a tension device does not necessarily render the wine useless as consumers can still operate the window covering just not by the loop cord. And in some cases, tension devices can be removed entirely leaving a fully functional looped cord. After nearly 40 years and hundreds of strangulation deaths on window wine cords, I am confident that the only strategy for stopping these deaths from continuing is to eliminate dangerous accessible cords both long and looped. We cannot rely on communications to address this hazard. Extensive information and education efforts by WCMA and the CPSC for the last 37 years, including CPSC press releases, social media posts, and WCMA's safety messaging on its website, on social media and magazines and other locations have had limited impact at best. In one case in which I served as an expert, the father of a deceased child testified that he had never heard of a child strangling on a window covering cord until he was in the emergency room and saw a poster on the wall depicting the hazard. We also cannot expect the on product warning to mitigate this hazard even though the warning is consistent with the ANC Z535.4 guidelines and it includes an explicit pictogram. Despite this, the warning is not likely to have an effect on consumer behavior and it ultimately won't have an effect on safety. Courted window coverings are part of the visual landscape of a home. They blend in with the background or highly familiar, uncomplicated and seemingly benign. Consumers do not tend to look for warnings on products that are familiar and non-threatening. And although they are open and closed daily, operating window coverings is an automatic behavior where we go through a behavioral script requiring little thought or attention. In other words, the consumer is in a task oriented mode when interacting with window coverings not in an information seeking mode. Furthermore, the warning on a window covering is not readily visible during use even when looking directly at the window covering. On horizontal blinds, for example, the warning is on the bottom rail. The warning on the bottom rail is not visible whether the blind is in the lowered or raised position. When lowered, the warning rests against the sill. In the raised position, the warning is parallel with the floor. For the reasons I have expressed, I strongly support the CPSC's NPR proposal to require custom window coverings have the same requirements as stock. A few other comments. One, I recommend a sticker be added to every blind, identifying the manufacturer and a toll-free number to call in case the product breaks. Two, retractable cords are a concern to me as I believe young children who observe operation of retractable cords will find them attractive in terms of the movement, the sound, and the responsiveness. And for this reason, I think that retractable cords that are accessible need to be protected by either they shouldn't be accessible or they should be protected by a shroud or other device that prevents them from circling a child's neck. And I would like, finally, I would like to see the standard address the serious potential risk of esophageal and airway burns caused by ingestion of button or coin cell batteries to young children. And this hazard can be addressed using performance requirements that are seen in the toy standard. I wanna add one more comment based on something that I've heard other people talk about and that is in terms of the time required to comply. As other people have said, this hazard has been known to industry for about 40 years. And we've known what the problem is, we know how to fix the problem and all these products already exist in the market. It's up to manufacturers to see what's coming. This is not a new hazard pattern. Getting up to speed is something that every manufacturer could have done on their own in advance of any potential goal that the CPSC has. Finally, in closing, I wanna say that window coverings remain in homes for many years or decades. Because of their longevity, I feel it is imperative to act quickly. If the mandatory standard were enacted today, I think we would continue to have about 20 more years when we would expect to see deaths continuing. I wish to thank the CPSC and its staff for working hard to address this issue. I urge the commission to issue the mandatory standard as quickly as possible to prevent more deaths and life-changing injuries to children in the United States. Thank you, Dr. Paul Nelson. And finally, we turn to Ms. Kaiser. Thank you for being here. Hi, good morning. Thank you for having me. I'm grateful for the opportunity to comment on the CPSC NPR for corded window covering products. As many of you know, I'm the founder of Parents for Window Blind Safety after losing my twin daughter, Cheyenne Rose. She lost her life in the inner cord of a stock window blind. And since then, I've advocated for safer window coverings in children's sleep and play environments, including being heavily involved in the voluntary standard development process since 2009. Our organization consists of hundreds of parents whose children have been injured or killed by accessible cords on window coverings in the