 Our lives more and welcome this public meeting of the consumer product safety commission. And I confirmed that all the commissioners are here, Mr. Bianco. Here, Commissioner Feldman may need to unmute. I'm muted. I'm here. Thank you. Thanks, Commissioner Trump. I'm here. Good morning. Morning. Thank you, Mr. Boyle. Good morning. I am here. Thank you. But before we start the business day, I would like to recognize and thank my colleague, Dana Bianco, who is here for what will most likely be her final commission meeting. Dana is a wonderful colleague and has been a good friend over the past year. I want to take a moment to express my appreciation for her public service here at the commission and the difference she has made during her time at the commission by bringing experience, development, private practice and a clear pragmatic perspective to product safety issues. And I'd be remiss if I didn't also recognize and commend her chief policy advisor who's been a stellar staffer to Commissioner Bianco. So thank you. Thank you, Alex. I really appreciate that. And you guys all know how emotional I get. So I'm not going to do that and let the record be crying. So let me just say that I'm proud of the work that we've done together during my time here and I'm leaving the commission, I believe, in really good hands. So I'm only a phone call or text away, of course, but I will definitely miss you guys. Well, thank you and good luck. So this morning, we are here for the staff's briefing on a proposed rule to establish a consumer product safety standard for adult portable bedrails. In March, the commission voted unanimously to move forward with this rulemaking. That vote came in response to two petitions filed on the issue. Gloria Black, who lost her mother in a bedrail related incidents, a consumer voice for quality long-term care, consumer federation, 60 other organizations submitted the first petition nine years ago. Public Citizen Health Research Group, all the second petition. And I'm pleased we now have a draft notice of proposed rulemaking in front of us. And the process is moving forward. In a moment, we'll turn to this meeting over to staff so they can brief us. Once they have completed the briefing, each commissioner will have 10 minutes to ask questions of the staff as multiple rounds necessary. Briefing us today is, sorry, just going back in this room. And obviously, if there are any questions with respect to the legal authority or other advice, we can have a closed session, executive session. Briefing us today, we have Benit Daya, I am sorry, I put your name. Project Manager, Division of Mechanical Engineering Directed for Library Sciences. And Hyun Kim, Attorney, Regulatory Affairs Division, Office of General Counsel. Also joining us are Jason Levine, CPSC Executive Director, Austin Schlick, General Counsel, and Alberta Mills, Commission Secretary. And with that, I'm going to turn the microphone over to our briefers. Good morning and welcome to staff's briefing on the draft notice of proposed rulemaking for adult portable bedrails. As the chairman stated, I'm Vinny Dayall, the project manager for APPRs, and I will be briefing the commission alongside Hyun Kim from CPSC's Office of General Counsel. Next slide. Walking through the structure of today's briefing, first Hyun will explain the underlining rulemaking process and legal considerations for the NPR. Then I will give a brief overview of the product and the general background leading up to this point. After that, we'll move on right into the staff's review of the hazard analysis, market outreach, and compliance actions. Staff's review of the existing voluntary standard, staff's proposed rule, and economic analysis of that rule. And then one last summary of staff's recommendation to the commission. And with that, I'll hand it off to Hayoon to get started on the next slide. Hayoon Kim Good morning. My name is Hayoon Kim. I'll be giving a brief overview of the statutory framework for issuing a standard under the Consumer Product Safety Act. This rulemaking falls under section seven and nine of the CPSA. Section seven of the CPSA authorizes the commission to issue consumer product safety standards that consists of performance requirements or requirements requiring warnings or instructions. The requirements must be reasonably necessary to prevent or reduce an unreasonable risk of injury associated with the product. Section seven of the CPSA also specifies that consumer product safety standards must be issued in accordance with the requirements of section nine of the statute. Next slide. Section nine of the CPSA provides procedural and substantive requirements for issuing a consumer product safety standard. It specifies that a notice of proposed rulemaking must include the text of the proposed rule, alternatives to the proposed rule, and a preliminary regulatory analysis. Section nine also requires that the commission must provide two opportunities for comments. First, section nine requires that rulemaking must be in accordance with section 553 of the Minister of Procedure Act, which requires that agencies give notice of a proposed rule and the opportunity to submit written comments on it. Second, section nine requires that the commission provide an opportunity for interested parties to make oral presentations of data, views, or arguments. The proposed rule provides for an opportunity to provide both written comments as well as for any interested party to request an opportunity to make an oral presentation to the commission. Next slide. As I mentioned, an NPR requires a preliminary regulatory analysis. Section nine provides that the