Selling Safe Consumer Electrical Products In The United States

U.S. Consumer Product Safety Commission

This presentation was prepared by CPSC staff. It has not been reviewed or approved by the Commission and may not reflect its views.

Selling Safe Consumer Electrical Products In

The United States

John GoldenRegional Product Safety Attaché (Asia-

Pacific)U.S. Embassy, Beijing

Electrical Product Hazards

• Electricity is a powerful, useful energy source that is potentially hazardous.

• Product failures or misuse can cause fires, electric shock, thermal burns (such as from exposure to hot surfaces) and chemical burns (such as from batteries).

• Equipment that generates, distributes or uses electrical energy should be compliant with standards and installed according to applicable electrical codes to mitigate safety risks.

Electrical Product Hazards U.S. Data - From 2006 to 2008:

50,100 structure fires per year- 400 deaths, 2,990 injuries & $1.3 billion

property losses- Fires caused mostly by:

- Electric cooking equipment- Electrical distribution system

components- Electric heating and cooling equipment

53 electrocutions on average per year

Electrical Product Hazard Prevention Strategies

CPSC staff promotes electrical safety through a multi-

pronged approach

• Supporting improvements to voluntary standards/codes

• Creating and enforcing technical regulations and bans

• Identifying products with defects and hazards through surveillance activities and recalls

• Developing education programs for consumers

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Voluntary Consensus Standards

• The electrical product safety system primarily relies on compliance with voluntary industry-consensus standards.

• Wholesalers and retailers specify which standard a supplier must meet.

• Three technical regulations for electrical products under CPSC’s jurisdiction.

•


• CPSC’s regulations do not require 3rd party certification for electrical products, but there is a high rate of voluntary participation – Many retailers will only sell electrical products if they

have been certified– Some states and municipalities require certification for

all electrical products to be sold in those jurisdictions– The Occupational Safety and Health Administration

(OSHA) requires certification for electrical products used in the workplace

CPSC staff strongly recommends that manufacturers or exporters/importers seek 3rd party certification for their electrical products as a means of hazard mitigation.


• Since CPSC staff relies primarily on voluntary standards over mandatory regulations for electrical products, the staff actively participates in the process of maintaining the standards by addressing emerging hazards through development and adoption of new or modified requirements.

• This continuous process begins with reviewing information from CPSC’s data collection systems.

Incident Databases

Injury and

potential injury

incident data*

Death certificate

s

In-depth investigation

s

National Electronic

Injury Surveillance

System

National Fire

Incident Reporting

System

IPII DTHS

INDP

NEISS

NFIRS

*Hotline, On-line consumer reports, Newspapers, News on Internet

Voluntary Standards - Staff Participation

Analyze injury/death

data for hazard

patternsReview

standards for

inadequacies

Conduct tests and

evaluations to support findings

Propose standards developme

nt or revisions

Participate in

committees

Voluntary Standards ProcessCase Study #1: In 2004, document shredding

machines were implicated in a number of finger amputations in small children.

Data Analysis

CPSC staff reviewed incident databases for paper

shredder incidents to determine the causes and scenarios that may lead to

finger injuries.

Voluntary Standards ProcessCase Study #1: Document Shredding Machines

Data AnalysisThe most severe injuries, amputations, occurred when a child was feeding paper into a shredder (even under adult supervision) and did not release the paper in time and their hand was pulled into the opening.


Standards Review

CPSC staff reviewed UL 60950-1 Information Technology

Equipment – Safety – Part 1: General Requirements for

accessibility to moving parts requirements for paper

shredders

Voluntary Standards ProcessCase Study #1: Paper Shredders

Evaluation

CPSC staff examined paper shredders for design

variations and to assess the efficacy of accessibility

probes


Standards Revision

CPSC staff issued a report of test results showing

design/standard vulnerabilities and proposed a working group to discuss

findings.


Standards Panel Participation

CPSC staff participated in UL 60950 working group to

develop new test requirements to reduce

access to hazardous moving parts.



Panel voted to accept proposed changes to UL

60950-1 to address moving parts accessibility

Voluntary Standards ProcessCase Study #2: Flexible Lighting Products (Rope Lights)

Data Analysis

A rope light is a string of series and/or series-parallel connected lamps enclosed in a flexible polymeric tube or extrusion.

CPSC staff was receiving reports of incidents

involving rope lights, which had been in use as a

commercial product, but was being sold for

residential use. Raised concerns about possible

risks of shock or fire.

Voluntary Standards ProcessCase Study #2 : Rope Lights

Standards ReviewThere was no standard for

rope lights. Although similar to holiday lights,

rope lights differ in several ways, including installation longer than 90 days, which put them out of the scope of

the holiday lighting standard.


Evaluation

CPSC staff examined the rope lights and defined the

areas of concern for residential use, such as field configuration (cutting lights

to length).


Standards Revision

CPSC staff proposed development of a standard

for rope lights based on identified potential hazards.



