This section of the FEDERAL REGISTER

contains notices to the public of the proposed

issuance of rules and regulations. The

purpose of these notices is to give interested

persons an opportunity to participate in the

rule making prior to the adoption of the final

rules.

Proposed Rules Federal Register

2327 

Vol. 80, No. 11 

Friday, January 16, 2015 

CONSUMER PRODUCT SAFETY 

COMMISSION 

16 CFR Chapter II 

[CPSC Docket No. CPSC–2013–0028] 

Corded Window Coverings; Request 

for Comments and Information 

AGENCY: Consumer Product Safety 

Commission. 

ACTION: Advance notice of proposed 

rulemaking. 

SUMMARY: The Consumer Product Safety 

Commission (the Commission or CPSC) 

has reason to believe that certain cords 

on window coverings may present an 

unreasonable risk of injury to young 

children. This advance notice of 

proposed rulemaking (ANPR) initiates a 

rulemaking proceeding under the 

Consumer Product Safety Act (CPSA). 

We invite comments concerning the risk 

of injury associated with corded 

window coverings, the regulatory 

alternatives discussed in this notice, the 

costs to achieve each regulatory 

alternative, the effect of each alternative 

on the safety, cost, utility, and 

availability of window coverings, and 

other possible ways to address the risk 

of strangulation posed to young children 

by window covering cords. We also 

invite interested persons to submit an 

existing standard or a statement of 

intent to modify or develop a voluntary 

standard to address the risk of injury 

described in this notice. 

DATES: Written comments in response to 

this notice must be received by March 

17, 2015. 

ADDRESSES: You may submit comments, 

identified by Docket No. CPSC–2013– 

0028, by any of the following methods: 

Electronic Submissions 

Submit electronic comments in the 

following way: 

Federal eRulemaking Portal: http://

www.regulations.gov. Follow the 

instructions for submitting comments. 

The Commission does not accept 

comments submitted by electronic mail 

(email), except through 

www.regulations.gov. The Commission 

encourages you to submit electronic 

comments by using the Federal 

eRulemaking Portal as described above. 

Written Submissions 

Submit written submissions in the 

following way: 

Mail/Hand delivery/Courier to: Office 

of the Secretary, Consumer Product 

Safety Commission, Room 820, 4330 

East West Highway, Bethesda, MD 

20814; (301) 504–7923. 

Instructions: All submissions received 

must include the agency name and 

docket number for this rulemaking. All 

comments received may be posted 

without change, including any personal 

identifiers, contact information, or other 

personal information provided, to: 

http://www.regulations.gov. Do not 

submit confidential business 

information, trade secret information, or 

other sensitive or protected information 

electronically. Such information should 

be submitted in writing. 

Docket: For access to the docket to 

read background documents or 

comments received, go to: http://

www.regulations.gov. 

FOR FURTHER INFORMATION CONTACT: 

Rana Balci-Sinha, Project Manager, 

Directorate for Engineering Sciences, 

Consumer Product Safety Commission, 

National Product Testing and 

Evaluation Center, 5 Research Place, 

Rockville, MD 20850; 301–987–2584; 

rbalcisinha@cpsc.gov. 

SUPPLEMENTARY INFORMATION: 

I. Background 

The purpose of this ANPR is to collect 

information related to a potential 

mandatory rule to address the risk of 

strangulation to young children on 

window covering cords. On October 8, 

2014, the Commission granted a petition 

to initiate a rulemaking to develop a 

mandatory safety standard for window 

coverings. The petition sought to 

prohibit window covering cords when a 

feasible cordless alternative exists. 

When a feasible cordless alternative 

does not exist, the petition requested 

that all window covering cords be made 

inaccessible by using passive guarding 

devices. The Commission granted the 

petition and directed staff to prepare 

this ANPR seeking information and 

comment on regulatory options for a 

mandatory rule to address the risk of 

strangulation to young children on 

window covering cords. 

This ANPR is based on information 

from staff’s December 31, 2014 Briefing 

Memorandum on Recommended 

Advance Notice of Proposed 

Rulemaking for Corded Window 

Coverings (ANPR Briefing 

Memorandum), available at http://

www.cpsc.gov/Global/Newsroom/FOIA/

CommissionBriefingPackages/2015/

Corded-Window-Coverings-AdvanceNotice-of-Proposed-Rulemaking.pdf, as 

well as CPSC staff’s October 1, 2014 

Staff Briefing Package in Response to 

the Petition CP 13–2, Requesting 

Mandatory Safety Standards for 

Window Coverings (Petition Briefing 

Package), available at: http://www.cpsc.

gov/Global/Newsroom/FOIA/

CommissionBriefingPackages/2015/

PetitionRequestingMandatoryStandard

forCordedWindowCoverings.pdf. 

Based on CPSC’s incident data, the 

Commission believes that certain 

window covering cords may present an 

unreasonable risk of injury, specifically 

strangulation, to young children. The 

Commission is aware of 184 reported 

fatal strangulations and 101 reported 

nonfatal strangulations from 1996 

through 2012 involving window 

covering cords among children 8 years 

and younger. Petition Briefing Package, 

Tab B. Using separate data from the 

National Center for Health Statistics 

(NCHS) and a CPSC study, CPSC 

estimates that on average, at least 11 

fatal strangulations related to window 

covering cords occurred per year in the 

United States from 1999 through 2010, 

among children under 5 years old. CPSC 

finds no observable trend in the data. Id. 

CPSC evaluated the risk of a fatal or 

nonfatal strangulation to children 

involving window covering cords. 

Based on various CPSC data sources 

(e.g., newspaper clippings, consumer 

complaints, death certificates purchased 

from states, medical examiners’ reports, 

and in-depth investigation (IDI) reports 

by CPSC staff), from 1996 through 2012, 

CPSC found, on average, about 11 

reported fatal strangulations, and on 

average, about six reported nonfatal 

strangulation incidents per year for 

children 8 years and younger. Id. 

Tab E of staff’s Petition Briefing 

Package analyzed the current voluntary 

standard for window coverings, ANSI/

WCMA A100.1–2014, American 

National Standard for Safety of Corded 


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Window Covering Products (ANSI/

WCMA standard or voluntary standard). 

CPSC engineering staff found that the 

current version of the ANSI/WCMA 

standard would not effectively address 

57 percent of the 249 window covering 

cord incidents investigated by CPSC 

staff. Two types of cords on window 

coverings continue to present a hazard 

to children: Pull cords and continuous 

loops. 

The Commission invites the public to 

review the information and ideas 

presented in this ANPR and to submit 

information and comments that would 

assist the Commission as it considers 

regulatory alternatives to reduce the 

strangulation risk to young children 

associated with corded window 

covering products. 

II. Window Covering Products 

Window coverings comprise a wide 

range of products, including shades, 

blinds, curtains, and draperies. In 

general terms, ‘‘hard’’ window 

coverings, composed of slats or vanes, 

are considered blinds; and ‘‘soft’’ 

window coverings that contain a 

continuous roll of material are 

considered shades. Both blinds and 

shades may have inner cords that cause 

a motion, such as raising, lowering, 

traversing, or rotating the window 

covering to achieve the desired level of 

light control. Curtains and draperies do 

not contain inner cords but may be 

operated by a continuous loop cord or 

beaded chain. The cord or loop that is 

manipulated by the consumer to operate 

the window covering is called an 

‘‘operating cord’’ and may be a pull cord 

(single cord or multiple cords) or 

continuous loops. Cordless window 

coverings are products designed to 

function without an operating cord but 

may contain inner cords. Petition 

Briefing Package, Briefing Memorandum 

at 9. 

A. Common Window Covering Products 

Following is a description of the most 

common window covering products and 

the types of cords associated with 

incidents for each window covering 

product. Cord types are based on CPSC’s 

review of the 249 IDIs completed by 

staff on window covering incidents. 

Petition Briefing Package, Briefing 

Memorandum Appendix, and Tab B at 

83–84. 