past two decades. And so I speak not only for my daughter, but for hundreds of children that have been strangled on accessible cords since her death. So over the years, many have died, I mean, many have said, that the voluntary process is a faster process. But if we look at the history, we can see that it has been an excruciating long process to eliminate the risks associated with children strangling on operating cords. So in 1985, all window coverings were manufactured with loops on operating cords. And then in 1996, WCMA and CPSC worked together to create the first ANSI standard. And some of the loops were cut into two cords. And then in 2002, WCMA revised the 1996 standard to address the intercord hazards. Operational cords remained untouched by WCMA, and that was her second opportunity to address operational cord hazards. And then in 2007, WCMA created the new ANSI standard in their third attempt, which fall short of preventing operating cord injuries. Then in 2009, WCMA released another ANSI standard update to address Roman shade intercord hazard in their fourth attempt. The CPSC replied that the new standard did not eliminate operating cord hazards. And then in 2011, WCMA proposed a revised ANSI standard that included updating tension devices and warning on packages. Operational cords were not addressed. The CPSC called to limit cords no longer than 12 inches was rejected as unfeasible. So in 2011, in September, safety advocates, such as myself, Rachel and Carol, walked out of a flawed ANSI process due to lack of transparency and faulty tension devices. In 2011, I'm sorry, in 2012, WCMA approved the 2012 ANSI standard ignoring advocates and the CPSC, and this was their fifth attempt in addressing operational cord hazards. In 2014, WCMA approved a new version with editorial changes, which was a sixth opportunity to deal with operational cords. And then in 2018, the WCMA had a seventh opportunity to address operational cord hazards, and that new standard was published, segregating stock products from custom products, allowing hazard cords to continue to be sold on all custom made products. WCMA promised to reopen the standard within six months to address hazards on custom products. So we waited three years for WCMA to announce the opening of the 2018 standard, and this is now their eighth opportunity to address operational cord hazards on custom products. So hundreds of cases of children strangling on accessible cords, the window covering industry has been given 30 years and eight opportunities to create safer products for consumers, and all of these voluntary standard processes account for an extremely slow removal of hazardous cords on window covering products. While children continue to die on cords products that their parents thought were safe, and that to me is the biggest problem because those parents thought those cords were safe, I thought they were safe. In 1996, the voluntary standards called for attention devices to be attached to the cords or beaded chain loops by manufacturers. However, the CPSC data shows hundreds of children strangled on loops and beads, many of which either did not have the safety devices attached to the wall, or they were not installed by the consumer or the installer. So the problems with the tie-down devices or the tension devices are threefold. Either the installers failed to anchor the devices, which happened to Pressley Eastburn, Jenna Holland, or Shara. They were either properly installed, but they pulled out of the wall. That happened with McKayla Cain, Silas Taylor, and Zia Poll, or the tie-down device Broke, which happened to Brandon Copbage. So using the consumer or an installer as a means to make an accessible cord safe is a historic failure. Although the window covering industry updated the standard in 2012 to render a product partially inoperable, if the devices were not installed properly, it did not remove the risk of strangulation if the cord on the device was pulled out of the wall during the incident. If the device was removed by the installer or installed improperly, there's still an accessible free-hanging loop. And that is not, to me, a reliable risk mitigation measure to rely on regular active consumer intervention to verify that the product is safe. Rather, the mandatory rules goal should set forth criteria that will make the product itself safer. Consumers need safety integrated into the window covering products that they use. So given the history of deaths on failed tie-down devices, especially the most recent cases, occurring on products that complied with the current standard during the time of the incident, I am perplexed why the WCMA did not work on effective solution eliminating the second most deadly hazardous scenario risk as it is directly associated with custom products. So as a steering committee member of the 2022 ANSI standard, I'm extremely concerned because as of now, the draft 2022 standard is removing pull cords and locking mechanisms, which is great, but they are replacing those with hazardous accessible continuous loop cords and chains, replacing one hazard for another. And I believe this to be a retrogressive safety move. This will allow for