 Good afternoon and thank you all for attending this open and public meeting between the window covering industry and CPSC staff. I am Dr. George Borlase, the head of the Office of Hazard Identification and Reduction, and I'm very pleased to welcome everyone to CPSC's National Product Test and Evaluation Center here in Rockville, Maryland. This meeting was requested by Mr. Ed Krennicke of Bracewell, and we are here today to discuss technologies currently available on window coverings and recent developments in window covering technology and design that reduce the risk of strangulation of young children from courted window coverings. I'd like to thank the WCMA, Window Covering Manufacturers Association, for the June 29, 2016 press release announcing that they initiated the process to revise the current voluntary window covering safety standard to effectively address the strangulation risk to children from products with accessible courts. CPSC staff, industry members at the table here today, and many of the audience members have been active participants in this voluntary standard activity, and CPSC staff look forward to working closely with everyone to develop an effective voluntary standard. The purpose of today's meeting is for CPSC staff to learn more about the ongoing industry innovations and new product development within the window covering industry, and to hear from the industry how they plan to bring these new products and approaches to the voluntary standard meetings once they are initiated by the Window Covering Manufacturers Association. Today's discussion will be focused on the industry's work and how it will be brought to the voluntary standard meetings, but we will not be focused on specific voluntary standard changes. Those discussions will take place in the appropriate voluntary standard meetings led by the Standards Development Organizer, WCMA. Before I get to introductions and start the presentations, I'd like to go over some housekeeping and rules for today's meeting. First, in case of a fire or some other emergency, please quickly exit through the front doors that are behind some of you and front of others of you, the doors you came in, and assemble in the parking lot when you come out to your left closest to Interstate 270. If we do need to evacuate, it is essential everyone assemble outside, please, so we can make sure everyone is accounted for. Second, bathrooms are available right here to my left behind many of you at the end of the hall, here and through the double doors. You do not need to pass or an escort to access the bathrooms. You can pass through the double doors to get to the bathrooms. Third, please remember to silence your cell phones, place them on vibrate, or please turn them off. I will note that while they are nearby, there are no Pokemon here in the building, so please don't feel compelled to check your Pokemon Go account. Thank you for bearing with them. I've got so many papers here. I'm trying to figure out which ones which. These meeting between the window covering industry engineers and CPSC staff was requested by Mr. Ed Krennic, and the presentations and discussions will be limited to those seated at the table. I ask that all audience members respect the meeting requests and hold all comments and questions. For those on the phone, while we did mute it, please just be aware of that and you could place your phone on mute also. Today's open meeting is being videotaped, and the video will be available on the CPSC website no later than one week from Friday. I would like to thank some of our guests and members of the public for joining us today, including Commissioner Robinson and Mr. Tyler Goodyear from Health Canada. Thank you for bearing with me on the admin items, and I'm thrilled to have this panel assembled today and to have this technical meeting. We have four representatives in the window covering industry. Mr. Tom Merker from Springs Window Fashions, Mr. Jim Anthony from Hunter Douglas, Mr. Jeff Stout from Newell Rubbermaid, Mr. Derek Marsh from Rollies, good to see you all again gentlemen, and we're also joined by Mr. Ralph Fasame, Executive Director of the WCMA. Participating of CPSC staff, myself, Dr. Joel Rekt, Director for Engineering Sciences, Mr. Mark Kumagai, Director for the Division of Mechanical and Combustion Engineering, Dr. Rana Balsicina, the Director for the Division of Human Factors, and Mr. Kevin Lee, a mechanical engineer with Mr. Kumagai's division. Again, thank you everybody for attending, and without any further delay, I'm going to turn it over to our presenters. Thank you George, and good afternoon everyone. Also on our part, thank you very much for agreeing to meet with us today. As you have noted, we have announced the opening of the standard. We wanted to make sure that we were able to have an opportunity to cover today the scope, the objectives of that standard, and some of the activities that we intend to bring to the standard development process once our meetings begin. First and foremost, our purpose here today is to review the objectives for the standard development process and make sure that the scope is well understood, to review the standard development process that we'll be utilizing, just refresh, to review some recent advancements and some of the possible approaches in standard development, and to review next steps and timelines. Some of the trends that we have witnessed and noticed in terms of just the U.S. Census Bureau trends, we've seen the continued increase in household formation, household and home sales are going up, so we know that there's going to be a continued growth in the number of windows and therefore the number of window coverings. We've noticed the growth in the population, zero to five years old, had a rapid increase up until about 2008 and 2009. It then has started to peak a little bit, but it still points to a very, very large amount of consumer interaction with window coverings and we believe that that will continue to grow. So we understand that what we're looking at from a demographic standpoint is increased opportunities for consumers to be engaged with window coverings. Tommy, you want to talk a little bit about some of the product trends? As far as product trends go, we've seen growth in cordless sales. Some categories in shades like cellular Roman, excuse me, where you already have a high percent of cordless, that continues to grow in 20, 30 percent over the last four to five years. And in categories that are like horizontals, which are a vast majority of the products that are made today, that is a smaller category in terms of cordless, very mature product category, so you don't see as much penetration in the cordless option, but we've seen a lot more growth in high percentages, 50 percent, 100 percent growth, but again it's on a small segment of the business. One of the other important factors that we've seen in shaping the trends that are looking forward on window coverings and consumer choice, certainly about a year, a little over a year ago, WCMA announced its Best for Kids program. And the Best for Kids program was a set of criteria that were above and beyond the standards requirements that were specifically designed to allow manufacturers and retailers and most of all consumers to easily select window coverings that were best suited for homes with young children. And the acceptance of that by all three of those stakeholder groups has been very, very good. Over 35 to 40 companies have already signed up, manufacturing companies representing thousands and thousands of products that are looking and using the Best for Kids. It requires a third party testing. It requires labeling and a retesting provision, but most importantly it provides an opportunity for consumers to be able to choose products that are best suited for homes with children. Now, what has that done? From a technical standpoint it has certainly driven manufacturers to produce products to meet those criteria or develop products that can meet those criteria. It is caught on with retailers and retailers are now requesting of manufacturers that their