preliminary regulatory analysis must discuss the potential benefits and costs of the rule and alternatives to the proposed rule. Next slide. To issue a final rule, the commission must consider and make specific findings, and these findings must be included in the rule. At the NPR stage, these findings are preliminary and must be included in the regulatory text. This slide shows some of the required findings, including the need for the public of the rule and the effect of the rule on the utility, cost, and availability of such products, as well as the means of achieving the rule while minimizing adverse effects on competition or the disruption of manufacturing or commercial practices. Next slide. In addition, the commission must make preliminary findings on existing voluntary standards. If a voluntary standard that addresses the risk of injury has been adopted and implemented, the commission must find that either compliance with the voluntary standard is not likely to adequately reduce the risk of injury, or that there is not likely to be substantial compliance with it. Next slide. Under the draft proposed rule, APBRs would be required to meet the requirements of the voluntary standard, ASTM F1A5-17, with modifications to address the unreasonable risk of injury associated with entrapments on APBRs. I will now turn it over to Benid who will provide further information about the background of the proposed rule and APBRs. Thank you. Next slide. Thanks, Ayun. So, as you can see, this timeline provides a quick background on the events and work that led up to this draft NPR. In 2013, the APBR petition was docketed. Then, in order to assist the development of a voluntary standard, the commission voted to defer a decision on the petition. From there, staff worked with ASTM to develop a standard, and in 2017, they published F3186. Then, staff began reviewing the market, collecting market samples for testing, and reviewing the final form of the standard to determine if it would adequately address the known hazards. All of that included two separate rounds of market compliance testing to the voluntary standard. Then, per the information presented in staff's 2022 briefing package, the commission voted to grant the petition and directed staff to develop a draft NPR. So, with all that history behind us, the next slide will show exactly what an APBR is. Next slide. As you can see in the pictures to the left, APBRs are products that consumers install on the sides of their beds. They are used as a solid support that can help prevent users from falling out of the bed, help them reposition in bed, or get them in and out of their beds. Next slide. Staff's review of the APBR incident data revealed that the majority of incidents were fatal, and most victims were over the age of 60. Per the analysis of each incident report, staff found that 85% of all incidents were related to bed rail entrapments, which also accounts for about 92% of all APBR fatalities. Generally speaking, this directly ties into the idea that APBR products are often used by vulnerable populations that have limited mobility. Users that need help getting into and around their beds due to medical conditions or injuries often don't have the capability of self-rescue if they find themselves entrapped. With that in mind, I'd like to notify you all that the next slide includes pictures of actual incidents and may be uncomfortable for some to see. Next slide. So, as mentioned, here are some examples of APBR incident staff reviewed. Although it might take a moment to digest, you can probably see that there are a number of ways and locations rail entrapments can actually occur, and that these incidents are completely dependent on the size, shape, location, assembly, or installation of these products. Next slide. Ultimately, after reviewing all of the incident reports, staff found four major entrapment zones, which include within the product, under the bed rail, between the rail and the mattress, and between the mattress and the end portions of the rail. Next slide. Staff specifically reviewed each fatal entrapment report in order to identify the most likely zone each incident occurred in. The majority of fatal entrapment incidents occurred between the rail and the mattress. It should be noted that 70 of these incidents are listed as unknown, and that's because the death reports did not provide enough information detailing the language, but staff still believe if more information was provided, most of these would fall under one of those four major zones. As shown in the column furthest to the right, the voluntary standard currently addresses all of the known hazardous entrapment locations with performance requirements, and it aims to address those entrapments related to other zones through requirements for warning, labeling, and instructions. Next slide. So staff's work has not only been internal to CPSC. Beyond the petition work, staff utilized all available venues of approach to address these known hazards. In 2020, the Office of Compliance sent a letter to industry, notifying them about the seriousness of entrapment hazards related to their APBR products, and urged them to comply with F31-86. Staff was also actively involved with ASTM 1570, providing all interested parties updates on the available incident data, presenting staff's compliance testing results, and through several other efforts to promote healthy developments and involvement in the voluntary standards process. Next slide. Staff is also involved with several APBR compliance actions, five of which resulted in APBR product recalls related to 13 deaths and 23 individual models of