accessible hazardous loops on all products in the marketplace as it was in pre-1995, when children were strangling every two weeks on looped operating cord systems. The solution though is in the 2000 voluntary standard. Rigid cord shrouds cover the loops with hard plastic material that cannot wrap around the neck. Cord-beated restraining device prevent the creation of hazardous loops by restraining the cord in a way that the child's head cannot pass through the loop while still allowing the cord to be accessible. Requiring shrouds and restraining devices to be incorporated into the product design that extends the full length of the cord and removing the tension device requirement will eliminates the risk of both installation or non-installation failure. So it should always be a concern to the CPSC staff and the CPSC commissioners and the public when an accessible cord is allowed on products, especially if it can be foreseen that a child can wrap the cord around his or her neck. Retractable cords are accessible cords that can extend when a user pulls them. Yet tension is retained the entire time the cord is being used. So although the cord retracts when the user lets go, the strangulation risk is still possible. So when a child pulls the cord, they can turn just one time before they let go. And when they turn, that cord can squeeze around their neck. And tension is created at the top of the headrail. So this type of incident could require a caregiver to need a knife or scissors to cut that tight cord off of the child neck, giving the caregiver even less time to save that child than a regular cord that is not under that type of tension. So the industry has provided the steering committee no data, no study or examples demonstrating how retractable cords can eliminate or reduce the strangulation risk from corded window covering products. For these reasons, I am against the use of retractable cords on window covering products unless specific requirements for length and rigidity are included to prevent strangulation hazards. I support a mandatory standard for custom window coverings that eliminates the risk of strangulation to children on custom window covering products and removes the burden of consumers keeping accessible cords safe. I strongly support a mandatory safety standard that the CPSC published in the NPR. And I believe it is extremely feasible for this innovative industry to adapt to these rules quickly due to their adaption to the Canadian regulation for corded window coverings, which many manufacturers and custom work rooms are already applying. As a mom who is your living, breathing data, and I say this because I'm a survivor of child loss, I think to myself, if the commission does nothing after having all this data, the technology available to fix the product safety issue and years of stalling voluntary processes by an industry that does not put children safety first, how will this affect other safety advocates whose issues are harder than this one? Will they even try? How will the commission be looked at? Will other safety advocates try hard for their causes knowing this one has everything aligned for this rule? I plead with you, move now and implement this mandatory rule. 30 years is too long. Thank you. Thank you, Ms. Kaiser. And I thank the second panel. We'll now turn to questions from the commissioners. And let's say, I will start with you, Ms. Kaiser. You walked through a very long timeline of how we've gotten to the current situation. I was gonna ask you, but I think you talked very forcefully about your concerns about the current voluntary process and that being the one that is the only one going forward. So I would just ask again, you have concerns that the voluntary process will lead quickly to a strong result. Seems like you just were pushing us to work on our own on a mandatory standard. Just want to confirm that with you. I do not believe that the current standard that's being proposed to the steering committee is going to have a strong result. I believe it due to the continuous loop chords that are going to remain on the product. So I am in full support of the CPSC to move forward on the rule. Thank you. Turning to Mr. Vasemi, in your testimony, focus on a couple of points with respect to the 2018 voluntary standard as it relates to custom products. First, you're noting that it only has been in effect for a couple of years and state there hasn't been enough time to evaluate its effectiveness. But you're also noting that the WCMA noting sort of safety gaps has reopened the standard for reconsideration. Is it fair to say that there's a recognition that the 2018 standard is insufficient to protect children with respect to the custom lines? No, thank you for the question. We always anticipated opening the standard as technology evolved to be able to address custom products. The opening proposal for the steering committee included the elimination of free-hanging chords, both operating chords and tilt chords as an opening position. Many of the other items that have been brought up regarding retractable chords that are not exposed at the head and then also have a rigid device at the end are proposals that