suppliers qualify and have products that qualify with Best for Kids criteria. And it has also allowed consumers to recognize those products in a simpler fashion and retailers really to promote them. So from an awareness standpoint that's been important, but also it's a driver not only of consumer behavior, but it's become a driver of manufacturers and retailers as well. So we think that that's an important point and has an impact now on the kinds of products that retailers will be asking for and manufacturers will be looking to sell. We do anticipate as products evolve we started the Best for Kids program with some very stringent criteria, some very narrow criteria. We recognize now that there have been advancements in cord covers and cord control devices. There's also some advancements in retractables and short cords. And so we need to look at how we can refine the criteria for Best for Kids so that they can also, these new innovations that manufacturers are coming up with can also be incorporated in that program. And we hope that those kinds of criteria are the kinds of things that we'll be able to bring also into the voluntary standard requirements. Okay, we also, and I think now we wanted to talk a little bit each of the manufacturers about some of the things that they're working on to try to also move forward in that direction. Sure, no problem. So our business, Rowley's ECMETA, we've since our last meeting grown, merged with a company based in Australia. And in Australia they also have child safety issues as you might imagine. And we have a dedicated innovation and design center, probably houses more engineers than any other business in our industry other than some of the folks who are represented here. And so ever since that transaction and even predating it, so call it two years ago, there are two themes that define every single new product development project in our company has to be child safe. And it has to be oriented toward energy management. Energy management really by definition means it's going to be child safe because you need to take human behavior out of the equation. So it's motorized. All right, so to have a true energy efficient system installed in a building means it's motorized. You're not requiring human beings to operate it. So every single new product development project in our company has to get approved by me and pass this very simple criteria. So we've been spending a lot of time, a lot of money on these issues, have for years, but now it's the sole focus of the company. And one of the things you, a couple product categories you heard about from Ralph, and I brought just a couple of examples because they mean different things to different people. And I just want to make sure that maybe you can get your mind around what we mean by a shrouded or covered cord because it means different things to different people. What I didn't bring an example of though, which is it started from a very small base, but the increase in this product category is truly remarkable, especially for a business or an industry that didn't move all that rapidly for many years. And that's motorization and automation. So as you're seeing everyone in a home wanting lights and thermostats and security systems, door locks, they all talk to each other now, maybe through your iPhone, but it's that that integration is happening extremely rapidly. Part of it, some people call it the Internet of Things trend, but the features in a home that talk to each other really don't do a whole lot of good if they can't talk to the window coverings as well. So your thermostat is, it may be an efficient thermostat like a nest that you're telling to not cool the house from 3000 miles away, but if you can't lower the window coverings, it's just going to have marginal impact because it's got to run at a certain level. So I didn't show you the motors, but we can see from our angle and I'm just, I'm sure everyone at this table is seeing the same thing and that is a dramatic rise in motorized product. And as you might expect, what that means, there's been a dramatic fall in costs, because part of the issue we always have in this industry is scale. You know, you have an infinite number of combinations of product that can be made on the custom side. And, you know, it's very difficult to have a one-size-fits-all solution. It's not something that you can just put on a shelf in it. You can make a few million of them and they sell. So, you know, we're finally starting to see some of the benefits of that. It's not going to happen overnight, but it's definitely happening. So on the manual side, I did bring two examples. I'll stand if that's okay. So when you talk about this right here is a, is what we call clutch, and it, it rotates and will move something up and down. You know, this happens to be one that goes into a roller shade. You have different configurations for cellular for Roman and other products, but the idea is exactly the same. So you have a continuous loop that's coming out, which is a topic of many discussions amongst people in this room. And so, you know, the, the discussion when we talk about shrouding or containing the cord is, you know, how do you put a loop, usually a loop, inside of a wand that encloses it. You're going to have to have an opening because you need a way to access or touch this thing to drive it. And so you've got a wand now that covers it, so it's not accessible. You need to keep the, the chain or the loop inside. And so you can't just take a pipe as some people have and attach it to a loop and call it good. Okay. So there's a spring down here that applies constant tension. There's a wheel right there that makes sure that this doesn't fall out when they're slack. All right. So even though it looks very simple, one, two, three, four, five, six, seven, eight, eight parts plus the wand in order to make something like this and has to get assembled. It has to get assembled to size because, you know, up here, you don't want that opening to be big enough to allow a head to fit through it, obviously. So if your window starts up there, this wouldn't be very appropriate because you can't reach it. Okay. So you're going to need a longer wand. You're going to need the ability to cut it down sometimes or have multiple sizes, certainly, because this right here is going to drive the length of the wand, including the, where's the top of the window? Because that's, you know, how you're operating your shade. So other than that, it's actually a very simple straight forward product. I mean, this then goes on the side of the window covering. There's a handle right here and there's a small engagement point that will grab the balls and then you just operate the shade like that. Okay. And we've got an ADA compliant version, which is a little bit bigger down here. So, you know, you can grab it because you do need to apply a fair bit of pressure. This is a metal ball and it doesn't tend to go through as quickly. It makes a bit more noise. Noise is a big issue. But this is a direction that our company has decided to go. It'll be available for sale and use within the next 60 days or so. But it's one way of covering a continuous loop and allowing the operation. The other kind of product that you've heard about is a retractable. And, you know, what we've, and this is also, by the way, in production and will be available on a commercial basis, certainly within 90 days. But just so, I think last time we were here, we attempted to show some of the complexity of products like this. So you need, because at the end of the day, you're retracting and this goes back up. So you always have tension on the cord. And when this is released, you don't have any exposed cord. And I think most people in prior discussions agree when there's tension on the cord like that, the likelihood of forming a hazardous loop is low. But in order to allow this to retract means that you have a very highly engineered clock spring in here that allows the gathering of the cord. So that's one spring. It's very difficult to make. Because we need to be able to have this work. Some windows get 120, 