1. Horizontal blind (Figure 1): 

Horizontal blinds are made using 

horizontal slats. Slats vary in their 

length and width and are manufactured 

using metal, vinyl, wood, fabric, and 

other materials. Horizontal blinds are 

typically raised and lowered using pull 

cords. Pull cords are part of the inner 

cords that users interact with to raise or 

lower the blind. Inner cords are attached 

to the bottom rail and threaded through 

the horizontal slats to raise and lower 

them, as well as to adjust the slats for 

lighting. Slats can be tilted with various 

mechanisms, including tilt cords, a tilt 

wand, or in the case of a blind with no 

operating cords, by using the bottom 

rail. Cords associated with horizontal 

blind incidents include: continuous 

loop cord/beaded-chain (free-standing, 

i.e., not mounted on a tension device), 

inner cord, pull cord (with loops or long 

cords), and tilt cord. 

2. Cellular shade (Figure 2): Cellular 

shades are made of multiple layers of 

material that are formed into tubes or 

cells in a horizontal orientation. Cellular 

shades, often referred to as honeycomb 

shades, are constructed so that an air 

pocket, which mimics the shape of a 

bee’s honeycomb, is formed in the 

center of the shade. Cellular shades are 

typically raised and lowered using an 

operating cord. Inner cords that assist in 

raising and lowering the blind are 

between the layers of material and are 

visible from the side openings only. 

Cords associated with cellular shade 

incidents include: continuous loop 

cord/beaded-chain (free-standing) and 

pull cord (with loops, cord connectors, 

or long cords). 


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3. Pleated shade (Figure 3): Pleated 

shades are made of pleated or folded 

material in a horizontal orientation. The 

pleated material can be raised and 

lowered similar to cellular shades. 

Unlike cellular shades, pleated shades 

do not have an air pocket. Cords 

associated with pleated shade incidents 

include: Continuous loop cord/beadedchain (free-standing) and pull cord 

(with loops or long cords). 

4. Roller shade (Figure 4): Roller 

shades are comprised of a roller, a 

means of supporting the roller, and 

flexible sheets of material attached to 

the roller. When a roller shade is raised, 

the material is gathered on the roller 

located at the top of the shade. Cords 

associated with roller shade incidents 

include: Continuous loop cord/beadedchain (free-standing). 


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5. Roll-up blind (Figure 5): Roll-up 

blinds are made of flexible material, 

which rolls up from the bottom of the 

blind when the blind is raised. Roll-up 

blinds are typically raised and lowered 

using pull cords. Cords associated with 

roll-up blind incidents include: Pull 

cord (with loops or long cords) and 

lifting loop (wraps around the bottom of 

the product and enables the shade to 

roll up from bottom to top.). 

6. Roman shade (Figure 6): Roman 

shades are made of fabric or other 

material that is suspended from a head 

rail. As the shade is raised, the material 

gathers from the bottom upward, toward 

the head rail. Cords associated with 

Roman shade incidents include: 

continuous loop cord/beaded-chain 

(free-standing), inner cords, and pull 

cord (with loops or long cords). 


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1 D&R International, Ltd. (September 2013). 

Residential windows and window coverings: A 

detailed view of the installed base and user 

behavior (DOE/EE–0965). U.S. Department of 

Energy, Office of Energy Efficiency and Renewable 

Energy, Washington DC. September, 2013. 

Available at: http://energy.gov/eere/buildings/

downloads/residential-windows-and-windowcoverings-detailed-view-installed-base-and. 2 Ibid. 

7. Vertical blind (Figure 7): Vertical 

blinds are made using slats in a vertical 

orientation that can be stacked to one or 

both sides of the head rail. The head rail 

houses mechanisms that allow slats to 

traverse or rotate or both. Cords 

associated with vertical blind incidents 

include: Continuous loop cord/beadedchain (free-standing). 

8. Drapery/Curtain (Figure 8): 

Draperies and curtains are usually made 

of a fabric material that hangs in a 

window or other opening (e.g., sliding 

door). Cords can sometimes be used to 

open and close draperies and curtains. 

Cords associated with drapery and 

curtain incidents include: Continuous 

loop cord/beaded-chain (free-standing). 

B. Window Covering Market 

Based on 2011 data, more than 350 

manufacturers and more than 1,800 

retailers of window coverings operate in 

the United States. Petition Briefing 

Package, Tab G. Three manufacturers 

reportedly accounted for almost 70 

percent of dollar sales in the U.S. 

window coverings market in 2008. 

Retail prices for corded window 

coverings have a wide range. The type 

of material, brands, and operating 

mechanisms affect the price. Average 

prices for window coverings range from 

about $50 to $440 for shades and from 

about $10 to $360 for blinds. Retail 

prices for extremely large and custommade window coverings can be as high 

as $3,000. 

The Commission obtained window 

covering market information from a 

study conducted by the consulting firm 

D&R International (D&R, 2013).1 The 

Window Covering Manufacturers 

Association (WCMA), the organization 

that developed the existing voluntary 

standard, engaged D&R to conduct the 

study. D&R received funding for the 

study from WCMA and the U.S. 

Department of Energy (DOE), through 

Lawrence Berkeley National Laboratory 

(LBNL). Based on information from the 

D&R study, shipments of residential 

window coverings from manufacturers 

may have amounted to about 100 

million to 150 million units in the 

United States in 2012. D&R based these 

estimates on information (including 

shipment, pricing, retail and 

manufacturing data) provided by 

WCMA members, U.S. Census Bureau 

reports of vinyl blind imports, and data 

collected from a WCMA-funded Internet 

survey of U.S. households, which D&R 

also conducted as part of the study. 

WCMA participated in designing and 

implementing the Internet survey. D&R 

developed a research plan in 

consultation with WCMA, with input 

from LBNL. DOE, through LBNL, 

provided funding to analyze the Internet 

survey and prepare the report.2

Augmenting the D&R estimates with 

U.S. housing statistics, more than 1 

billion window coverings may be in use 


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3N. Marcy, G. Rutherford. ‘‘Strangulations 

Involving Children Under 5 Years Old.’’ U.S. 

Consumer Product Safety Commission, December 

2002. 

in U.S. homes. Petition Briefing 

Package, Tab G at 148–152. 

The Commission does not have 

precise information on sales of cordless 

window coverings (or window 

coverings with inaccessible cords), but 

based on CPSC discussions with 

industry participants and review of a 

major retailer’s Web site, sales of 

cordless window coverings may amount 

to as much as 25 percent of the market. 

CPSC compared the retail sales prices 

of cordless and corded products and 

found that manually operated cordless 

window coverings may cost about $15 

to $130 more than similar corded 

window coverings. The observed prices 

of motor-operated window coverings are 

more than $100 higher than the prices 

of corded window coverings, and the 

price differences can exceed $300. Some 

wand-operated vertical blinds cost 

about the same as corded versions; 

others appear to cost about $10 more 

than corded vertical blinds. The 

Commission has insufficient 

information to determine how the costs 

or retail prices of safer window 

coverings will change over time. Id. 

III. The Risk of Injury 

A. Incident Data Overview 

CPSC estimates that a minimum of 11 

fatal strangulations related to window 

covering cords, on average, occurred per 

year in the United States from 1999 

through 2010, among children under 5 

years old, based on National Center for 

Health Statistics (NCHS) data and a 

CPSC study.3 Petition Briefing Package, 

Tab B. Additionally, CPSC’s emergency 

department-treated injury data (National 

Electronic Injury Surveillance System or 

NEISS) demonstrate that from 1996 

through 2012, an estimated 1,590 

children received treatment for injuries 

resulting from entanglements on 

window covering cords based on NEISS 

data. Id. at 80–82. 