have been raised during the steering committee and are being incorporated. The safety of the battery for rechargeable systems and motorized systems was brought up and it's being incorporated. So the development process is not yet done but we always anticipated having as much alliance or much alignment, I should say between the custom standards requirements and the stock requirements as we could. So this is a part two from the last revision. So it seems like, yes, there are safety issues that still need to be addressed from the 2018 standard. And you've said in the testimony that you believe that voluntary standards revision process is the fastest way to address risk of strangulation from when they're covering chords. And while I'm supportive of strong voluntary standards, I do note from the testimony that we've heard that the many years and decades it's taken even to get to the 2018 standard. Non-profit organizations haven't raised concerns about working on the rulemaking and the voluntary standard at the same time. Given the sophistication of your organization and members, are you saying that your members can't work on both at the same time? Well, we're working, certainly we're working on the voluntary standard and we're providing comments to the proposed rule. The proposed rule just eliminates whole slots of products and so the ability to be able to understand where the comments might lead, certainly if that's a process as opposed to just a restatement of the current rule, it would be something that we're gonna continue to participate in of course. But we think that moving on the voluntary standard and getting these provisions adopted as quickly as possible would be the fastest way to move forward. And I appreciate everybody's participation in the process and I think that's important. But with the lives of small children at stake, it seems like all options should be pursued as quickly as possible to get to a result as quickly as possible. Whether it's getting to a good result in the voluntary standards process or getting to a mandatory rule, whatever's a faster way to make a safer work for our children is a good path forward. I'm gonna pause with my questions there and turn to my fellow commissioners. Commissioner Biacco. Thank you, Chair. Thank you all for being here. Ms. Kaiser, I'm very sorry for your loss. I can't imagine the heartache that you suffered in the situation. I think this issue in many ways is very simple. I think this issue in many ways is very complicated. But I have some very strong thoughts about this which I will express. But before I do, I do have a question for Ms. Woodcock. You mentioned there are examples of innovation that are out there right now that can address some of the concerns. Can you give me some examples of those? Spring systems are much improved. If you remember the old-fashioned spring blinds that you would pull and they would flap up in the ceiling, spring systems are incredible changes and the projection is much smaller so it fits in more places. Unfortunately, with a spring system, you have to be able to access the system by touching it, which makes it inaccessible for many windows and also it doesn't work on really large windows. Motorization has become more affordable. It is something that has changed with lithium batteries and made motorization possible without having to plug in to electricity. But then, unfortunately, with motorization, you have to recharge batteries, you have to replace batteries and that requires in many cases having to climb on a ladder. So once or twice a year, the customer, the homeowner has to be able to climb on a ladder to recharge batteries and this causes a lot of callbacks and makes it not a great choice for many customers. It's also more expensive. But seeing the innovation in my career since the standards have been implemented has been incredible and I know there'll be more and more improvements and I look forward to that and to teaching that but it's a gradual process. So, thank you, thank you for that. So as a commissioner, you come to the table with, at least for me, I try to come with a blank slate and to listen to everybody's point of view but in this case, I wanna share two situations with you which lead me to where I am right now. One, in the 90s, I had a friend who lost a child in a court accident long, long before I ever heard of the CPSC. So this issue has been around for quite some time and while I'm a very large supporter of voluntary standards because I do believe they can work, they should work and I do believe they are the fastest. If it's not in place and we're waiting 40 years since my friend lost a son, it's not an adequate standard and I'm not patient for 40 years of looking at all of these different things. I mean, I'm just not. And I know Dr. Pollock Nelson raised an issue about communications. So let me like commissioner Trump share a very ironic anecdotal situation for me. So I become confirmed as a new CPSC commissioner. I sell my house, I moved to DC, I buy a new house. I go into the blind store. I order my blinds for my bedroom and the person who waited on me proceeded to tell me how the CPSC is just the pain in the butt. Don't