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So today I would like to commend you, Mr. Chairman, and the members of this subcommittee for undertaking a study which I believe will be useful-not only to Congress and this Commission but to Government, industry, labor and consumers who will benefit from information about accident statistics which your inquiry should develop.

A discussion of the adequacy of a data system relating to accidents and injuries involving common household products directly involves our assigned mission. We have established one task force to identify the relationship between consumer products and accidental injuries and deaths. Two additional task forces bear tangentially on this problem.

One of these is charged with evaluating industry's efforts at selfregulation. This not only involves a review of the development, promulgation, and use of safety standards for household products but includes considerations in design, performance, quality control, manufacturing methods, premarket testing and other safety considerations. The other task force is concerned with an analysis of Federal, State, and local laws, including common law, for their adequacy in providing protection to the consumer from hazardous household products.

I should mention that from the beginning the Commission staff has encountered considerable difficulty in obtaining valid statistical information on product-related injuries. For instance, there is no routine analysis or review of death certificates submitted to the National Center for Health Statistics by State governments for product-related injuries. We realize the inadequacies of basic information entered in some death certificates but feel that there is sufficient information on certain mortality classifications to provide important leads for preventive action by agencies with related program responsibility.

We are encountering difficulty in obtaining copies of indepth investigation reports by surveillance teams operated by the Department of Health, Education, and Welfare. This agency has been most cooperative in working with the Commission but due to severe limitations of staff and funds has been able to provide us with only about 10 percent of the 3,000 injury reports they have completed by surveillance teams. In addition, there is no mandatory reporting system for nonfatal accidental injuries that restrict activity or are disabling. The spasmodic and incomplete community injury surveys conducted during the past 12 years by the Public Health Service and other groups do not provide data that are statistically comparable or that can be used for guidance of regulatory agencies and for evaluating the effectiveness of community action programs.

Another difficulty involves the unavailability of information on accidental injuries reported to insurance companies for claims on product liability or for medical and health insurance. While we are now receiving some information from the insurance industry, we must reserve judgment on the adequacy and availability of the data we seek. Similarly, in most instances, neither the manufacturers nor their retail distributors have any system for collecting data on injuries to customers except when legal action is filed against them.

The remainder of my testimony will deal specifically with the questions submitted by the subcommittee for consideration by our Commission.

The National Commission on Product Safety has no official regulatory responsibilities.

An indirect regulatory effect has emerged as a byproduct of our public hearings, staff investigations and direct communications with manufacturers and distributors of consumer products. For example, at our Boston hearing on December 17, 1968, testimony was presented regarding a toy tunnel covered with a highly flammable fabric. Ironically, the cloth cover of the tunnel was imprinted with safety slogans for children. Yet if a child had lighted a candle or a match-as children will when playing in a tunnel-he could have been trapped in a flaming inferno. Approximately 50,000 of these toy tunnels were declared a banned hazardous substance by the Food and Drug Administration after it was alerted to this problem.

As the result of a Commission interim report recommending amendment of the Hazardous Substances Act to include thermal, mechanical and electrical hazards, the Toy Manufacturers' Association and their members have taken steps to develop safety standards in 21 different classifications of toys.

When testimony was presented in Washington last February 19 regarding a burn hazard associated with gas floor furnaces, the American Gas Association and the Gas Appliance Manufacturers Association took steps to review their certification and approval system for these hot floor furnace grates. Both organizations have announced they will no longer certify this device with its hazardous temperatures. În addition the industry has undertaken special research to develop alternate methods for reducing surface temperatures in floor furnace grates.

Our hearings last January 14 in Washington which pointed up the injury potential associated with annealed glass in patio doors, tubshower enclosures, storm doors and fixed transparent panels spurred the Federal Housing Administration to modify its Minimum Property Standards to require safety glazing in all hazardous high-risk areas. We have not yet seen the revised Minimum Property Standards but understand that it now exists-counsel advises me he received a copy in this room this morning.