CPSC also receives incident data 

through newspaper clippings, consumer 

complaints, death certificates purchased 

from states, medical examiners’ reports, 

and IDI reports. Using data from these 

sources, CPSC found a total of 285 

reported fatal and nonfatal strangulation 

incidents from January 1996 through 

December 2012 involving window 

coverings among children 8 years of age 

or younger. These 285 incidents do not 

constitute a statistical sample of known 

probability and do not necessarily 

include all window covering, cordrelated strangulation incidents that 

occurred during that period. Given that 

these reports are anecdotal and 

reporting is incomplete, CPSC strongly 

discourages drawing any inferences 

based on the year-to-year increase or 

decrease shown in the reported data. Id. 

Of the 285 incidents, 184 resulted in 

a fatality. Among the nonfatal incidents, 

19 involved hospitalizations (7 percent). 

The long-term outcomes of these 19 

injuries varied from a scar around the 

neck, to quadriplegia, to permanent 

brain damage. In addition, 67 incidents 

(24 percent) involved less-severe 

injuries, some of which required 

medical treatment but not 

hospitalization. In the remaining 15 

incidents (5 percent), a child became 

entangled in a window covering cord 

but was able to disentangle him or 

herself from the cord and escape injury. 

Of the 285 total reported incidents 

involving window covering cords, CPSC 

staff reviewed the completed IDIs for 

249 incidents. Table 1 presents a 

breakdown of all 249 investigated 

incidents, by type of window coverings 

and type of cord. 

TABLE 1—DISTRIBUTION OF INVESTIGATED INCIDENTS BY TYPE OF WINDOW COVERING AND ASSOCIATED CORD 1996– 

2012 

Pull cord 

Continuous 

loop cord/ 

beaded-chain 

Inner cord Lifting loop Tilt cord Unknown Total 

(percentage) 

Horizontal ..................... 90 3 23 ........................ 2 13 131 (53%) 

Vertical ......................... ........................ 41 ........................ ........................ ........................ 2 43 (17) 

Roman .......................... 2 1 24 ........................ ........................ ........................ 27 (11) 

Curtain/drapery ............ ........................ 13 ........................ ........................ ........................ 1 14 (6) 

Cellular ......................... 5 5 ........................ ........................ ........................ ........................ 10 (4) 

Roller ............................ ........................ 6 ........................ ........................ ........................ ........................ 6 (2) 

Roll-up .......................... 2 ........................ ........................ 3 ........................ ........................ 5 (2) 

Unknown ...................... 2 1 ........................ ........................ ........................ 10 13 (5) 

Total ...................... 101 70 47 3 2 26 249 (100) 

Source: CPSC In-Depth Investigation File (INDP). 

Of the 249 incidents investigated by 

CPSC staff, 170 involved a fatality. 

Ninety-two (54 percent) of these fatal 

incidents involved a horizontal blind, 

36 (21 percent) involved a vertical 

blind, 14 (8 percent) involved a curtain/ 

drapery, eight (5 percent) a Roman 

shade, five (3 percent) a cellular shade, 

four (2 percent) a roll-up shade, and two 

(1 percent) a roller shade. Staff was 

unable to identify the window covering 

type in 9 (5 percent) of the 170 fatalities. 

Id. at 84–85. 

B. Physiology of Strangulation and 

Associated Injuries 

Young children are at risk of 

strangulation on corded window 

coverings. Strangulation due to 

mechanical compression of the neck 

involves obstruction of the airway 

passage and occlusion of blood vessels 

in the neck. Petition Briefing Package, 

Tab C. Strangulation can occur when a 

child’s head or neck becomes entangled 

in any position, even in situations 

where the body is fully or partially 

supported, in the event that a lateral 

pressure is sustained at a level resulting 

in vascular occlusion. Id. at 94. 

Strangulation can rapidly progress to 

anoxia, associated cardiac arrest, and 

death. Permanent, irreversible damage 

can occur if the delivery of oxygen to 

tissues is reduced. The severity of 

oxygen deprivation ultimately governs 

the victim’s chance for survival or the 

degree of neurological damage. 

Neurological damage may range from 

amnesia, loss of cognitive abilities due 

to hypoxic-ischemic injury to the 

hippocampus, mobility limitations, and 


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4Brouardel P. La pendaison, La strangulation, La 

suffocation, La submersion. JB Bailliere et fil, Paris, 

France, 1897; pp. 38–40. 5 Ibid. and Polson CJ. Hanging In: Polson CJ and 

Gee DJ (eds.) Essentials of forensic medicine, 

Oxford England, 1973 371–404. 6 Digeronimo RJ1, Mayes TC. Near-hanging injury 

in childhood: a literature review and report of three 

cases. Pediatr Emerg Care. 1994 Jun; 10(3):150–6; 

Hoff BH. Multiple organ failure after near-hanging. 

Crit Care Med 1978; 6:366–9. Howell MA; Iserson, 

K.V. Strangulation: A review of ligature, manual 

and postural neck compression injuries. Ann. 

Emerg. Med. 13:179–185, 1984; Polson CJ. Hanging 

In: Polson CJ and Gee DJ (eds.) Essentials of forensic 

medicine, Oxford England, 1973 371–404. 7Frankenburg, W.K., Dodds, J., Archer, P. et al.: 

The DENVER II Technical Manual 1990, Denver 

Developmental Materials, Denver, Co. 8Peterson, L., Ewigman, B., and Kivlahan, C., 

(1993) ‘‘Judgments Regarding Appropriate Child 

Supervision to Prevent Injury: The Role of 

Environmental Risk and Child Age.’’ Child 

Development, 64, 934–950. 

9 Vredenburgh, A.G., & Zackowitz, I.B., (2006). 

Expectations. In M. S. Wogalter (Ed.), Handbook of 

warnings (pp. 345–354). Mahwah, NJ: Lawrence 

Erlbaum Associates. 

10 DeJoy, D.M., (1999). Attitudes and Beliefs. In 

M. S. Wogalter, D. M. DeJoy, & K. R. Laughery 

(Eds.), Warnings and risk communication (pp. 189– 

219). Philadelphia: Taylor & Francis. 

loss of function, to long-term vegetative 

state. Experimental studies show that 2 

kg (4.4 lbs.) of pressure on the neck may 

occlude the jugular vein 4 and 3–5 kg 

(7–11 lbs.) may occlude the carotid 

artery.5 Minimal compression of any of 

these vessels can lead to 

unconsciousness within 15 seconds and 

death in 2 to 3 minutes (Digeronimo and 

Mayes, 1994; Hoff, 1978; lserson, 1984; 

Polson, 1973).6 The vagus nerve, 

responsible for maintaining a constant 

heart rate, is also located in the neck, in 

close proximity to the jugular vein and 

carotid artery. If the vagus nerve is 

compressed, cardiac arrest can result, 

due to mechanical stimulation of the 

carotid sinus-vagal reflex. Petition 

Briefing Package, Tab C at 94–95. 

The majority of incidents involving 

window covering cords resulted in 

death (184 of 285 incidents reviewed). 

Of the 19 incidents that required 

hospitalization, nine patients suffered 

severe neurological outcomes, such as 

cerebral edema, coma, loss of cognitive 

abilities, a loss of function or mobility, 

and quadriplegia. Some patients 

required intensive care, monitoring, 

lifelong care, and therapy. Four of the 

entanglement incidents occurred on the 

child’s arm or wrist and did not involve 

the neck. In 78 incidents involving the 

neck that were reported as minor or no 

injury, the child was found entangled in 

a cord or with the cord wrapped around 

the neck. In some incidents, the cord 

was wrapped so tightly that the child 

turned blue and had red marks or rope 

burns visible on the neck. Three 

children suffered temporary airway 

obstruction and were subsequently 

taken to the hospital. If the child had 

not been released from the cord, all of 

these nonfatal incidents could have had 

a more serious and even fatal outcome. 

Id. at 95. 