listen to all of these warnings. Don't take this into consideration, they're all safe. And it's that kind of confusion that the consumer is suffering. I'd like to think I wasn't confused at the time but frankly I went in there wanting those electric, motorized lines so badly but they were cost prohibitive at least for me. So here I am in this new situation having, known about this, although in 40 years ago I thought it was a freak accident. And when I get here much later in time, we learned that it isn't a freak accident, that it happens more times than it should. And so with all of that background, I have to say that I'm not patient for any more, let's get together again and let's try this and let's try that. As you pointed out, Ms. Woodcock and I think Mr. Vosamy also mentioned, there's been a lot of technology that's evolved. There's been a lot of innovation that's evolved over a time that I didn't even start law school yet and now here I am. So I just don't have the patience for that. I think it's time to move on. Is the mandatory standard here going to be perfect? None of these situations are perfect. You can't make a foolproof, flawless product. I mean, it's just the nature of the beast. I think that I was not here when the stock and common type of blinds was broken into segments. I question the prudency of that. I question whether or not the industry could have taken steps. You guys have known about this for years. And so to suggest at this stage that they need more time, I'm not receptive. I'm sorry, I'm not receptive to that for all of these reasons. So I don't wanna see anybody go out of business. I don't wanna see costs go up for consumers significantly. I don't wanna seek any of that. But when I take into consideration everything I heard today, everything I heard is a CPSC commissioner. Everything I've heard is a consumer and a human being walking this earth. I have to side on the mandatory standard. It's time to move forward. So if you can make it faster, get it done, get it done. But until then, I think it's long overdue for the CPSC to move forward on this issue. Thank you. Thank you, commissioner. Commissioner Feldman. Thank you, Mr. Chairman. Again, specifically to Ms. Kaiser, I wanna say and express my condolences for your loss, but also to say thank you for your advocacy and to everybody that appeared today to testify in front of the commission. Thank you for being here and for testifying. As I said at the end of the first panel, these incidents involving operating court strangulation are tragic and have remained unresolved for too long. I'm glad to see this process move forward. Again, I wanna thank the witnesses for their testimony. I have no questions at this time and would yield back the balance of my time. Thank you, commissioner. Commissioner Trumka. Thank you, Mr. Chair. Mr. Basami, you're the executive director of the Window Covering Manufacturers Association. How many manufacturers does your group represent? We represent 35 or 40. How many people are on your board of directors? We have four on our board of directors. And I understand that's not a full-time job, a board member there. So what companies do your board members work for in their day jobs? Our board members work for Hunter Douglas, Levolor, Roles, Akmeda, and Springs Window Fashions. Thank you. And do those line up with the member companies that provide the most financial support to your organization through dues or fees? Yes, they do. But those companies have been represented for quite some time. Thank you. Thank you. So WCMA oversees the development of the voluntary standards for your industry. And Ms. Pollack Nelson, in her written testimony, helpfully pointed out that industries note about the court's regulation risk since at least 1983. For the 13 years that followed that, there were no voluntary standards. And then the first ones produced in 1996 after 1995 requests from CPSA. Mr. Basami did the 1996 voluntary standard eliminate accessible cords that could become wrapped around a child's neck. And did it do that for all window coverings from that point forward? I wasn't there at that time, but no commissioner did not. Thank you. And so CPSC again asked industry to strengthen that standard. Did industries 2002 update eliminate accessible cords that could become wrapped around a child's neck from all window coverings from that point forward? Not from all window coverings. Thank you. So CPSC agreed with that. And it again asked industry to approve the standard. You started at WCMA in 2005. So you were around for the 2007 update. Did that one eliminate accessible cords that could become wrapped around a child's neck from all window coverings from that point forward? Not completely no. In 2009, another 14 children died by court's regulation and 34 additional children almost died by strangulation. That was 26 years after industry was first made aware of court's strangulation. In 2010, CPSC held a public meeting about window coverings and WCMA announced that it would quote, establish a steering committee and oversee six task groups that would study the issue. That year, there were another 11 fatal strangulations and 20 near miss