130 degrees. And we need it to also work when it gets down close to freezing. And that impacts metal differently. Spring steel is what we'd be using in here. So this product, we have to have it work for 10,000 up and down cycles. We don't want to sell it otherwise because then it just comes back. And consumers, especially in this country, sort of ride these kinds of products hard. You have to assume they're not going to use it in a delicate manner. So we need it not to break because that obviously creates other issues. We can't have this thing dangling on the ground because we've lost tension in the clock spring. So then we have another spring in here. Because what you're doing is you're lowering the shade and you're putting energy inside of a spring in here. Now depending on the size of the window covering, you need a different size spring. So anywhere from 10 to 20 inches of spring in here that you load when you're lowering the shade. So right now energy is going in and you release it and the energy is being released. So that means you've got to be able to properly assess based on the weight of the fabric, the weight of the bottom bar, the size of the shade, how big that spring needs to be. And again, it's got to work 10,000 times up and down. And it has to work in severe temperatures. Then you move over here and you have to have the ability for this to stop where you want it to stop on the top. So I've set it for right here. But depending on your window, you might want it to go all the way up or you might want it to be a bit lower. It really just depends on what's at the top of your window, what your preferences are. You might want a permanent privacy setting for people who are looking in at a certain angle. So what you have in here then is a break and a stop mechanism because if it flies up too fast, it's going to destroy the window covering pretty quickly. So it goes up in a very slow and controlled manner. If it flies up, it'll break because you're just slamming metal together. You're slamming plastic together. And I think most of us, at least in childhood in schools, saw what happens to those kinds of window coverings. They're basically viewed as a disposable product because it will break. We can't let this break. So over here, there's a break and there's a stop because you've got to figure out where you want it to stop on the top. So there's a lot more going on in here than you can see. And frankly, at this point, this product is getting from a cost standpoint, forget about selling price, from a cost standpoint very close to a low-end motor system. As I said, that's kind of coming down. So for our business anyway, this directionally is about as far as we're going to be going, at least based on what we're seeing from a mechanical standpoint. Then we're really trying to drive down cost and accessibility and usability on the motor side. So this is our product category. Oops, sorry. And you can do these in double shades too, privacy and sun control. Yes. Is that for a new product? Is the one for a retrofit or for a new product? So it was designed for new product because we want to make sure that this opening right here is the proper size. If you are trying to install it on an after-the-fact basis, you might be relying on the consumer to determine how long this is. But because you figure here's, if it's a roller shade, it's coming out this way. This way you can ship it like that because shipping is obviously an issue. But this product here would get made in 16-19 foot lengths and you cut it down to size depending on where the top of the window is and what the consumer wants. So like in some countries, they talk about the bottom of a loop being over a certain level. But that means you're reaching like that. Even I'm reaching like that. I'm not very tall, but there are plenty of folks shorter than I am. So this product lets it come down to here, which is a more natural way of operating anything, including a shade. Is there any current products out there that would be a retrofit for the current horizontal blinds for the cords? There's a product available. It doesn't work very well. So we're not promoting it yet. This for us was a more important direction to tackle first. Let's see how it works. Let's see what the acceptance is. Derek, I was wondering if you could take maybe an extra minute or two to talk about, you were talking about the size of the window kind of became a limiting factor. If you could talk, it doesn't have to be the eighth of an inch, but about how tall was the window or how wide was the window or what became the limits on the wand in terms of maybe height, width, weight, or material or type? Sure. No problem. So you've got to look at the retractable device differently because that's got the spring systems in them. And it really, for us, stopped becoming usable, predictable, cost effective at about 10 feet by 10 feet. So that'll cover 90 plus percent of windows, but doesn't cover all of them. This wand, on the other hand, we've got about 50 different, well, if I take color out of the equation, we probably have 20 different clutches. They're geared, they're spring assisted, they're bigger. So you can really get, with a manual system, if you're spring assisted and using this, you could frankly go as wide as 25 by 10. So it's massive. I mean, at that point, you're into the thousands of dollars and you're going to use a motor, well, more than likely use a motor. But this doesn't prohibit you from a size perspective because you work on this side of it here. So you get your mechanical advantage and you get a larger pulley driving a smaller tube or you spring assist it. And then all this is doing is rotating the chain. So anything you can do with the chain today, you can do with this or a continuous loop. So it won't work with cord. Cord is too hard to grab. Continuous cord loop, but that's a pretty small part of the segment. The cord retracting device, would that work for conventional operating system or only for rollers? When you say conventional operating system, you mean like a cord lock system? Yes. That could, absolutely, it could drive up what I call a mini blind or a horizontal shade. Yep, it can do a Roman shade. It can do a cellular shade. I mean, I just happen to show it on a configuration for roller shade, which is a predominant product category for us. I would add to that simply stating that the internal operating system is different if you're raising a roller shade versus raising a blind. So you have to put components that don't exist today in some means for wrapping up cord to use a retractable system with that type of product. I'd just like to add on to that because Hunter Douglas has ones for cellular and for blinds as well. Retractable cords. Exists, it's being sold today. Yeah, they exist. I guess going back towards the beginning, Derek, when you were talking about the two things that Rolex looks for, energy management and then child safe, how does your company define child safe? And I guess I was looking at it maybe from what are your performance requirements because I think that might be something that might be of interest then as we're looking down the road on performance requirements, vice design requirements. So I was wondering how does your company define child safe then? What are the other performance requirements associated with that that perhaps would be of interest? There are. I mean, first and foremost, we look to the current standards and our view is to the extent it goes beyond the standard, it gives us an edge of some sort. We know from, as you heard before, that retailers are beginning to demand different solutions. So it really helps that it's being there's a pull as opposed to a push. It's very difficult to push something on a customer that maybe isn't interested in buying and certainly in paying more. But ultimately, if it's being pulled through by the end consumer or the retailer, it sure makes life a little bit easier. So now there's a slightly different dynamic in the industry in that regard. So how do we define it? I don't have a written clear set of instructions and I