APBRs. The table provides a general summary of these actions. Next slide. Per CPSA requirements, staff assessed ASTM F31-86 in order to determine if the voluntary standard would adequately address risks of injury associated with APBRs. While the standard does have performance requirements that are most closely related to APBR hazards, such as entrapment, structural integrity, retention systems and misassembly, staff found that the standard would need additional modifications in order to adequately address the known hazards. And furthermore, staff's compliance testing results showed that there was no market compliance to the voluntary standard. Next slide. For this draft NPR, staff proposed several modifications to ASTM F31-86-17 in order to adequately address the known APBR hazards. These modifications include additional definitions for terms used throughout the standard, guidance and test setup requirements for mattress heights and for products with multiple settings, improved language for several test methods so all interpretations address known hazards and several corrections to dimensions, tolerances and other editorial needs. Next slide. The market for APBRs and similar products is expected to grow, meaning that even if these incidents occur at a constant rate per product, CPSC may see a significant increase in the average number of deaths from 17 deaths per year to an average of 32 per year over the next three decades. Each year, these deaths are equivalent to about $300 million, while the annual cost to comply would be around $2 million. If only entrapment hazards are addressed by the proposed rule, it would result in a net benefit of $265 million per year. That's excluding any residual benefits from additional prevented deaths and injuries likely to be addressed by the rule as well. Next slide. Staff's economic analysis went on to assume that even more conserved with scenarios by also accounting for less than ideal regulatory efficacy rates as well. Even assuming that the regulation prevents only 25% of the 92% of fatalities, the net benefits are still around $65 million annually. That being said, staff did find that the rule would have significant adverse effects on three of the seven identified small manufacturers, but with the expected future growth in the space, it is highly likely that more manufacturers will join the space rather than leave the industry. Next slide. In addition to the proposed rule, staff considered six alternative actions. Staff does not recommend any of these alternatives. The first four listed would not adequately address the known hazard modes, and moving forward is highly likely that the majority of the $300 million in annual societal costs would continue to be felt, or even increase in coming years. While staff doesn't recommend the fifth and sixth alternative actions, staff would like to hear comments within the common period of the NPR regarding these options. Again, staff doesn't recommend an effective date beyond the minimum 30 days, due to the fact that that industry should be adequately aware of these hazards related to APPRs and staff's ongoing actions. Next slide. In summary, to address deaths and injuries, staff recommends that the commission, published in NPR, that mandates a safety standard based on ASTM F3186-17 with modifications to address the hazard, and staff also proposes an effective date 30 days following the publication of the final rule in the Federal Register. And with that, staff's briefing package on the draft NPR for APPRs has come to an end, and on behalf of myself, Ayune, and the entire team, thank you all very much for your time. Thank you very much, both of you, and all the staff that worked on this. At this point in time, we're going to turn to questions from the commissioners. I'm going to recognize myself for 10 minutes. And again, thank you, Mr. Jayal, for your briefing and apologies again for mispronouncing your name early on. As you said, one of the petitions submitted to the CPSC on this issue called for a ban on portable bed rails. Obviously, staff is not recommending this, and acknowledges that there are going to be unaddressed fatalities from the standard. What was the thinking in considering, can you expand a little bit more on thinking between considering a ban rather than a performance standard? Yeah, so approximately 180,000 APPR units are sold annually, which is indicative of their utility in that people are buying these products. And these are products that consumers rely on to reduce their risk of falling out of bed, assist them repositioning the bed and assist them in transitioning into or out of their beds. If we were to ban APPR products from the market, that could potentially leave consumers without any alternatives. The APR does ask for comment on whether ban would be appropriate. Is that correct? Yes. So staff did recommend asking for comments on banning the product and the potential loss utilities associated with that. Thank you. I also noticed that the package recommends a 30-day effective way, a date based on the fact that firms are well aware of the voluntary standard and should be able to easily meet the standard. Even though staff shockingly has found that there's no products that meet the voluntary standard, can you expand a bit on why the firm staffs, the firm believes that firms will be able to meet the requirements of the 30-day standard once the rules are finalized? Yeah. Sure thing. So staff assesses that the compliance action is taken to write the letters to the firms in 2020 to note that the non-compliance with the voluntary standard would be an indication of substantial product hazards