As a result of a special press release by the Commission on entrapment of children in refrigeration devices, the industry voluntarily adopted a policy requiring the same protective features on food freezers that are now required by law for refrigerators. In addition they initiated a major national educational campaign to warn purchasers of new refrigerators of ways to avoid dangers with temporarily idle or discarded refrigerators.

We are engaged in a number of activities which involve collecting and analyzing data concerning accidental injuries. We have conducted public hearings in New York, Boston, Washington, Chicago, Portland, and Los Angeles. We have heard from representatives of industry, the general public, and specialists in the fields of standards and safety. Additional hearings will be scheduled during the next fiscal year. We were privileged to have as witnesses at two of our hearings members of your committee, Congresswoman Dwyer and Congressman Rosenthal, who presented impressive statements in New York and Washington. Other Members of the Congress have also testified. An analysis of the testimony presented at our hearings points out the overwhelming sentiment by numerous witnesses that a data collection system and data bank are needed for the reporting of accidental injuries and deaths. An analysis of these statements by more

than 18 witnesses is attached as an appendix to this testimony. It is quite impressive when you put it together and look at it this way. It clearly establishes the overwhelming need for a system of this type.

It is important to recognize the significance of this testimony. There was unanimous agreement that the present system is inadequate; there is no dissent on this point. There have been several recommendations for a solution to this problem. All recognize that there is a role and responsibility for both Government and industry at all levels.

It is evident from the testimony presented that a data bank is necessary to support many of the injury estimates presented as a part of the testimony of witnesses from all walks of life. Informationgathering activities now being conducted by the Commisison staff include the following:

A mail survey of 80,000 U.S. physicians for the 2-week period April 7 through April 21, 1969, has been completed. Doctors queried were general practitioners, pediatricians, surgeons, and osteopaths who were asked to complete a simple questionnaire on patients treated in their offices for accidental injuries involving one of the roughly 300 products on our list. About 10,000 responses have been received to date. All information received from the survey is now in the hands of a data processing firm in Princeton, N.J., which will make a detailed analysis for the Commission.

Another of the Commission's efforts to obtain factual injury data on household products has been a product liability claim survey directed to insurance companies. I think this is the first of this type that has ever been conducted.

Over 547 U.S. insurance companies which write product liability insurance for manufacturers were queried regarding accident reports on every closed case involving injuries during a 90-day period. Although this survey has not been completed, over 250 companies have already filed reports for an average of about 750 individual accident reports for each month. Because of the cooperation of the insurance industry, the money and manpower used by the Commission have been minimal-probably not in excess of 100 man-days and $5,000, including salaries. The data being collected are name of product, nature of injury, name of company, severity of injury and whether or not payment was made. The experience of the insurance companies reporting leads us to believe the information obtained is reliable within the limits set out by the Commission's request.

Other special surveys are being conducted by our task force on industry self-regulation. While much of the information does not bear directly on accidental injuries and products, there is supporting information in these areas. Special questionnaires have been developed for the following groups: Independent product testing laboratories; government testing laboratories; retail stores; manufacturers of consumer products; product services and repair; utility companies; standards organizations; professional societies and trade associations. These are in various stages of development-some have been pretested, some are two-thirds completed, others have not yet been approved by the Bureau of the Budget for distribution. Copies are available for the subcommittee and an individual progress report can be made on any that are of interest to this group.

Miscellaneous cases of accidental injuries are reported by physicians to the National Commission on Product Safety on an informal

basis.

Several hundred unsolicited consumer complaints have been received by the Commission with unverified product-related injuries reported in some of the letters. Since many of these are still under investigation and lack verification, we will not have an accurate tabulation until later this year.

Staff studies and investigations have been conducted on selected accidents reported in newspaper clippings and in referrals from other agencies. Referrals have come from Members of the Congress, the President's Committee on Consumer Interests, and from numerous other Government agencies and nongovernmental sources.