C. Population at Risk of Strangulation 

Corded window covering incidents 

involve children from about 7 months to 

8 years old. Petition Briefing Package, 

Tab C at 95. Incident data demonstrate 

that hazard scenarios involving window 

covering cords are consistent with child 

development milestones. Children go 

from total dependence on others to 

independence in their first 5 years of 

life. Petition Briefing Package, Tab D. 

Starting from around 3 months of age, 

children begin to grasp objects placed in 

their hands. By 6 months of age, most 

children master reaching and grasping 

objects within their reach. Children 

learn to stand by holding onto an object 

starting at around 8 months of age, and 

a month later, they can stand. At around 

10 months of age, children learn to 

stand without holding on to an object. 

Between 12 to 18 months of age, 

children progress from walking, to 

running, to walking up stairs, to 

climbing. As children gain new skills 

(e.g., sitting, standing, walking, running, 

climbing), they want to use and perfect 

those skills.7 The window covering cord 

incident data show that children 

climbed on beds, chairs, tables, and 

other furniture to interact with the 

window coverings. In some incidents, 

children were reportedly imitating 

superheroes or using the beaded chains 

as necklaces. Petition Briefing Package, 

Tab D at 101–102. 

Parents are advised to encourage 

children to start taking care of 

themselves beginning at around age 2 

years so that the children can learn 

independence and self-discovery. 

During these times of independence and 

exploration, children have less 

supervision. The degree of appropriate 

supervision is strongly linked to 

developmental level. Research shows 

that for preschool (birth to 4 years), 

constant supervision is required, except 

when children are in rooms in the home 

that are perceived as safe (living room/ 

bedroom) or in rooms that are deemed 

fairly safe (bathroom/garage/kitchen).8

Children’s bedrooms and living or play 

rooms are considered by caregivers to be 

the safest rooms in the home. A review 

of the incidents reported to CPSC shows 

that bedrooms, living rooms, family 

rooms, or TV rooms were the locations 

where most incidents occurred. These 

are rooms that caregivers perceive to be 

the safest rooms in the home, and thus, 

caregivers may be inclined to leave 

children alone in these rooms. Petition 

Briefing Package, Tab D at 102–103. 

Research demonstrates that the more 

familiar caregivers are with a product, 

the lower their recognition is of the 

product’s hazards.9 Increased 

familiarity, ease and frequency of use, 

and low price of a product reduce the 

likelihood that people will read warning 

labels. Consumers are highly familiar 

with window coverings and interact 

with window coverings daily. Even 

though no specific studies or surveys 

related to the use of safety devices for 

window coverings exist, research shows 

that the rate of compliance with 

instructions is lower when more effort 

and time (cost of compliance) are 

required to comply with the 

instructions.10

In some incidents, parents had seen 

the warning labels and were aware of 

the hazards of hanging cords and 

continuous loops. Parents used cord 

cleats, tied the cords together, or used 

other means to keep the cords out of 

reach of the child; however, the child 

was still able to access the cords and 

strangle. In other cases, parents did not 

use any safety devices. One reason for 

not using the safety devices is that the 

parents may have assumed the cords 

were not a problem because their child 

had not shown any interest in the 

window blind cords. In some incidents, 

safety devices, such as tie-down devices 

or cord cleats, were not used when the 

parents did not perceive a threat to the 

child. In a few cases, parents reported 

that that they had observed their child’s 

interaction with cords but did not think 

the cords were a danger. Petition 

Briefing Package, Tab D at 103–105. 

The Commission concludes that if 

cords are accessible and hazardous, 

window coverings will present a risk of 

strangulation to young children. 

Children cannot be supervised 100 

percent of the time, and they can 

strangle in a few minutes. Children will 

continue to explore their environment 

and interact with accessible window 

covering cords even when parents try to 

be conscientious and use safety devices 

on window coverings. Id. at 106. 

D. Hazard Scenarios Associated With 

Corded Window Covering Products 

Table 2 depicts the nine hazard 

scenarios CPSC staff found when 

reviewing 249 IDIs related to corded 

window covering incidents. 

BILLING CODE 6355–01–P 


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Table 2: Hazard Scenarios Associated with Corded Window Covering Products 

Scenario 

1. 

Loose pull cords can get knotted or 

tangled and create a loop in which 

children can strangle. 

Blinds or shades with multiple cords 

can create this hazard. 

2. One or more 

Children can wrap one or more long 

pull cords around their necks and 

strangle. 

Blinds and shades with single or 

multiple cords can create this hazard. 

When pull cords end in a single 

tassel, children can strangle in the 

loop above the tassel. 

Blinds or shades with pull cords 

ending in one tassel can create this 

hazard. 

Demonstration 

knotted or cords. 
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4. 

Children can insert their heads into 

the loop above the stop ball (or cord 

connector). 

Blinds or shades with stop ball (or 

cord connector) can create this 

hazard. 

Children can insert their heads and 

strangle in the loop created by tying 

the pull cord to another object, such 

as a curtain rod creating aU-shaped 

openmg. 

Blinds and shades with single or 

multiple cords can create this hazard. 

Children can insert their heads into 

the cord loop or beaded chain loop, 

which is not kept taut with a tension 

device. 

Vertical blinds and shades that 

operate with continuous loop system 

can create this hazard. 
2336 Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Proposed Rules 

BILLING CODE 6355–01–C IV. Efforts To Address the Hazard 

Associated With Corded Window 

Coverings 

A. Development of a Voluntary 

Standard 

1. Performance Requirements 

CPSC has been working with the 

window covering industry to address 

the hazards associated with corded 

window covering products for many 

years. Petition Briefing Package, Briefing 

Memorandum at 14–15, Table E, and 

Tab F. In 1995, CPSC staff began 

working with the WCMA on an ANSI/ 

WCMA standard to address accessible 

cords on window coverings. WCMA 

published the first version of the ANSI/ 

WCMA standard in 1996. The 1996 

standard sought to prevent strangulation 


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Children can pull the inner cord of a 

horizontal blind and create a large 

enough loop in which they can insert 

their heads and strangle. 

Children can insert their heads 

between the inner cord of a Roman 

shade and the shade material and 

strangle. 

Children can insert their heads into 

the lifting loop that slides off the 

roll-up shade and strangle. 

Petition Briefing Package, Briefing Memorandum Appendix and Tab E. 
Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Proposed Rules 2337 

11Changes to the descriptive text found in the 

ANSI/WCMA Standard, Appendix E, Figure E1, 

Row 3. 

incidents created by looped cords by 

requiring either: (a) Separate operating 

cords, or (b) a cord release device on 

multiple cords ending in one tassel. The 

standard also required a tension device 

that would hold the cord or bead loop 

taut when installed according to 

manufacturer’s instructions. 

In 2001, CPSC staff sent a letter to the 

WCMA asking for revisions to the 1996 

standard, including the addition of 

inner cord stops and the elimination of 

free-hanging cords or bead chains longer 

than the neck circumference of a fifth 

percentile 7- to 9-month-old child. In 

January 2002, CPSC staff sent a similar 

request by letter to WCMA. In August 

2002, the published ANSI/WCMA 

standard required inner cord stops. In 

2007, the published ANSI/WCMA 

standard required that tension devices 

partially limit the consumer’s ability to 

control the blind if the tension device is 

not properly installed. 

In 2009, WCMA published a 

provisional voluntary standard 

specifying descriptive requirements for 

Roman shades. CPSC staff sent a letter 

to the WCMA underscoring that the 

descriptive requirements still allowed 

inner cords to be accessible. In 

September 2010, WCMA published a 

stronger performance-based standard 

addressing Roman shade inner cords as 

another provisional standard. In 

November 2010, CPSC held a public 

meeting and WCMA announced that 

WCMA would establish a steering 

committee to oversee the activities of six 

task groups, including one intended for 

pull cords and another for continuous 

loops. At the CPSC public meeting, 

WCMA reiterated its intent to minimize 

the risks associated with pull cords and 

continuous loops and to draft revisions 

to the voluntary standard for balloting 

by the end of October 2011. 