and the other related efforts that we've done to recall APPRs as sufficiently alerted firms to the voluntary standard. And then furthermore, we assess that the changes that would be required by the draft proposed rule would feasibly be completed for a low cost. But despite all of that, staff is still seeking comments. We recommend seeking comments in the NPR for those factors. Given this awareness that commissioners consider an anti-stockpiling provision at this point. So staff recommended the minimum 30-day effective date and that's because, again, through staff's outreach efforts and compliance actions, the APPR industry is adequately aware of our current voluntary standard and rulemaking efforts. But again, that's something that we would like to see comments on. Thank you. Thanks again to both of you. Those are my questions for now. I'm going to turn to Commissioner Bianco. Thank you, Mr. Chair. And thank you both for your good work on this project and your presentation. The question I have really is more for the benefit of some of our listeners as people have asked me this question and I'm not sure I gave the best explanation. But why are these bedrails under the jurisdiction of the CPSC and not the FDA? What's the difference between these bedrails being a consumer product versus a medical device? I'll address that question. So first of all, voluntary standard covers both bedrails that are under CPSC's jurisdiction and under FDA's jurisdiction. FDA first came out with its guidance because they found that hospital beds also had railing that posed similar issues. With respect to the jurisdictional question of whether it falls into CPSC's jurisdiction versus FDA's jurisdiction, if an APBR has a medical purpose that is classified by the FDA as a medical device, it would fall under FDA's jurisdiction. We note that FDA does not reference bedrails or bed handles. Rather, FDA regulations talk about movable or latchable side rails. So FDA regulates adjustable hospital beds for medical purposes. So bedrails that are in accessory or are pertinent to regulated hospital bed is considered by the FDA to have a medical purpose and be subject to FDA's jurisdiction as a medical device. That's where the rail is integrated into the design of the bed. For CPSC, we look to see how the bedrail is marketed, how it's sold, how it's advertised, and whether it serves any medical purpose by the advertising. So that's how we distinguish whether it falls under our jurisdiction or whether it's more appropriately under FDA's jurisdiction. I would also note that FDA representatives have also been part of the ASTM subcommittee meetings. So they're well aware of all of these discussions that we've been having about bedrails. Thank you very much. I do appreciate that, and that I don't have any more questions otherwise. Thank you. Thank you, Commissioner Feldman. Thank you, Mr. Chairman. Mr. Dayal and Ms. Kim, I want to thank you again for the presentation and obviously offer my thanks to all of the agency staff that worked on this. The adult portable bedrail is a product that does present a real risk of death to one of our most vulnerable populations. This is an issue as your timeline laid out that's been on our radar at CPSC for quite some time now. This rulemaking was a key priority of the former acting chairman and one, unfortunately, that he wasn't able to deliver on. But I'm pleased that we're now at a spot where we're moving forward. So I do want to congratulate you, Mr. Chairman, and this commission in particular for getting to a point where others have failed. It's an important step forward in terms of protecting consumers from APBR entrapments. I support the NPR. I think that this is something that we're going to get done. I think that Americans are going to be safer because of our actions here. I have no questions, but again, I appreciate the presentation today. Thank you. Thank you, Commissioner, Commissioner Trump. Thank you. So where we know the hazard pattern, almost all the entrapment deaths in our data are in zones two, three or four. So in other words, where someone died because they were wedged between the mattress and the bedrail as opposed to being entrapped inside the bars of the bedrail itself. So so where the mattress is a factor. Now the proposed performance standard measures mattress. It takes into consideration mattress thickness, but I didn't see anything about firmness, which would seem to be relevant here too. So can you talk a little bit about how mattress softness or firmness could influence entrapment between the mattress and the bedrail? True thing. So when it comes to softness and firmness, zone three testing, specifically tests for mattress compressibility and entrapment hazards associated with it. The pass bail criterion is entirely based on how far the actual test probe is allowed to sink between the mattress and the bedrail. Furthermore, the range of mattress firmness available on the market should be considered by any manufacturer that's designing APPRs. Staff also notes that a final rule would require firms to certify compliance based on a reasonable testing program, which staff would define as testing throughout that entire range of mattress firmness, firmnesses to be a reasonable test program. And we would expect certified products to meet those requirements throughout that range. And then in addition to that, staff further notes that CPSC testing in support of compliance would use reasonable but stressing conditions of a compressible mattress. But in addition to that, even more, staff encourages the submission of any comments, concerns, or additional information concerning