don't want to say I know it when I see it. It's not something along those lines, but for us it's above and beyond the current set of standards. Now that's for new products. So we still sell this product with a chain and a tension device. I'll call it a mass market product. It's in significant demand and it definitely works when the tension device is installed. It's safe. But new products that have come out are above and beyond that. No other questions for Derek. Talk a little bit from a spring's window fashions perspective. So we recognize that common barriers to product in the marketplace around cordless motorization really cost is number one. Size limits are another. When you think about more complex systems like cordless motorized even clutch systems, the retractable cords, there's far more components involved and there is a direct relationship between complexity and reliability. I mean a perceived correlation between those things. So typically higher complexity can result in more remakes or more failures to the field. Derek had commented about the use. People operate window coverings in America and they have to be very robust in their design. Considering that when we go to market with a product like a cordless product, the product today for custom is built around a very broad spectrum of fabrics and colors because this is a fashion industry. And so that also contributes to complexity. So when we look at new development we're very focused on motorization of course because we believe that there's a lot of future with motorization as overcoming some of these barriers but still cost is very high. But we're looking at how do we cost reduce current cordless systems. So we're driving towards OPP type product so that that will narrow the field so it may have limitations on the breadth of the product that's being offered and the sizes. I'm sorry Tom did you say OPP? Oh I'm sorry I used an acronym OPP is opening price point. So it's trying to bring to market lower cost product and that's done through value engineering analysis and applying lean methodologies to product design. So you know where you have fasteners and assembly points you work at trying to eliminate those into more snap fit versus a fastener or that type of thing. Reduce the number of components you reduce the cost and the labor that goes into putting those systems together. We've seen cordless grow within our business significantly over the years we introduced cordless into cellular around 2002 and we've been applying it to every one of our product lines since that time and we've seen growth go from the 5 to 10 percent penetration to well over 60 percent. So we continue to see a lot of growth in those products as cordless. So we we're heavily engaged in the value analysis that goes on in redesigning of products and new systems. What would the price point be for a value I guess a low end cordless system? How much would that cost for the consumer? Well it's a little difficult to put a price tag on things because it's usually viewed as a percent of product cost and entry level type products can be anywhere from 20 percent minimum to 50 percent of the product cost as a cordless. So it's a very wide range it really depends on the base product that you're trying to apply this operating system to. I'd like to take an opportunity to answer the question too about safety as it was asked about you know what do we use for criteria. We rely heavily on the safety standard and looking beyond that too. So there are some products that we would evaluate that might pass the standard as it's written but we might see that there's you know possible misuse or improper use of products so we try to design around that as well but that really becomes the central point when we're doing design work we have a stage gate process that we follow and we do technical reviews and we review all requirements for product not just the fashion elements but also the safety and so we take those into consideration and they must pass those requirements the safety standing being the primary one that we give strong consideration to through the design process. Any questions for me? You mentioned over 60 percent cordless does it refer to the cellular or honeycomb? That's primarily cellular yes we've seen a lot of growth in other product categories as I mentioned earlier you have some mature categories like horizontals where being very mature they're more commodity price driven as far as consumers making choices and you use we've seen a lot of growth in the cordless option but still a lot of growth on a small percent isn't significant to the overall but shades and keep in mind too that you know the basic difference between blinds and shades blinds are like horizontals where you have a louver so they're not operated up and down as often as a shade would be because a shade in order to manage light and privacy you have to fully operate it but with a horizontal blind or a vertical blind all you have to do is tilt or rotate the louvers and so there's less of an incentive to add cost into a product as simple as that to make it cordless. Any other questions for me? Well on the on the horizontals I mean from what we had in our ANPR even we know from the data that a lot of the strangulations unfortunately occur with horizontals so I guess when we're looking at it you know what are you know what are the opportunities or what are there to go towards something and I'm not saying cordless specifically but you know what are the opportunities with horizontal blinds to specifically address exposed operating cords you know keeping not trying to get design specific but I guess you know at a broader sense what are some of the opportunities there then hearing what you're saying about it's growing but it's a small percent to start. It's still from from our perspective trying to add complexity to those systems is very expensive not in just from you know the parts that you're putting in but to the end and consumer and you know it's hard to overcome something as simple as a cord lock because you're you're literally looking at 25 cents or maybe even less than that to manage the cord control so that becomes a huge challenge you know how do you how do you look at that and change it cover the cords we've seen operating systems that have been introduced that do that and quite honestly from my experience they're difficult to retrofit and they're difficult to operate and that becomes a barrier as well I mean when a consumer goes to purchase window coverings it's a it can be a very big decision for them financially and to think that they could be replacing 20 window coverings in the house easily um it just magnifies with that additional cost throughout so it just becomes a very big challenge as to how do you how do you replace those types of operating systems there are systems like retractable cords that can be fitted but you're adding a lot of complexity to that system did I answer your question you did I mean I guess so from hearing there's almost like a step function increase in terms of if you're addressing it from horizontal for horizontal blinds there's not a small tweak or change to go from removing an exposed or accessible operating cord you're looking at a large step increase if you will in complexity in my mind you are and that's where our focus has been is that we're focused on on cordless systems we're revising for better reliability revising for lower cost those are the focus points for us motorization still it's a hard sell into that type of product because of it being more like a commodity is um I mean some of these these retrofitter devices that will cover the cord and allow you to operate at the operating cord costs more than the underlying product itself almost sometimes a factor of two so that's some of the challenge that that time was just referring to but but George I think from an overall standpoint not to get maybe company specific here but what I'm being told from from various excuse me various members is that they're looking at to control the cords on a typical you know single cord or whatever multi-cord cord lock system