First Edition of UL 2388 – Standard for Safety of

Flexible Lighting Products was issued July 3, 2002

Technical RegulationsOnly three technical regulations for

electrical products under CPSC’s jurisdiction:

• 16 CFR 1505 – Requirements for electrically-operated toys or other electrically operated articles intended for use by children

• 16 CFR 1204 – Safety Standard for Omnidirectional Citizens Band Base Station Antennas

• 16 CFR 1120.3(a) – Requirements for handheld hair dryers require integral immersion protection in accordance with UL 859 and UL 1727

Other Requirements

Safe Installation = Electrical Safety

• The National Electrical Code (NEC) covers the installation of electrical equipment in public and private premises.– Product standards requirements are in

accordance with the NEC.

• The NEC is a consensus code published by the National Fire Protection Association.– This is NOT a national standard, but it is

widely adopted as law by state and local municipalities.

RecallsA product for which it has been preliminarily determined to create a substantial product safety hazard must be recalled, i.e., removed from sale and those in consumer’s hands must be remedied through repair, replacement, or refund, as appropriate under the circumstances.

Besides working to make products safer, CPSC staff strives to make consumers safer users through information and education and engaging them in thinking about safety first.

Consumer Education

• www.cpsc.gov

• www.SaferProducts.gov

• Press releases

• Neighborhood Safety Network

• Publications

• News Conferences

• Social media

Consumer Education

• Compliance with applicable regulations, standards and the NEC are highly effective ways to mitigate hazards from equipment that generates, distributes, or uses electrical energy.

• Importers, although reliant on foreign producers, are directly responsible for the safety of products they bring into the United States.

Responsibility to Comply

All equally responsibleManufactur

ersImporters

Distributors Retailers

Responsibility to Comply

Manufacturers and importers should follow best practices to ensure that their products do not pose undue risks and need to be recalled. • Comply with consensus standards and technical

regulations• Obtain third-party certification for products• Implement a rigorous recordkeeping system to

document all relevant aspects of design and manufacturing to assure that all changes can be easily tracked

• Maintain quality and configuration control• Assess impact of material or component

substitutions

Case Study #3: This hair dryer is missing an immersion detection current interrupter (IDCI) plug and presents a risk of electrocution if dropped in water. It violates the requirements under 16 CFR 1120.3(a) .

CPSC seized products at the port.

Follow Best Practices – Avoid Unsafe Products


Case Study #4: Uncertified luminaire did not meet voluntary standards requirements. It was assembled with poor workmanship, lacked proper strain relief on the power cord and did not have a polarized plug. Unit posed fire and shock hazards.

CPSC seized units at the port.


Case Study #5: Uncertified decorative lighting string did not meet voluntary standards requirements. The wire was undersized, plug lacked overcurrent protection, strain relief was inadequate and circuit enclosure was not flame-resistant. Unit posed fire and shock hazards.


Follow Best Practices – Avoid Unsafe Products Case Study #6:

Uncertified handheld work light did not meet voluntary standards requirements. Deficiencies included assembly with poor workmanship, undersized wire, inadequate strain relief on the power cord and substandard components. Unit posed fire and shock hazards.



Case Study #7: Uncertified portable electric fan did not meet voluntary standard requirements; deficiencies included motor without thermal protection, undersized wire, inadequate strain relief on the power cord and lack of integral overcurrent protection in plug. Unit posed fire and shock hazards.


Follow Best Practices – Avoid Unsafe Products Case Study #8: Remote

control toy helicopters provided with rechargeable lithium-ion batteries without charge/discharge control circuitry or thermal protection, allowing batteries to be overcharged or over-discharged, overheat and ignite. Posed fire hazard.

Units recalled.


Case Study #9: Uncertified 6-outlet current tap did not meet the voluntary standard. It was poorly constructed from inadequate materials. Sheet metal was too thin and flimsy and lacked strength to properly contact plug blades. Resulting loose connections can arc and overheat. Ground pin was poorly fastened to grounding bus. Unit posed fire and shock hazards.



Case Study #10: Uncertified power strip was not compliant with the standard. Power cord and internal wiring were severely undersized, and the cord strain relief was inadequate. Sheet metal buses were too thin and flimsy and deformed when a plug was inserted. Internal connections were poorly made and easily came loose. Unit posed fire and shock hazards.CPSC seized units at the

port.

Follow Best Practices – Avoid Unsafe Products Case Study #11: Third-party

certified dehumidifier involved in fire incidents. Poor recordkeeping and failure to follow process controls allowed non-flame resistant plastic resins to be used in enclosure molding in place of approved polymeric material. Insufficient flame-resistance allowed internal failure to ignite surrounding plastic and propagate flames beyond unit.

Units recalled.

Summary

Electrical product safety does not happen by accident; it requires diligence and vigelance from producer to user.

• Be aware of CPSC regulations • Follow applicable voluntary standards during design

and manufacturing of products• Obtain third-party certification for products• Follow best manufacturing practices to ensure

products are built consistently and with proper quality and safety

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John GoldenRegional Product Safety Attaché (Asia-

Pacific)U.S. Embassy, Beijing

Phone: 86-10-8531-3318Fax: 86-10-8531-3652

E-mail: [email protected] E-mail: [email protected]