On December 20, 2011, the WCMA 

balloted proposed revisions to the 

voluntary standard. On February 6, 

2012, staff sent WCMA a letter 

providing comments on the proposed 

revision. In these comments, CPSC staff 

reiterated that the hazardous loop 

determination should be made for all 

cords and that the length of an 

accessible operating cord should not be 

longer than the neck circumference of 

the youngest child at risk. In addition, 

staff raised concerns about the inability 

of tension devices to eliminate 

effectively or reduce significantly the 

risk of strangulation under certain 

foreseeable-use conditions. 

In November 2012, the WCMA 

announced the approval of the 2012 

version of the ANSI/WCMA standard, 

which includes: (1) Requirements for 

durability and performance testing of 

the tension/hold down devices, 

including new requirements for 

anchoring; (2) specific installation 

instructions and warnings; (3) new 

requirements for products that rely on 

‘‘wide lift bands’’ to raise and lower 

window coverings; (4) requirements for 

a warning label and pictograms on the 

outside of stock packaging and 

merchandising materials for corded 

products; and (5) expanded testing 

requirements for cord accessibility, 

hazardous loop testing, roll-up style 

shade performance, and durability 

testing of all safety devices. 

WCMA approved a revised ANSI/

WCMA standard on July 21, 2014.11

Section 4.3 of the 2014 ANSI/WCMA 

standard specifies that window 

coverings with an exposed operating 

cord or continuous loop operating 

system shall meet one of the following 

requirements: 

4.3.1: Product shall have no accessible 

operating cords 

4.3.2: Product shall have one or more 

separate operating cords 

4.3.3: Product shall contain a cord 

release device in the loop or head rail 

4.3.4: Product shall contain a 

permanently attached cord retraction 

device 

4.3.5: Product shall contain a cord shear 

device 

4.3.6: Product shall contain a cord 

shroud device 

4.3.7: Product shall contain a cord 

tension device 

4.3.8: Product shall contain a loop cord 

or bead chain-restraining device 

4.3.9: If the product requires a cord 

connector, i.e. stop ball, the exposed 

loop above the cord connector shall 

be limited to less than 3 inches below 

the bottom of the cord lock when the 

bottom rail is fully lowered. 

Thus, the ANSI/WCMA standard 

allows for separate operating cords, cord 

release devices, cord retractors, cord 

shrouds, cord tensioners, and loop/bead 

chain restraining devices. 

2. Warning Labels 

In addition to performance 

requirements, the ANSI/WCMA 

standard requires a number of warning 

labels and hangtags on window 

coverings, all of which are accompanied 

with a pictogram. ANPR Briefing 

Memorandum at 5. 

B. Substantial Compliance With the 

Voluntary Standard 

According to the WCMA, 

manufacturers of window coverings are 

in substantial compliance with the 

voluntary standard. Beyond WCMA’s 

comments, CPSC has no data on the 

extent of compliance and cannot 

estimate the proportion of annual sales 

of window covering products that 

comply. CPSC has 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. For example, the 

1996 version of the standard required 

that pull cords have separate tassels or 

a breakaway tassel to reduce the hazard 

with the loop above a single tassel. 

Among the incidents associated with 

the loop above a single tassel, staff’s 

review of incidents showed that only 

one product out of 14 products involved 

in incidents was manufactured after the 

1996 standard went into effect and did 

not comply with the requirement. 

Petition Briefing Package, Briefing 

Memorandum at 18. 

C. Engineering Staff’s Assessment of 

ANSI/WCMA Standard 

1. Performance Requirements 

For the Petition Briefing Package, the 

Division of Mechanical Engineering 

(ESME) reviewed the incident data to 

determine whether the 2014 version of 

the ANSI/WCMA standard would 

address the hazards presented in the 

249 IDIs reviewed by staff. Petition 

Briefing Package, Tab E. According to 

ESME staff’s assessment, the 2014 

version of the ANSI/WCMA standard 

addresses the hazards in 25.7 percent 

(64/249) of the investigated incidents, 

while hazards reported in 57 percent 

(141/249) are not addressed by the 

ANSI/WCMA standard. Insufficient 

information was available to draw any 

conclusions for the remaining 17.7 

percent (44/249) of investigated 

incidents. Id. at 123–124. 

Table 3 summarizes the hazard types 

identified in the 249 IDIs reviewed by 

CPSC staff, and ESME’s assessment of 

the hazard addressability with the 

current 2014 version of the voluntary 

standard. An Appendix to Tab E of the 

Petition Briefing Package includes more 

detailed descriptions of each of these 

hazard scenarios. 


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12http://www.cpsc.gov//PageFiles/170256/

WCMA_Ltr_22_July_2014.pdf. 

13http://www.cpsc.gov//PageFiles/170642/

WCMALettertoGBorlase8_29.pdf. 

TABLE 3—ADDRESSABILITY OF THE HAZARDS WITH THE 2014 ANSI/WCMA STANDARD

Entanglement mechanism 

(hazard scenario in Table 2) 

Number of 

incidents 

Investigated 

IDIs 

(%) 

Section of the standard related 

to the hazard Conclusion 

1. Entanglement from pull cords ................... 69 27.7 ....................................................................... Not addressed. 

14 5.6 ....................................................................... Addressed. 

Entanglement in a loop created by knotted 

or tangled pull cord (hazard scenario 1).

38 15.3 Section 4.3.2 allows multiple cords in unspecified lengths.Not addressed. 

Entanglement in one or more long cords, 

which the child wrapped around the neck 

(hazard scenario 2).

25 10.0 Sections 4.3.2 and 4.3.9 allow accessible 

free hanging operating cords.

Not addressed. 

Entanglement in a loop above a single tassel 

of the cord (hazard scenario 3).

14 5.6 Sections 4.3.2 and 4.3.3 require either separate cords or cords with release devices 

in the loop.

Addressed. 

Entanglement in a loop above the stop ball 

of the cord (hazard scenario 4).

4 1.6 Section 4.3.9 allows for an accessible loop 

when the bottom rail is fully raised.

Not addressed. 

Entanglement in a loop created when pullcord was tied to another object, usually on 

the wall (hazard scenario 5).

2 0.8 Section 4.3.2 allows unspecified length of 

cords.

Not addressed. 

2. Entanglement in a continuous loop cord 

(hazard scenario 6).

70 28.1 Section 4.3.7 requires a cord tension device 

that will at least partially prevent the operation of the window covering, when not 

installed but still allows some operability.

Not addressed. 

3. Entanglement from inner cords (hazard 

scenarios 7 and 8).

47 18.9 Section 4.4 addresses accessibility and 

hazardousness of inner cord loops.

Addressed. 

4. Entanglement in the lifting loop of a roll-up 

shade (hazard scenario 9).

3 1.2 Section 4.4.5 addresses the accessible lifting loops of a roll-up style shade.Addressed. 

5. Entanglement in the tilt cords (hazard scenario 2).2 0.8 Section 4.3.2 allows multiple cords in unspecified lengths.Not addressed. 

6. Unknown .................................................... 44 17.7 ....................................................................... Unknown. 

Although the standard does address a 

portion of the hazards associated with 

pull cords, remaining pull cord hazards 

and continuous loop cords account for 

more than 50 percent of the hazard 

scenarios that are not addressed by the 

standard. 

Continuous Loops. Continuous loops 

need to be kept taut so that the freestanding loop does not cause a hazard 

to young children. The voluntary 

standard requires a tension device to be 

attached on the loop by the 

manufacturer. After receiving the 

product, the consumer must install the 

tension device on an external surface, 

such as a wall or window sill, per 

manufacturer’s instructions. As 

explained in the ESHF memorandum, 

Tab D of the Petition Briefing Package, 

compliance with instructions declines if 

the effort and time required for the 

installation is high. The first publication 

of the voluntary standard (1996) 

required that a cord tension device be 

supplied and removal of it is a 

sequential process (i.e., requires two or 

more independent steps to be performed 

in a specific order). Once the tension 

device is installed, it becomes a passive 

device. 