they're looking at a true cordless system they're looking at shrouds and or retractable to make the cord inaccessible and they're looking at some combination of technology to use a cordless system with a short cord so from a from a from an umbrella standpoint those are the kinds of areas that the investigation is going on and it may it may be different for different types of products but if you can't go without an operating cord then how do you cover it or how do you shorten it or how do you attract it any other questions for me not that you can't ask a question later I'll answer it but I was going to ask whether you see any trends in terms of the horizontal blind sales is it as prominent as before is it increasing or decreasing no no as far as the category of horizontal blinds now I I don't believe that that's a growing category there are other product categories that are on a you know a trend trending up on terms of sales horizontal is is really almost I don't want to say restricted to commercial but that's where a lot of the business has been it's very simple solution for for many consumers to pick a horizontal blind but shades for instance is one that is kind of taking market away from products like horizontals and that's because of the again it's a fashion-driven industry and so it all there's a lot of energy related benefits that you get from you know solar roller shades that tend to be replacing those types of horizontal products in the marketplace all right thank you thanks Tom so following Derek and Tom we're going to talk about a lot of the same things we're focused on three areas motorization retractable cords and cordless systems that's our main thrust at this point a lot of it is cost reductions as they both mentioned they're all expensive systems we're increasing the cost on all of them by putting those lift systems in the shades with regard to horizontals we do have a retractable cord device that pumps up the horizontal blind whether it be a wood blind or a metal blind but frankly people don't raise and lower them very much so it's hard for them to justify the extra cost you put a $25 motor in there a spring motor and then you never use it so it does take the cords away but it doesn't really get used very often so basically we designed it engineered it built it and then a lot of people aren't buying it that's the end result last year we launched our power view motorization product which is through your cell phone home automation systems across all of our product lines and so that's selling really well our job right now is to cost reduce that so that a lot more people can afford it working on other motorization systems for tilting for horizontal blinds those kinds of applications so you get rid of those tilt cords or even the wand that people don't like now mostly it is re-engineering the things that we've engineered in the past like they said take the fabrication labor out have snap fits rather than screws I think you guys saw those storyboards I put together before with all the complication all the different parts on them we're trying to take a lot of that complexity out there's also governors when you click it and walk away the shade you don't want it to just fall like a rock so you have to govern the load as it comes down trying to reduce the cost of those governors so there's a lot of tooling involved there's a lot of engineering involved and testing getting on to the testing as well we have a stage gate process as well we rely on the standard heavily we've got a test lab that goes through the standard with the head probe testing the hazardous loop testing accessibility testing we got uv exposure impact testing all those things that are in the standard we test in our lab lead testing even and it's in our quality process that child safety is one of those criteria that a product doesn't go out into the market unless it passes all those tests so since similar question so for hunter-duckless when you say when you say child safety how does hunter-duckless define child safety as one of the requirements before it goes out well the the current thrust is to get rid of cords completely as far as lift systems with being spring assist retractable cord driven and motorization and at this point we're not launching any new products with those the cord locks we've got multiple products on the agenda and none of those have cord locks as the part of the plan can you can you expand on that just so i make sure i got it so from hunter-duckless's perspective all new products being launched don't have an accessible corded with them um i would just say cord locks or cord cord locks okay so what what maybe help me visualize because multiple cords coming out of the head rail to a joiner and then maybe a single pole cord afterward we're not launching any new products with that so what does still have a cord then in our product line i'm just trying to make sure i get the scope there's some legacy products still that have those cords in in them and we're delgently working to try to replace those with new solutions too so i'm not on those teams but i know that that's the um the rest of the company is to get rid of those do you have any demos not right now okay derrick brought props so i thought maybe other people brought props too i was thinking about it but i'd have to pack my suitcase full of them so i didn't okay jeff stout with level or window fashions and we face uh we face a lot of the same challenges as everybody else so the complexity of the cordless systems um working to really cost reduce that um we've tried multiple solutions over the years we've taken a lot of products to consumer research um what we've typically found out is consumers lack the simple operation that they're always used to they don't like uh some gimmick operation they prefer a standard product and they prefer it to be as low cost as possible and so we put a lot of our focus on reducing the complexity of the systems to reduce the cost of the systems and to try and bring the the added cost of the cordless systems in line with what they would more typically be paying for a corded system um so that's a lot of our engineering effort we operate very similar to most of these folks stagegate engineering system we have our own internal test lab um you know we work we partner with uh companies across the globe on development um it's uh it's uh one of our key focuses obviously is to try and have the best solution the most reliable solution at the lowest cost to the consumer and uh I know we last spoken a form like this on May 26th of 2015 I was wondering if you could uh have any more additional detail about maybe what level or is done in the last uh you know 16 months or so or what are some of the areas that level or is focused in terms of defining either child safety internally how level or approaches you know child safety in the development yeah so in general we focus our new product development on cordless solutions or solutions that meet this set best for kids uh criteria um we work on motorized systems but quite honestly we won't sell very many of those because we're not a high priced we don't compete in that market very strongly we do have a presence there but we won't sell a lot of those units for a while until we can get the cost down um you know just cost reducing our existing models we literally just had a line review with lows recently so it's hard to say what exactly will be on shelves um in the next time period but uh we've presented them with uh numerous options at a at a substantially better cost than what they've seen in the past and so that's really our focus is to make the solutions more cost affordable and to drive that market penetration of the cordless solutions is there a chance for any of the low cost um current um horizontal blinds to be within the same price range within maybe i don't know ten five to ten dollar range of a cordless horizontal blind because i want to see if i guess this is for anyone is it possible or are you guys coming up with anything that would address a horizontal uh corded issue so we are on the low end scale so so a couple