Analysis has been initiated on the 314 reports received from the FDA injury surveillance teams. While cooperation has been excellent from personnel assigned to the Cincinnati unit of the Office of Product Safety, we have not been able to obtain an additional 2,700 investigation reports because of reported lack of personnel, lack of constant access to duplicating equipment and more pressing priorities in that

office.

A bibliographic study has been initiated to survey the biomedical literature for information on product-related accidents. The source of this survey material is the National Library of Medicine and the Library of Congress. The number of citations obtained for 1966 and 1967 is 2,946. From this group, more than 300 articles have been selected for complete reading and analysis and are now in the process of being annotated and coded for inclusion in a central information system.

Final analysis of this information will not be completed for several months. The primary purpose of this data collection is to help define which products afford an unreasonable hazard to consumers. The information will provide guidance for future staff operations, leads for appropriate subjects to be explored in public hearings, information for referrals for existing regulatory agencies, and, most important, will guide the Commission in the preparation of its final report for presentation to the Congress and to the President.

Regarding the dissemination of data to other interested parties, we regularly refer consumer complaints regarding products not in our jurisdiction to the Federal Trade Commission, the Food and Drug Administration, the Department of Commerce, the President's Committee on Consumer Interests, the Department of Agriculture, and to concerned Members of the Congress. I might add that as a result of this fruitful exchange of information with Members of Congress, we have received excellent cooperation in handling complaints from constituents and assisting consumers and manufacturers' representatives in obtaining desired information.

Our Commission has an open information policy and considers nearly all of the information received as in the public domain. To date we have never refused a request for information from any source. The final report of the Commission will be a comprehensive published document which will be printed in quantity for wide distribution. To date we have, as published material in limited quantity, corrected transcripts of our hearings as part of the information available to the

public. We have published an interim report recommending amendments to the Hazardous Substances Act to include mechanical, thermal, and electrical hazards in the scope of the child protection amendments. Intermittently we have distributed news releases and other pertinent data regarding Commission activities. There has been no release of a published statistical analysis to date.

Unpublished data are available in certain categories. Copies of consumer complaints received by the Commission are sent to manufacturers of products identified in the complaint letters. They are asked to comment on the complaint and give us additional information on the named product. Copies of witnesses' testimony are provided to trade associations, manufacturers, consumer groups, and other government agencies upon request. Every effort is made to share fully the information acquired by the Commission.

A reproducible, continuing, statistically valid system for identification of consumer injuries related to household products is needed. In addition an indepth epidemiological investigation on selected products with high frequency and severity priorities will be necessary. There is a fundamental need for a national system of surveillance not just investigation teams located in two or three localities. Previous testimony before our Commission has cited the need for 10 to 20 additional permanent surveillance teams in the United States. The Department of Transportation, I understand, has seven interdisciplinary teams now operating and is providing for 20 additional teams in the transport accident field during the next fiscal year. We know of no proposal for additional surveillance teams in the budget request of any agency for fiscal 1970.

I might add the officials in the National Center for Health Statistics have been most cooperative. We understand a hospital survey for admissions to emergency rooms will be conducted by the Food and Drug Administration and there is consideration in other groups for house-to-house canvasses for information regarding injuries to families. These represent the major statistical needs of this Commission and any ongoing agency charged with responsibilities similar to ours. This operation, of course, must be coordinated with information derived from an analysis of death certificates, from abstracts of the pertinent literature and many other sources that would feed into an organized, automated data collection and analysis system. We are experimenting with a scientific indexing and retrieval system for this information and believe that a centralized data bank on accident injuries could be developed from this base. Additional work done by the cooperating Government agencies will be incorporated into the system.

This information clearinghouse and exchange could provide vitally needed information for consumers, attorneys, industries, community organizations and for other Government agencies including the Congress.

There is a wealth of information available in some States and localities concerning accidental deaths and injuries. No formal procedures now exist for tapping the supply of information except through special surveys or through the accumulation of official vital documents sent to the National Center for Health Statistics. Our Commission obtains information through the process of public hearings and

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