February	2,	2015

VIA	EMAIL

Ms.	Alberta	Mills

Acting	Secretary

Division	of	the	Secretariat

Office	of	General	Counsel

U.S.	Consumer	Product	Safety	Commission

4330	East	West	Highway

Bethesda,	MD	20814

Re: Docket	ID:	CPSC-2013-0028	- Petition	for	Rulemaking	to	Eliminate	

Accessible	Cords	on	Window	Covering	Products

Dear	Ms.	Mills,

On	 behalf	 of	 the	 Window	 Covering	 Manufacturers	 Association,	 (WCMA),	 I	 write	 to

request	 an	 extension	 of	 time	 to	 comment	 on	 the	 Advanced	 Notice	 of	 Proposed	

Rulemaking	(ANPR)	for	Corded	Window	Coverings.

The	comment	period	 for	 this	ANPR	currently	closes	on	March	17,	2015.			On	behalf	of	

WCMA	and	its	members,	we	 respectfully	 request	a	75-day	extension	from	 this current	

deadline.	 	 We	 are	 requesting	 this	 extension	 because	 of	 the	 numerous	 studies and	

analyses	 that	 the	 industry	 is	 undertaking	 in	an	effort	 to	 provide	 the	 Commission	 with	

information	that	CPSC	admittedly	lacks	and	with	the	most	current	and	up-to-date	data.

We	appreciate	that	CPSC	acknowledged	in	its	staff	report	that	it	currently	does not	have	

sufficient	 data	 in	 a	 number	 of	 key	 areas	 and	 concludes	 the	 report	 with	 39 questions	

requesting	 information.	While	 CPSC	 attempted	 to	 obtain	 accurate	 information	 on	 the	

window	 covering	 industry	 and	 its	 products	 based	 on	 publicly	 available	 information,	

there	are	also	several	examples	where	the	data	was	either	incorrect	or	misinterpreted	

by	 CPSC	 staff.	 	 The	 reliance	 on	 a	 D&R	 International	 study	 that	 was	 submitted	 to	 the	

Department	 of	 Energy	 for	 a	 different	 purpose	 resulted	 in	 an	 incorrect	 analysis	 of the	

market	that	led	CPSC	to severely	undercount	the	number	of	businesses	engaged	in	the	

manufacture,	 sale	 and	 installation	 of	 window	 coverings.	 	 The	 staff	 analysis	 also	

incorrectly	concludes	that	three	manufacturers	account	for	almost	70	percent	of	dollar	

sales	in	 the	U.S.	window	 coverings	market.			Further,	 the	staff	report	 raises	 questions	

related	 to	 the	 effectiveness	 of	 the	 latest	 voluntary	 standard,	 the	
Page	2

availability	 of	 cordless	 products,	 the	 projected	 societal	 costs	 associated	 with	

strangulation,	and	the	costs	associated	with	the	remedy	that	the	petitioners	seek. 1

It	 is	 essential	 that	 the	 Commission	 and	 its	 staff	 have	 access	 to	 the	 most	 current	

information	 available.	 	Our	 request	 is	 based	 on	 the	 need	 for	 sufficient	 opportunity	 to	

develop	and	present	a	more	complete	factual	record	for	CPSC’s	consideration		to	permit	

a	well-informed	analysis	before	considering	whether	 the	agency	can	move to	 the	next	

stage	of	promulgating	such	a	significant	rule.		To	this	end,	WCMA	has	engaged	a	number	

of	 independent	 firms	 to	 conduct	 behavioral,	 consumer,	 and	 economic	 and	 statistical	

studies.		These	firms	have	indicated	to	us	that	they	cannot	meet	the	current	deadline	of	

March	17,	2015.		An	extension	of	75	days	from	the	current	deadline	of	March	17,	2015	

should	permit	completion	of	these	endeavors.		

Thank	you	for	your	consideration	of	this	request	and	please	do	not	hesitate	to	contact	

me	if	you	have	any	questions.

Sincerely,

Ralph	Vasami

Executive	Director

Window	Covering	Manufacturers	Association

CC: Chairman	Elliot	Kaye

Commissioner	Robert	S.	Adler

Commissioner	Ann	Marie	Buerkle

Commissioner	Joseph	Mohorovic

Commissioner	Marietta	S.	Robinson

																																																												 1 As	other	examples	of	inadequate	information,	the	report	states:

• CPSC	“does	not	have	precise	information	on	sales	of	cordless	window	coverings	(or	

window	coverings	with	inaccessible	cords).”	

• “The	Commission	has	insufficient	information	to	determine	how	the	costs	or	retail	

prices	of	safer	window	coverings	will	change	over	time.”

• CPSC	possesses	only	“some	anecdotal	information	on	product	compliance	and	incident	

hazard	patterns	that	lends	support	to	WCMA's	contention	that	products	substantially	

comply	with	the	voluntary	standard.”

• CPSC	“does	not	have	information	to	assess	the	effectiveness	of	public	education.”