points yes we are working on that system specifically the horizontal mini blind system but no we're not to the 10 range yet we're still in the range that tom mentioned and it depends on the size if it's vile or metal they can go out to 72 inches wide or they can be less than two feet wide and so that price range is still 20 to 50 percent range um but that is that is better than it was a year ago and i assume that will continue to get better each year quite honestly yeah i guess that's my uh follow up on this uh you know several of you mentioned you know that you're driving your your new development is focusing on this and on value engineering uh specifically within the cordless you know do you see in one year two years you know uh is there a point in time where you think these new innovations are coming to market that will reduce that uh increment i don't think it will ever get to a zero cost adder but i do think it at some point it becomes the new norm and it uh you know it gets enough market penetration to where it's not it's it is the conversation at that point and if you can get it down to the range you're talking about 10 percent then then it's pretty easily pretty easy for the consumer to make that um gap and and logic for the 10 percent right i just wonder if you ever see uh how long out you're forecasting that it's hard to say quite honestly i would say that um it's very difficult because of the product types to to say specifically what cost comes out i can say with with a degree of confidence that when you look at a what is the cost of cordless in a system um it's difficult you know i should say i should go this way when you look at the cost adder that cordless has over a corded system about the best that i can see that you're going to be able to do through just value engineering is taking about half of that difference help because you cannot get away from the fact that you have to have certain components make up a cordless system you have to have a spooling system you have to have some type of a spring motor um these are basic components and so you will not as as jeff had just stated you're not going to get to a zero net it's just it's not possible and still be able to accomplish the same function of raising and lowering the blind or shade also trying to get to how long does that take it's not unusual depending upon are you making a minor change to something it could be three to six months from the time that you get product changed to the time that you get it integrated into the field but a true development if you're really starting from scratch it could be easily 18 months before you are able to bring something to market um and it's all very reliant on on what is it that you're changing what are you affecting in that process joe also i think um and again i'm speaking much more broadly and without any knowledge of exact details of design or or cost but i think what we're talking about is not all cost driven okay there's a there's a certain amount of this that's cost driven where you know value engineering and cost of components and complexity comes down but then there's also the demand side and so to the extent that we can continue to drive the demand side and the acceptance of cordless options and have the retailers be partners in that uh we think will create perhaps a new floor uh so that um in in a certain period of time people won't be comparing between you know the lowest cost cord lock system that they ever saw and these newer designs that uh that that you know promote the the the goals that we're trying to promote here so i think it's a it's a combination of of driving cost out it's also a combination of of driving demand up and um and so i think that's important it's a it's it's both parts of the equation in order for us to to be able to accomplish that and we spend a lot of time in working with other participants in the industry showing them options and very often you've got to develop it to a point where it works i mean what you saw that i just showed you that had all 3d printed parts um you know 3d printings come a long way and it's allowed us to move a lot faster but it it still is an an 18 month process and to bring a more complex system from an engineering standpoint to be ready for market it can easily consume over a million dollars that's tooling that's engineering uh investment and so on uh and frankly you know it's not just the manufacturing side as as ralph just mentioned there's got to be demand and so you know we've um taken a flyer if you will on a number of products over the years that were child safe well beyond what is currently in the standard um tooled them up um and showed them to a combination of participants in the industry including retailers and then ultimately they make the decision on whether they're going to put it on their shelves or offer it and you know really until recently answers usually been that's cool come back and see us you know in a year or two or three we don't think it's going to sell but you know we're getting a lot more of an open mind and a better reception nowadays but it's you know it's been it's been a long road with a whole lot of frankly um sunk investment that you know we won't recover but we were willing to make it's but that's the nature of of this process we can't just build it and they will come and that's where I think as we talk a little bit about the standard uh the standard has to play a role in that as well voluntary standard has to play a role in that as well um and uh you know maybe this is a good time just to kind of go over the objectives of the standard you know first and foremost the primary goal of the next revision is to address the risk of strangulation to young children from operating courts um we uh you know we we have been talking in terms of uh cordless and inaccessible cords and short cords and whatever the combination of that uh that that's that scenario needs to be um we want to maintain a performance-based standard to ensure that advances in technology to address the strangulation risk to young children can be tested for compliance so they can be brought quickly to market so we don't want the standard to be in any way an impediment to somebody bringing something to market and getting it tested and accept it quickly um where possible uh we would like to simplify the process to demonstrate compliance um you know we have gotten comments from time to time at the standard is uh can be complex to understand we want to make it as simple as possible to understand so that people understand what what's involved in complying um and we're also looking at exploring the possibility of a joint standard development with the canadian standard association and we've spoken with uh the standards uh council of canada on various approaches that we might be able to uh to take so that we can and whether that turns out to be a single document two documents uh you know jointly developed documents we're not really sure yet but we know that we have the support of uh of ansy and the standards council of canada in exploring that to the fullest so that we'll have no gap uh between the jurisdictions and the requirements and the timing uh interpretation of the standard and we think that that's uh that's a good thing all around um you know but the main goal going back George before I talk a little bit more about the the process is that the that this revision um you know will address the risk of strangulation to young children from certain operating courts um in terms of the process um you know we'll utilize you know once again we'll utilize the ansy canvas you know standard development process uh as as you stated at the beginning um you know we've worked with cpsc and many of the stakeholders here and we will continue to reach out and do that uh and have them as part of the process um the standard will be performance base we will not be looking at prescriptive requirements uh you know new developments on on operating systems and court control systems much like what we've seen here and talked about here um you know will be uh you know will be um hopefully uh available