mattress compressibility during the comment period for the NPR. In particular, information on whether there should be a standard mattress, including firmness, and what that standard would look like would be valuable for us to consider. Well, that's encouraging. I'm glad to hear that you have thought through this issue and would consider requiring them a reasonable program that would have to test through the entire range of firmness and softness. But it would probably be useful to spell that out for the firms who are actually doing the testing. And I guess when we get to the final rule, we could probably do that based on what we hear back here. So would you recommend adding instructions at some point during the performance test to account for worst case scenario mattress firmness? So staff is open to suggestions and comments during the NPR comment period. But in terms of staff's proposed language, Note 2 states that testers and manufacturers should account for all mattress types in order to account for foreseeable use and misuse of the products. And again, if this proposed rule were to be finalized, staff would be testing all these products in these more onerous applicable cases. So it would be to their detriment not to consider them or test to them. All right. Well, that's good to hear. I will read Note 2 and make sure I understand that. But I think maybe moving that up to more prominent, just so we're perfectly clear what testing we're putting on folks could be useful. Now, there's a 30-day effective date in the proposal. And I very much appreciate that. I think that should be the default in all of our rules. So the shorter an effective date, the more we can increase the benefit of the rule for consumers. Is that right? Yeah. So if we were to extend that date, that means there's more time for these incidents to be happening. That's the plain and simple. Well, yeah. And I agree that that is unacceptable. And because shorter effective dates maximize benefits, we should be adopting those wherever we can. I mean, would you agree with that statement? I think we can only talk for this rule. So we are recommending it for this rule. Our data shows that 92% of deaths are related to entrapment as opposed to other causes. And the package mentioned several times what the benefits would be if the rule prevents 92% of deaths. So I think what we're saying, and I wanted to make sure about this, does that mean that the analysis assumes that the rule would prevent 100% of entrapment deaths? So the assessment that staff made, so it was based on the modifications to the standard, and while it did focus on entrapment deaths, we did our sensitivity analysis to estimate the benefits for a range of 25 to 75% effectiveness, which is 25 to 75% prevented of the 92% of failure entrapments. So yeah, that's 65 million. It's only on the 92%, but then in addition to that, it doesn't account for any of the other residual benefits. And so there's an extra 8% of falls and other types of hazards that would probably benefit from having a mandatory standard. So I get that, and I appreciate the fact that even at a 20% effectiveness rate, we blow the cost benefit out of the water on the positive end, which is good to see. But how effective do we think this will be at preventing these entrapment deaths is what I'm getting at. Do we think that it is going to be 100% effective at that 92%? So we don't have exact numbers on how effective it's going to be, but what I can say is that staff has assessed the standard and technically speaking, and from that we've concluded that it would likely address all of the known hazard modes. So those four entrapment zones, they're likely to be covered by the requirements that we are proposing here. Technically speaking, because those are based on the anthropometric measurements of those that are at risk for these types of hazards. Okay. So I'm still not trying to... I mean, we don't have an exact assessment of whether it will be 100... I mean, we don't have a projection of how good we think it'll be at preventing those deaths. Yeah. Unfortunately, we don't have that sort of magic ball, but we do know that even if it's only 25% effective, we're still, as you said, blowing it out of the water. So that's really the best that we can really do. Okay. On the cost benefits, I guess I'll have to put that aside for another day. In terms of... and the chair asked about this a bit. So the petitioners here asked us to consider a ban on these products. And we, the commission voted unanimously to grant that petition. There's not a lot of discussion about why the ban wasn't recommended in here. Can you explain how the costs and benefits of a ban would compare to the benefits and costs of this proposal? For example, would a ban be more likely to address entrapment deaths and injuries than the recommended performance standards? Yeah. So if APBRs are manned from the market, this will effectively eliminate APBR-related deaths. However, the cost of the lost utility from abandoned products, so consumers losing the products that they use daily to get in and out of bed, while that's unknown and unquantified by staff, that could ultimately outweigh the benefit. And that's because when they depend on these sorts of things, they'd be willing to pay more for a bed rail. And that exact value isn't exactly quantifiable right now at least. And yeah, a ban by definition would remove all of these products that they depend on. And in addition to that, some consumers would incur additional losses because they might be falling or getting injured because they don't have these products. So what did we do to assess the