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	Rulema king	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	C orded	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	 th is 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	 informati on, 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,	 thePage 2

av ailability	 of	 cordless	 products, the	 projected	 societal	 costs	 associated	 with strangulation,	and	th e	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	m ore	complete	factual	record	for	CPSC’s	consideration		to	permit
a	well

- informed	analysis	before	conside ring	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	comple tion	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	wind ow	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	pro duct	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.”