strangulations. In 2011, WCMA proposed more visions to the voluntary standard. And then the 2011 update eliminated accessible cords that could become wrapped around a child's neck from all window coverings going forward. Not on all window coverings. By 2012, at least 39 children had been strangled to death by courted window coverings. CPSC again asked WCMA to address the hazard. The WCMA's 2012 update to the voluntary standard eliminated accessible cords that could become wrapped around a child's neck and did it do that for all window coverings going forward? No, the 2010 and 2012 was focused on removing the inter-court strangulation hazard with the development of the accessibility test and the hazardous loop test. That was developed in conjunction with CPSC with advocates as well as labs to eliminate the hazard associated with inter-court. Thank you. So now it didn't eliminate it for all cords going forward. In 2014, CPSC requested now for a six-time to WCMA address the hazard, which at that time had killed at least 53 children. With no action by 2017, CPSC began its process and that year, WCMA hosted numerous steering committee meetings. By that time, at least 78 children had been strangled to death by courted window coverings. In 2018, WCMA published a new voluntary standard. It did eliminate pre-hanging universal loop cords, but only for the stock window coverings, my custom, which make up almost half the market. Mr. Visami, in your written testimony, you said that if CPSC finalizes a rule, and you said that again here today for custom window coverings, it goes into effect six months after it's published, it would be, quote, impossible to design and implement suitable replacements, meaning that there would not be product available by the end of this year. So, Mr. Visami, I just want to make sure I understand. Your position is that industry hasn't had enough time to design and implement safer alternatives, despite knowing about the risk of 40 years and despite 30 years of repeated requests from CPSC that you adequately address the risk through voluntary standards. No, sir, that's not my assertion. My assertion is that the elimination of complete systems, the retractable court system has not had any incidents on it. It would not be allowed. Mr. Visami, I appreciate that, but it was a rhetorical question. The group's been working on voluntary standards for decades. And in just one subset of that time, 2009 to 2019, over 200 children were either fatally strangled or near fatally strangled. As a 501-C69 profit, WCMA publicly files its 990s, and those forms do list you as executive director, but they don't have a line item for your salary like there would typically be on a 990. But WCMA's biggest expense of almost half a million dollars per year is paid to a contractor called the Kellen Company. Mr. Visami, what's your position with the Kellen Company? I'm the president of the Kellen Company. Thank you. Is you or is Kellen Company's compensation affected in any way by whether a mandatory standard is delayed or avoided? No. Good. One of your justifications for continued delay that you discussed today is that you want more time to see if your old voluntary standard from 2018 suddenly fixes the problem. But as we see deaths continue, I want to know where you would draw the line for success or failure on that. And specifically, how many more children would have to be strangled to death for you to consider that voluntary standard from 2018 for custom products in effect? Commissioner First, let me say that we recognize the tragedy that these kinds of accidents and strangulations cause. And believe me, we don't take this lightly. We have my comment regarding the 2018 standard was specific to the point in the proposed rulemaking that the assertion that it's inadequate. We recognize that we need to continue to move forward and that's why we've reopened the standard and that's why we've eliminated in our first proposal, we've eliminated free-hanging cords and tilt cords, which account for the majority of incidents over the years. And so those would be eliminated. There's been some discussion and some proposals that have come up regarding limiting the use of continuous loop cords to certain products only. That came up at the last steering committee and those issues are being addressed and will be addressed as well. And I thank you for that context. But when you're measuring the success or an effectiveness of something, you have to have a measure in mind. And I'm asking you what the number is for debts before you would gauge that in effective. Is there a number? No, there's not a number, sir. I don't know how anyone eliminates has been said, eliminates all risk. But for sure, we don't have a number that is a go-no-go acceptable or not. No, it's not. So you'd rather wait and see on that. Fair enough. Mr. Chair, I assume I'm running out of post to my time. I will have a second round, but I'll yield back for now if that's all right. Thank you, commissioner. I don't, do any of the other commissioners questions for a second round? Does not appear so. So I go back to you, Mr. Schruka. Thank you very much. So Mr. Visami stock products have been