In 2007, the voluntary standard 

introduced the ‘‘partial inoperability 

clause,’’ which meant that if the tension 

device was not properly installed, the 

tension device should at least partially 

prevent the operation of the window 

covering. The latest version of the 

standard includes the same partial 

inoperability requirement, in addition to 

a new durability test procedure to 

prevent the tension device, if installed, 

from coming off the wall or breaking 

under the tested conditions. 

Pull Cords. For the Petition Briefing 

Package, ESME staff concluded that the 

voluntary standard does not address the 

following hazard scenarios: (1) Loops 

resulting from knotted or entangled pull 

cords, (2) pull cords that are wrapped 

around the neck, (3) pull cords that are 

tied to another object, and (4) pull cords 

with loops above stop ball/cord 

connector. The recently published 

Canadian standard (CAN/CSA–Z600–14 

Safety of Corded Window Covering 

Products) adopts the requirements of the 

ANSI/WCMA standard with one change: 

adding cord cleats as a required 

component to mitigate the pull cord 

hazard. CPSC understands that for the 

spirit of harmonization, WCMA will 

propose to include a similar 

requirement to the ANSI/WCMA 

standard. 

CPSC staff has raised concerns 

regarding the pull cord and continuous 

loop hazards to WCMA, repeatedly 

emphasizing that either eliminating 

access to the pull cords or making 

accessible cords nonhazardous in both 

raised or lowered heights of the window 

covering would greatly reduce the 

incidents. Most recently, on July 22, 

2014, CPSC staff sent a letter to WCMA 

suggesting revisions to the voluntary 

standard that would address the 

strangulation hazard created by pull 

cords and continuous loops on window 

coverings.12 WCMA responded to staff’s 

letter on August 29, 2014.13 ANPR 

Briefing Memorandum at 4. 

WCMA believes that cord cleats, a 

device around which a cord can be 

wound and can be attached to a wall or 

other structure, or that is integral with 

the product, can help reduce incidents 

associated with pull cords. WCMA 

intends to utilize an expedited approval 

process to add cord cleats as a 

requirement to the ANSI/WCMA 

standard with the objective of 

harmonizing the standard with the latest 

version of the Canadian standard (CAN/ 

CSA Z600 window covering standard). 

Staff has several concerns with cord 

cleats. Cord cleats require that the user 

remove and then secure the cord to the 

cleat each time the window covering is 

raised or lowered in order to mitigate 

the hazard, which consumers may feel 

to be a nuisance and not do, thus 

voiding the protections ostensibly 

provided. In addition, failure to install 

a cord cleat will not cause the window 

covering to cease operating as intended, 

which may also serve to reduce the 


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14 IDI 110103CCC3322. 

15 IDI 050407CCC3309. 

16http://www.cpsc.gov/PageFiles/121510/

5009a.pdf. 

17A permanent marking or label cannot be 

removed or, during an attempt to manually remove 

it without the aid of tools or solvents, the marking 

or label tears apart or damages the surface to which 

it is attached. 

18Operational hangtags contain information 

based on the characteristics of the product or the 

safety devices included on the product. 

protection provided. Indeed, many stock 

products already come with cord cleats 

in the box, so the degree to which they 

are installed and used is in question. 

For example, in a 2010 incident, a fouryear-old child who was standing on the 

back of a couch, reached the pull cords 

which were usually wrapped around the 

cord cleat, but not on the day of the 

incident.14 When cord cleats are 

installed, consumers still need to be 

aware that children can climb up to get 

to the cords, as observed in a 2005 

incident where a four-year-old child 

moved a small plastic table near to a 

window, climbed upon the table, 

reached up and removed the pull 

cord.15 Furthermore, even if cleats are 

used to wrap excess pull cords, the 

cords above the cleat present a 

strangulation hazard.16 A cord cleat 

retrofit program may be beneficial for 

those consumers who become aware of 

the hazard and want to take action to 

mitigate the pull cord hazard. However, 

staff believes that consumers who 

respond to a recall likely install and use 

cord cleats more consistently than 

consumers who are unaware of the 

hazard. The latter group of consumers 

may overlook the cord cleat as they are 

not aware of the hazard, and the 

operation of the product does not 

necessitate the installation and use of 

cord cleats. 

Regarding continuous loops and 

tension devices, CPSC staff’s IDI review 

of 70 incidents associated with 

entanglement in a continuous loop cord 

showed that the majority of the incident 

units did not have a tension device 

installed on the continuous loop. Staff 

recognizes that tension devices, when 

properly installed and intact, keep the 

looped cords taut and do not allow a 

child’s head to enter into the loop. If 

tension devices are not installed, are 

installed improperly, or are removed 

from the cord, a hazardous loop is 

present. ANPR Briefing Memorandum at 

4. 

2. Warning Labels 

Warning labels are intended to alert 

the user of the strangulation hazard, and 

to keep cords away from children and 

move furniture away from cords as 

children can climb on furniture to reach 

cords. Warning labels and hang tags 

have been part of the ANSI/WCMA 

standard since its first publication in 

1996. In 2009, the voluntary standard 

required a hang tag that must be 

attached to the lower most section of the 

inner cord on the back side of a Roman 

shade. The voluntary standard was 

amended in 2012 to require that a 

warning label be placed on the product 

package (or on merchandising material 

for custom products) and displayed 

conspicuously. The requirement to 

include warnings on retail packaging 

and merchandising materials was 

intended to warn consumers about the 

strangulation hazard associated with 

accessible cords so that consumers can 

make an informed purchasing decision. 

Staff believes that the requirement to 

place a warning on product packaging is 

potentially beneficial for consumers 

who either learn of the hazard by 

reviewing the warning material on 

packaging or are aware of the hazard 

and looking for a safer product to 

purchase. However, consumers who are 

not the original purchasers of the 

product will not benefit from 

information included on packaging 

materials as the packaging is discarded 

after the product is installed. 

The ANSI/WCMA standard requires 

permanent warning labels 17and 

operational hangtags 18 on the product 

that follow ANSI Z535.4, American 

National Standard for Product Safety 

Signs and Labels. Research 

demonstrates that warning labels should 

first be visible and noticeable. Warning 

labels should also have design 

characteristics that encourage the user 

to stop and read the warning. Effective 

labels state the hazard, explain the 

consequences of the hazard, and 

provide instructions on how to avoid 

the hazard using explicit text to improve 

comprehension. Staff believes that 

warning labels on window coverings 

that comply with the ANSI/WCMA 

standard have design characteristics to 

make them visible and noticeable. For 

example, warnings that are placed 

directly on the product have higher 

noticeability compared to the warnings 

listed in a ‘‘distant’’ instruction manual 

(Wogalter et al., 1987). Additionally, the 

voluntary standard requires the word 

‘‘Warning’’ in all capital letters and 

printed in an orange color. The required 

warning messages that are on the 

warning labels and hang tags explain 

the nature of the hazard, the 

consequences of the hazard, and 

provide instructions on how to avoid 

the hazard, as recommended in the 

warning literature (Wogalter and 

Laughery, 2006). Finally, the required 

labels have a pictogram which should 

increase their noticeability because 

pictograms help capture user’s attention 

(Wogalter and Leonard 1999). 

Even though the warning labels 

required by the ANSI/WCMA standard 

meet the usual criteria for what is 

considered a well-designed warning 

label, CPSC staff believes that the labels 

have limited effectiveness in changing 

the user’s behavior in the purchase and 

use of window coverings. The inherent 

problem with the strangulation hazard 

associated with window covering cords 

and warning labels is that people are 

less likely to read instructions or 

recognize potential hazards associated 

with the products that they use more 

frequently (Godfrey et al., 1994). 