to to meet those performance requirements um you know we're appropriate and we can model and and use uh charts and flow charts and graphs to make it very easy for somebody to follow if this then that uh you know we'll do that um we also think in in a couple of the questions that you uh that you brought up um you know go to the heart of this but we'll be looking at um product segmentation approaches uh you know can uh are there approaches available in product segmentation uh that we can evaluate to determine which might have the greatest impact um recognizing that as as as tom has said and others uh in terms of product categories there's still some products and still some applications that might need a courted system of some type and how do you get how do you get that involved but we would be looking at um product categories in terms of of how to segment or potentially segment product categories operating systems might be another one applications and uses of products uh distribution channels um location in the home uh and then as you started to ask your size weight uh geometry configuration um and so all of those we think are um are opportunities to evaluate um you know where we can make the most impact on the on the greatest number of products that are going into the market um you know recognizing that there there will be some exceptions uh but I think that that's uh that's really what we're trying to uh to do which is why uh you reference the press release that uh you know we think that this next revision of the standard is going to have a major impact in that area no thanks for all fun we've had a lot of conversations on this over the last 16 months or so and you know I think we all appreciate the engineering challenges on the window coverings and I appreciate the fact that in looking at this when we talk about the risk of strangulation from window coverings we all recognize that it's a not a one size fits all solution and that the time has come that we not wait until we have a window covering design that fits everything in other words we're going to have to look at you know for each of the window coverings what are the different ways we can manage the risk whether it's a roller shade whether it's a horizontal blind you know whether it's a uh continuous bead loop you know there's going to be different ways to manage the risk and it's really important that we sit down and as we break them out look at how can we manage the risk because we all know that there isn't one window covering type that fits all of them addresses all of them but at the same time we can't you know wait until it's developed to that point and I guess maybe from each of the companies as we've talked today I've heard a lot about you know defining child safe and how it's dependent on the standard and I guess what I was interested in from each of you all is the industry members is from what you've seen and learned over the last 16 months since our last meeting what do you see specifically that you then you know bring to the voluntary standard you know to improve the voluntary standard so that raises your or improves your definition of child safe so that's kind of my question is from the last meeting in May until now what have each of you kind of specifically seen that you plan to bring to the voluntary standard that rate you know raises that you know definition of child safe which you kind of describe as being dependent on the voluntary standard um I'll speak first on this that you know I really look at this in two ways right so there's products where you don't have a lot of penetration maybe not a lot of awareness so how do you how do you bring awareness to that and and on the other side of that best for kids which you know in the last 12 months that that was brought forth published in May of last year so there hasn't been a lot of exposure to it but yet retailers have embraced it they understand it it's simple and so they're using that as a means to to help build awareness through their markets through their distribution points so those are the types of things that that we look to as well as as we've already spoken about how do you how do you affect the barriers that that prevent people from just accepting cordless across the board and cost is a big part of that and so we have a lot of emphasis a lot of investment going into that again on cordless on motorized type systems in order to help make those help overcome those barriers to to purchase for the consumer I think from our standpoint we've had really dozens of prototypes ideas that we've been able to talk to either focus groups retailers and others about I think there's a a much greater awareness on our part of what they like and don't like again as I said before it was much more of a where the engineers here will design it and you know you guys should buy it because it's safe or it's cool or whatever the feature might be so there's a lot more collaboration in the industry now there's there there's real feedback we've gotten on the the spring loaded system or spring supported system in some way that was a big learning curve I mean it you know they there were certainly spring systems available before but now they're interacting with wands and with with other devices how do you make that consumer friendly affordable and explainable for a retailer if there's too much complexity they struggle frankly selling it so I you know I think there's been a a big learning curve and in that regard in in the direction of what I would consider to be very promising new tech new improved technologies so we could bring that to the table I've had a couple of meetings with our test lab two four-hour meetings actually just to go through the standard step-by-step definitions test procedures all the different protocols that are in the standard to find out what they would like to see you know try and be a sounding board and so I think simplification of the standard is something that we could bring help to make it more streamlined and smooth for the test technicians work with bureau veritas and inter tech and how they test things trying to compare notes what resulted you get what resulted we get are we actually synchronizing those results you know how come we thought it was okay and they thought it failed those kinds of complexities so I think we can simplify that and harmonize with Canada that would be helpful as well and how do you see the intersection between simplifying the standard harmonizing with Canada and addressing the better addressing the strangulation risk I think I was focusing on how the testing gets done more than from an overall company strategy yeah from my viewpoint the the current testing complexity makes it more difficult for the r&d teams to develop products and to test it if you if you build a prototype and you test it one time and it's close to passing or failing you can't use that same product again you have to create an entire new prototype because it performs differently each time each additional time you test it you get variability between labs in Asia and the us and just depends on who's doing the test how long they've been doing it those types of things just add complexity to the product development process in general and certainly don't help us move any faster it's like with finite resources it's distracting or inefficient then when you've got yes it's certainly a challenge I'm gonna just try to wrap make a little bit of wrap up here and then maybe we could take a quick break before we finalize please sure okay I think you know we're we may be getting focused on some some of the technical issues your question really is how are we going to bring new innovations to the voluntary standard process okay and how are we going to how are we going to address that and I think that our focus coming into this revision process as we've as we've said is cordless inaccessible cords short cords incapable of forming a hazardous loop how many products can be impacted by that set of criteria okay and so the technical folks will have to work within the context of but that's really if we're looking at a goal of