complying with the voluntary standards since 2018. How much of the costs record this operating system components drop since then? I don't know. We don't capture that data, sir. You know, so even if you could check with your members on that, I bet they would have that information. And if you would be willing to share that information with commission staff, I think it would be very helpful, particularly if you could do that within the next seven days. And you commit to trying to do that. Sure. Yes, sir. Thank you. How many custom courted products were sold in the last three years? I don't know the, the answer to that. I don't have a, I don't have a way of measuring that. Do you have a sense even as a percent of civil sales, what you think they make up? Yes. From, from, from the, from the information that I have from, from, from our members and other, other, manage other retailers. Custom products are somewhere in the neighborhood of 20% of the total market stock products are 80% of the total market. Would you submit also to, to commission staff, the information that you have on that topic in the next seven days, please. I will submit it. Can't promise seven days, sir, but I will submit it. Thank you. How many custom courted products do you think are currently in use? I don't, I don't have any way of really knowing that. And, and, you know, there are, there are custom products that have been in use for, you know, for many years. And, you know, there are, there are a significant number of, of window coverings out there. So I wouldn't have any way of really giving you an honest answer as to what, how many custom versus stock products are out there. Total. I mean, do you have a sense of percentage? Again, I would, I would, I would say that if the market is selling on an annual basis, 80% stock and 20% custom, then 20% of the, of the installed base somewhere in that neighborhood, 20, 25% would be custom. Okay. So that's been consistent over time then the, the 80, 20. It has been. Okay. So if you do have any additional information to add there, I'd also appreciate if you could submit that to staff as well. Yes. Okay. You did mention people with disabilities could be harmed by the proposed rule. And I saw that in your written testimony as well. Obviously our staff disagrees. They put it out a number of accessibility options that are on the market. Which organizations representing people with disabilities? Did you consult and arriving at your assertion? Well, we've, we've, you know, we've, we've worked with veterans with disabilities. We've worked with some other organizations in the past to, to just ask them for their input on how, you know, on how they would recommend that products that don't have operating cords or a motorized system be operated by, you know, by, by people in a, in a wheelchair, for instance, or with limited range range of motion or grasping. You also said that there are no viable option or no viable replacements for courted custom window coverings that the whole market might evaporate if we issue this rule. Isn't your testimony to the commission that there's no, or those custom window coverings on the market? No, no. And that is not my assertion. My assertion is that there are over 20 varieties, categories of custom products currently on the market over 20 varieties. There are probably cordless operating systems, as has been mentioned and as has been acknowledged. There's probably cord cordless operating systems for the majority of those, if not all of them. The difficulty is that there is not a cordless operating system for every product configuration within those 21 categories. And so as I, as I qualified, whether it's size, whether it's weight, whether it is location in the, of its installation, those are the, those are the areas where a, what would be adaptable to a custom product in a cordless operating system would not be once you got to a certain segment of the product category. So that certain segment of the product category. I'm interested in that too. And I think Miss, Miss Kaiser, you pointed out a very useful point. There's a Canadian rule that was published in 2019. And it's quite similar to CPSC's proposed rule. And the company is Mr. Visami that you represent. They seem to have had three years to think about how to make products that comply with Canada's rule. So companies that sell in Canada do sell in the US and vice versa. And so that would be very useful going forward, I think for those companies now that face. I don't have any further questions. I thank you all very much for your time. Thank you to the commissioner. And thank you to the panel for, for testifying today. Especially Miss Kaiser, who I know that this is not an easy process at all. So I appreciate you're sharing your views and your story. Testimony, all of your testimony has been instructive. And I'm sure it'll help us and the staff as we move forward with the final rulemaking package. And again, I would encourage everyone who has testified as well as all of people in the public generally to comment in the proceeding for all written comments in the proceeding. And with that, the hearing is adjourned. Thank you. Thank you. Thank you.