Research demonstrates that high 

familiarity with a product can lower a 

user’s inclination to read warnings or 

reduce the likelihood that the user will 

believe such information, lowering the 

rate of compliance with the warning 

(Riley, 2004). Window coverings are 

decorative products providing utility 

and found in every household in one 

form or another. Consumers interact 

with window coverings daily and 

experienced users are likely to repeat 

behaviors with little conscious thought, 

especially on a product that they have 

had numerous prior experiences (Riley, 

2004). 

Even after users notice and read the 

warning label, comprehend the message 

and make the decision to follow the 

instructions, they must comply with the 

warning as instructed to mitigate the 

hazard. User’s actual ability to comply 

with a warning is affected by cost of 

compliance, which includes effort, time, 

and perceived compromise in product 

performance as well as expense. In the 

case of window coverings, safety 

recommendations other than purchasing 

inherently safe products (e.g., cordless 

products or products with inaccessible 

cords), such as keeping cords out of 

reach of children, moving the furniture 

away from cords, installing a tension 

device to the wall or floor, and 

installing cord cleats, entail significant 

limitations or high cost of compliance. 

For example, depending on the room 

design limitations, consumers may not 

have the ability to keep cords away from 

furniture. Additionally, requiring 

consumers to wrap the pull cords 

around the cord cleat each and every 

time the window covering is raised or 

lowered leads to potential errors, such 

as forgetting the intended action during 

the routine use of the product. ANPR 

Briefing Memorandum at 5–6. 


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D. Available Technology To Address the 

Hazard 

Although not currently mandatory, a 

variety of technologies currently used 

by window covering manufacturers on 

window covering products eliminate the 

risk of strangulation to young children. 

CPSC’s engineering staff reviewed 

window covering products currently on 

the market that incorporate technologies 

to address the hazard associated with 

corded products. Petition Briefing 

Package, Tab E at 130–136. Available 

products that address the hazard 

include, but are not limited to: Manual 

and motorized cordless window 

coverings, cord shrouds, and cord 

retractors. 

Cords can be made inaccessible with 

passive guarding devices. Passive 

guarding devices allow the user to 

operate the window covering without 

direct interaction of a hazardous cord. 

These types of devices would include 

cord shrouds, integrated cord/chain 

tensioners, or cord retractors. 

Cordless blinds and shades are raised 

and lowered by pushing the bottom rail 

up or pulling the rail down. This same 

motion may also be used to adjust the 

position of the horizontal slats for light 

control. Through market research, staff 

found several examples of cordless 

blinds that can be made with a 

maximum height 84’’ and a maximum 

width of 144’’. 

Rigid cord shrouds (Figure 9) can be 

retrofitted over various types of window 

coverings to enclose pull cords and 

continuous cord loops. An encased 

clutch system allows the user to utilize 

the pull cords in the cord shroud while 

eliminating access to the hazardous 

cords. 

Loop cord/bead chain restraining 

devices (Figure 10) keep the looped 

bead chain taut, preventing access to a 

hazardous loop, and do not require 

external components to be installed. 

Crank mechanisms (Figure 11) replace 

the continuous loop mechanism with a 

crank/wand mechanism. Because the 

operating cord is replaced with a wand, 

the strangulation hazards are completely 

removed. 


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Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Proposed Rules 2341 

Cord retractors (Figure 12) passively 

retract the operating cord within 6 

inches of the head rail. These devices 

are intended to keep the operating cords 

out of the child’s reach. Through market 

research, staff found several examples of 

cord retractors that can be used on 

window coverings with a maximum 

height of 120’’ and a maximum width of 

174’’. 

Cordless motorized blinds are raised 

and lowered using an electric motor 

with a supplied controller. These 

products function in a manner similar to 

the motorized projector screens. 

Because these products use a motor 

instead of a pull cord, there are no 

exposed hazardous cords. 

Table 4 groups the hazard patterns 

with the appropriate available 

technologies. 

TABLE 4—HAZARD PATTERNS WITH AVAILABLE TECHNOLOGIES

Hazard Products ANSI/WCMA requirements 

Does the ANSI/WCMA 

Standard effectively address the hazard per engineering staff’s assessment 

Available 

technology 

(commercially available or 

in prototype stage) to 

address hazard 

Hazard 1. Loops created 

by knotted or tangled 

cord.

Horizontal blinds, Cellular 

shades, Roll up blinds, 

Roman shades, Pleated 

shades.

4.3.2 The product shall 

have one or more separate operating cords.

No—free hanging, exposed operating cords 

are permissible.

Cordless window coverings, rigid cord 

shrouds, crank mechanisms, cord retractors, 

cordless motorized window coverings. 


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TABLE 4—HAZARD PATTERNS WITH AVAILABLE TECHNOLOGIES—Continued 

Hazard Products ANSI/WCMA requirements 

Does the ANSI/WCMA 

Standard effectively address the hazard per engineering staff’s assessment 

Available 

technology 

(commercially available or 

in prototype stage) to 

address hazard 

Hazard 2. One or more 

long cords which the 

child wrapped around 

the neck involving pull 

cords and tilt cords.

Horizontal blinds, Cellular 

shades, Roll up blinds, 

Roman shades, Pleated 

shades.

4.3.2 The product shall 

have one or more separate operating cords.

4.3.9 The product shall, if 

it requires a cord connector, limit the exposed 

loop above the cord 

connector to less than 3 

inches below the bottom 

of the cord lock when 

bottom rail is in the fully 

lowered position. 

No—accessible, free hanging cords can be 

wrapped around the 

neck of a child as incident data demonstrates.

Cordless window coverings, rigid cord 

shrouds, crank mechanisms, cord retractors, 

and, cordless motorized 

window coverings. 

Hazard 3. Loop above a 

single tassel of the cord.

Horizontal blinds, Cellular 

shades, Roll Up blinds, 

Roman shades, Pleated 

shades.

4.3.2 The product shall 

have one or more separate operating cords.

4.3.3 The Product shall 

contain a cord release 

device in the loop or the 

head rail. 

Yes—by requiring either 

separate tassels on 

each cord or breakaway 

tassel, however this separate tassel configuration presents a wraparound (hazard #1) or 

knotted loop (hazard#2) 

strangulation hazards as 

described above.

Hazard 4. Loop above the 

stop ball of the cord.

Horizontal blinds, Cellular 

shades, Roll up blinds, 

Roman shades, Pleated 

shades.

4.3.9 The cord connector 

shall limit the exposed 

loop above the cord 

connector to less than 3 

inches below the bottom 

of the cord lock when 

the bottom rail is fully 

lowered.

No—a product that meets 

the standard could still 

contain an accessible 

hazardous loop when 

the bottom rail is raised.

Cordless window coverings, rigid cord 

shrouds, crank mechanisms, cord retractors, 

and, cordless motorized 

window coverings. 

Hazard 5. Loop created 

when pull-cord was tied 

to another object, usually 

on the wall.

Horizontal blinds, Cellular 

shades, Roll up blinds, 

Roman shades, Pleated 

shades.

4.3.2 The product shall 

have one or more separate operating cords.

No—consumers may attempt to keep the long 

cords away from children by tying the cords 

on a curtain rod or other 

means.

Cordless window coverings, rigid cord 

shrouds, crank mechanisms, cord retractors, 

and, cordless motorized 

window coverings. 

Hazard Unknown manner 

(involving a pull cord).

Horizontal blinds, Cellular 

Shades, Roll Up blinds, 

Roman Shades, Pleated 

shades.

N/A .................................... Unknown ........................... Unknown. 

Hazard 6. Entanglement in 

a continuous loop cord.

Vertical blinds, Roller 

shades, Curtains and 

draperies.

4.3.7 The product shall 

contain a cord tension 

device that will at least 

partially prevent the window covering from functioning for light control or 

privacy when not installed.

No—hazardous loops are 

not effectively addressed 

by the standard when 

the blind continues to be 

operational, despite the 

fact that the tension device is not properly installed.

Loop cord/bead restraining 

device, crank mechanisms, motorized option. 