utility of the products? So we know that vulnerable persons often rely on these products to reduce their risk from falling, assist repositioning, and assist them in transitioning. And the fact that 180,000 of these APBRs are sold annually, that indicates that these products are, they do have utility for consumers. And that without these products, the alternatives would be extended hospital stays, purchasing or renting medical beds, which if they were banned staff would consider that a lot of low income individuals or people that don't have access would forgo that expense and possibly expose themselves to the potential falling and other societal costs and injuries and deaths. So I think there's just one thing I disagree with on that is that sales, in my opinion, are not indicative of utility. There are plenty of useless products sold. For example, at one point there were a lot of magnet sets that were being sold until recently. So the question I think that I have on utility is, do we know that they do a good job of stopping people from rolling out of bed? Or do they do a good job of helping people in and out of bed? And I think those are the questions we should look at as we consider the package. And I'd love to get consumer comments on that to say, hey, yeah, these really are useful. We use these every day. There might be a great argument for it, but I'd really like to take a look at that before we just assume utility based on sales volume. Yes, definitely. That is something that staff wants to see comments on. Excellent. All right. Thank you. Thank you, Commissioner. Commissioner Boyle. Thank you, Mr. Chair. And thank you, Mr. Dayall and Ms. Kim and all the staff who worked on this package. I really appreciate all the hard work. I do have a couple of questions for you, Mr. Dayall. I just wanted to ask a little bit about staff's assessment of the adequacy of the voluntary standard. I know that we're proposing modifications. So does that mean by definition staff assesses the voluntary standard to be inadequate? Yeah. So we characterize the modifications as important clarifications. Staff assesses ASTM F-31-86-17 to generally address the hazard patterns, but it leaves some testing ambiguity. Based on the discussions with test labs and others, staff has identified some areas of the standard that need clarification, as well as some gaps that staff has identified in the standards requirements and methodology. This makes it possible for testers to misinterpret the tests in a way that passes the standard, but does not address known product hazards. Staff propose these modifications to address these issues and provide test labs and manufacturers a consistent way of ensuring that products which do not adequately address these hazards do not pass these tests. Okay. So are you saying I just want to clarify then that the changes are substantive? I'm not sure. I understood your answer, whether the modifications that we're proposing are substantive or editorial clarifying? They are substantive changes. So to the extent that you're asking if the voluntary standard is inadequate, as currently written, the answer is yes, it is inadequate without the additional modifications made by staff. Yes. Thank you. That was what I was asking. So I wanted to just clarify that. Thank you, Ms. Quinn. But I would point out, even if tomorrow, if all of the modifications were adopted in the voluntary standard, that would not mean that we should stop mandatory rulemaking, correct? Because of the zero compliance that you found? Correct. Okay. Can you speculate as to why there was such striking abysmal compliance? So it's correct that F3186, so F3186-17 was published in 2017, and it's been over five years since then. Frankly speaking, staff does not know why the market is not complying. As stated in the briefing, staff has attempted to work with industry through every available venue available to us. So at this point, staff strongly believe a standard is needed to prevent unnecessary deaths. Okay. Thank you. I did have one other question about the percent of victims based on gender, and I believe the package said that 70% of the incident victims and incident fatalities were female. How do you account for that differential? Yeah. So staff agrees that there is a clear gender disparity in incidents related to APPRs, but we don't have any specific data to explain this. While we know that older women outnumber older men, the difference in fatalities seems to be stronger than the difference in population. So could it be testing differences, physical differences, crap? As of right now, staff doesn't have any insights on that, but it's something that we could definitely get back to you on. I think it was a striking statistic and might influence the type of testing that is done or the type of instrumentation perhaps. Okay. I don't have any other questions. Again, thank you very much. I do really strongly support action on this and appreciate all the staff work. Thank you. Thank you, Commissioner. That finishes the round of questions. Does any commissioner have an additional question? Hearing none, again, I'd like to thank the staff for this informed briefing and to the commissioners for active participation. I look forward to the consideration of this package soon. As I end note, I also would say that our thoughts go out to the people of Puerto Rico and Florida, so facing the storm and the wake of the storm as well. CPSC is putting out a lot of safety information about including the use of safe generators and urge people to use that information and protect themselves against further harms. With that, the meeting is closed. Thanks.