attacking those those operating cords it's how many of those how many of those products can be made cordless can have inaccessible cords of the type that that we've we've seen or heard about today or can be some combination of of short cords that can't form a hazardous loop and you're right there is no one product that can handle that there is no one operating system that can handle that but if we if we look at that then and and we look at some of the some of the approaches that we we can take you know what that people have suggested over the years in terms of different types of segmentation and not recognizing it not every every configuration of every product could meet that but work on what's the greatest impact that we can bring I think that's the focus that we're trying to to to bring and that's really an outgrowth of the the original criteria that we have with the best for kids and that we're looking to expand as we go forward so let me ask a question George so I'm the engineer that's going to work with the standards or my group is going to work with the standards I'm not hearing too much I'm not hearing too much direction on where the standard is going or where you're going to bring the standard that's going to result in safer products for for window window blinds cordless inaccessible cords short cords that can't form a hazardous loop I think that's a direction and if you have a cordless system or you have a system that has inaccessible cords or you have a system that has a short cord that can't form a hazardous loop I think that's speaking directly to the direction so are we looking at when we do open when you do open the standard you're looking at developing requirements that will ensure that those are products that are are going to be made to to that standard that is that that's that's the direction that we're we're looking at we're looking at how do we make the biggest impact to allow those kinds of systems to impact the greatest number of products I guess to clarify that in terms of how to make the greatest impact so you're saying the the approach is is getting rid of the hazardous loops essentially through those several things you just described so are you saying the how to address the maximum impact is in terms of the segmentation how to segment it could be segmentation it could be operating systems it could be a number of different things that that's really you're going to be the some of the technical people bringing that what's the the greatest feasibility but that's the end result that we're looking for so you're not looking at 100% cordless or retractable or short cords so there will still be some exceptions I believe there will be I don't I don't I don't believe that there's 100 as Georgia does not 100% available for every product category but I think you know certainly as we brought up in the data before in the previous discussions there's an opportunity to make sure we overlaid to your point on addressing the greatest need you know not addressing a need just based on you know commercial availability or sales but on the type especially based on what we're seeing in the data I think there's a real opportunity here to make sure we overlay those on top of each other I mean we talked briefly about horizontal blinds before the reason we talked about horizontal blinds is from the data we know that's one of the you know major blind types where we've seen fatalities with the with the cord it used to be roman shades there was a real effective effort to address roman shades gosh probably well over a decade ago now you know it's still in the data but not not the same way so um you know from our perspective I think you know making sure with the with the data that we do I think it's the same type of analysis George same type of analysis process right and just following up on that well I think several people mentioned the desire to you know get this maximum benefit you know now that the time has come by you know what what we're able to achieve now but I wonder if there's a view towards you know what that next step would be after that would there be a plan to then you know follow up with you know perhaps additional segments additional operating systems down the road Joel as we've learned over the years I don't think this is a category we're ever done so I would imagine that um that you know as things develop over the next generation right now I'd like to get this next revision out fair enough take five minutes go right before the break Ralph you had said two things one you needed a five-minute break and then the second thing is you had some kind of I just wanted to closing type remark so I wanted to pick up there um yes I think that one of the things that I wanted to just reiterate is the the goal for the standard development which is to reduce the risk of strangulation and and we also look forward to working with with all of you on this process we will we'll use the ANSI process we'll look at all kinds of developments that that have been talked about today and then others we will look at various approaches to how we address the standard product segmentation will be one of those aspects that we look at look at in addition to the the technical aspect so various various approaches will be evaluated I went through the list before so just to reiterate product categories we'll look at operating systems applications and uses distribution channels such as stock versus custom location in the home size and weight of products and and the ability of products to be readily adapted to some of the new technologies and and really what we want to look at George I think speaks to your point we want to look at which of these or which combination of these has the greatest impact you know on the on the the products that are going in the market and the greatest penetration of products that go into the market having said that you know next steps you know we'll begin the the development process convene the steering committee established the canvas body determined the feasibility of developing the joint standard with csa in some concrete terms established meeting dates timelines milestones and and and the formal reviews develop the key actions that we have assigned ownership throughout the committee engaged retailers and and other key stakeholders to gain consensus you know and last but not least our goal and our target which is a very aggressive one is to have a standard ready to submit for antsy ballot by the end of this year so we we in concluding we thank you for having us for allowing us to come in we look forward to working with you and and we're all going to have to work together if we're going to if we're going to achieve this very aggressive goal thank you thank you Ralph and you know from the cpsc staff side again thank you for you know at the end of June announcing initiating the revision of the voluntary standard it's something that staff and you've been working on I think since the day after the last standard was published back in 2012 I think that was the next day's letter so staff is certainly looking forward to the opportunity you know to to work with you all on this you know with respect to the segmentation again you know looking at how do we and you know we understand it's a very fragmented market there's a lot of different window operating types there's different sizes within the home you know there's different rooms with different window covering types how do we really segment it so that we most effectively address the strangulation risk to young children in the home you know kind of difficult and I we but and we appreciate how difficult that problem can be and but we also I think from the last couple of years have shown that we're more than willing to step up with you have other stakeholders step up with you and the industry and really address it and develop this time around a standard that effectively addresses the risk of strangulation to young children in the home so thank you all again for the time it's good to see you again after so many months and have another meeting and with that I'll adjourn the meeting thank you all