Hazard 7a. Entanglement 

from exposed inner 

cords with no cord stops.

Horizontal blinds ............... 4.4.1 the product shall 

have no inner cords.

4.4.2 no accessible inner 

cords.

4.4.3 accessible inner 

cords shall pass the 

hazardous loop test.

4.4.3.1 inner cord stop 

devices or cord connectors shall be positioned 

3 inches or less below 

the head rail.

4.4.4 shrouded inner 

cords.

Yes—window coverings 

associated with the inner 

cord hazard scenario 

appeared to be older 

products that were manufactured before the 

2002 standard was published. Engineering staff 

believes that had the 

cord stops involved in 

the incident scenarios 

met the voluntary standard, they would not likely 

have occurred.


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TABLE 4—HAZARD PATTERNS WITH AVAILABLE TECHNOLOGIES—Continued 

Hazard Products ANSI/WCMA requirements 

Does the ANSI/WCMA 

Standard effectively address the hazard per engineering staff’s assessment 

Available 

technology 

(commercially available or 

in prototype stage) to 

address hazard 

Hazard 7b. Entanglement 

from exposed inner 

cords when the cord 

stops are positioned too 

low.

Horizontal blinds ............... 4.4.1 the product shall 

have no inner cords.

4.4.2 no accessible inner 

cords.

4.4.3 accessible inner 

cords shall pass the 

hazardous loop test.

4.4.3.1 inner cord stop 

devices or cord connectors shall be positioned 

3 inches or less below 

the head rail.

4.4.4 shrouded inner 

cords.

Yes—window coverings 

associated with the inner 

cord hazard scenario 

appeared to be older 

products that were manufactured before the 

2002 standard was published. Engineering staff 

believes that had the 

cord stops involved in 

the incident scenarios 

met the voluntary standard, they would not likely 

have occurred.

Hazard 8. Entanglement in 

the Roman shade inner 

cord.

Roman shades .................. 4.4.1 the product shall 

have no inner cords.

4.4.2 no accessible inner 

cords.

4.4.3 accessible inner 

cords shall pass the 

hazardous loop test.

4.4.3.1 inner cord stop 

devices or cord connectors shall be positioned 

3 inches or less below 

the head rail.

4.4.4 shrouded inner 

cords.

Yes—the requirements 

prevent hazardous inner 

cords that may allow 

child’s head to be inserted to the loop.

Hazard 9. Entanglement in 

the lifting loop.

Roll up blind ...................... 4.4.5 accessible inner 

cords shall feature an 

inner cord release device.

Yes—the lifting loop shall 

be pulled 48 times in 

various directions. The 

lifting loop shall breakaway with an average 

force not to exceed 3 

pounds. This test mimics 

the force that may be 

exerted due to the 

child’s head being in the 

loop.

E. Compliance Actions 

Compliance staff began working with 

WCMA in 1994, when CPSC announced 

a joint recall with the WCMA on how 

to eliminate the loops on pull cords 

ending in one tassel. Petition Briefing 

Package, Tab F. The WCMA created the 

larger Window Covering Safety Council 

(WCSC) to include window covering 

manufacturers and retailers to support 

the recall and to provide free repair kits 

to consumers. In 1999, after an 

extensive review of the incidents 

reported to CPSC, Compliance staff 

began a new investigation of window 

covering deaths resulting from inner 

cords of horizontal blinds. In 2000, 

CPSC and WCMA again announced a 

joint recall involving inner cord stops to 

reduce the risk of a child pulling on the 

inner cords and creating a hazardous 

loop. Id. at 142–143. 

In 2005, Compliance staff learned of 

a nonfatal incident involving the inner 

cord of a Roman shade. Subsequently, 

CPSC investigated a worldwide retailer 

following a child’s death from the inner 

cord of a Roman shade. In 2008, CPSC 

and the retailer announced a joint recall 

for Roman shades, offering a full refund 

to consumers. In 2009, CPSC and 15 

manufacturers and retailers in 

conjunction with the WCSC, announced 

individual recalls of Roman shades and 

roll-up blinds. In 2012, two more recalls 

occurred: One involving horizontal 

blinds manufactured without inner cord 

stops and vertical blinds manufactured 

without tension devices, and the second 

recall to repair and correct an assembly 

error in a breakaway cord connector. Id. 

at 143–145. 

F. Public Education 

Since the window covering-related 

first safety alert was issued in 1985, 

CPSC has been warning parents of the 

danger of child strangulation due to 

corded window coverings. Petition 

Briefing Package, Briefing Memorandum 

at 19. CPSC identified window 

coverings as one of the top five hidden 

home hazards.19 Every October, CPSC 

participates jointly with WCSC in 

National Window Covering Safety 

Month to urge parents and caregivers to 

check their window coverings for 

exposed and dangling cords and to take 

precautions. Both CPSC and WCSC 

recommend cordless window coverings 

or window coverings with inaccessible 

cords in homes where young children 

live or visit. In addition to traditional 

communication methods, CPSC reaches 

out to consumers using social media, 

such as safety blogs and online chats, 

the Neighborhood Safety Network, and 


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20 Ibid. 

through partnerships (such as with the 

Department of Defense) to create 

awareness of the hazards associated 

with corded window coverings. CPSC 

does not have information to assess the 

effectiveness of public education 

campaigns. 

V. Existing Standards for Window 

Covering Products 

A. ANSI/WCMA Standard 

Although no mandatory window 

covering standard exists in the United 

States, the 2014 version of the ANSI/ 

WCMA voluntary standard establishes 

safety performance requirements.. The 

standard applies to all interior corded 

window covering products sold in the 

United States and includes, but is not 

limited to, cellular shades, horizontal 

blinds, pleated shades, roll-up style 

blinds, roller shades, Roman style 

shades, traverse rods, and vertical 

blinds. The standard was first published 

in 1996, and subsequently was revised 

six times. The latest version was 

published in 2014. Section IV.A–C of 

this ANPR review provisions in the 

ANSI/WCMA standard intended to 

address the hazard creating by corded 

window coverings. 

B. International Standards 

Three international standards specify 

requirements for the safety of window 

coverings: 

(1) Competition and Consumer 

(Corded Internal Window Coverings) 

Safety Standard 2014 published in 

Australia (Australian standard), 

(2) Corded Window Covering Products 

Regulations (SOR/2009–11) and CAN/ 

CSA–Z600–14 Safety of Corded Window 

Covering Products published in Canada, 

which is based on the 2012 ANSI/ 

WCMA standard with some 

modifications (Canadian standard), and 

(3) EN 13120:2009+A1:2014 Internal 

blinds—Performance requirements 

including safety, EN 16433:2014 

Internal blinds—Protection from 

strangulation hazards—Test methods, 

and EN 16434:2014 Internal blinds— 

Protection from strangulation hazards. 

Requirements and test methods for 

safety devices published by European 

Committee for Standardization 

(European standard). 

CPSC engineering staff compared the 

ANSI/WCMA standard with the 

international standards and concluded 

that the ANSI standard developed by 

WCMA is one of strongest standards in 

the world. Petition Briefing Package, 

Tab E at 124–130. 

1. Australian Standard 

Australia has a mandatory product 

safety standard requiring the provision 

of information, warnings, instructions, 

and safety devices with corded internal 

window coverings (CIWC). A new 

regulation has been enacted requiring 

those installing CIWC in trade or 

commerce to follow the safety 

instructions when installing the product 

and avoid the production of dangerous 

lengths or loops of cord. 

A corded internal window covering 

must be installed to meet the following 

four requirements: 

a. A loose cord cannot form a 220 mm 

loop or longer at less than 1600 mm 

(62.99 in.). 

b. The product must be installed 

using the installation instruction on the 

retail packaging and any other provided 

information about how to ensure a loose 

cord cannot form a loop described in 

requirement 1. 

c. No part of the cord guide (a device 

designed to retract, tension, or secure a 

cord) may be installed lower than 1600 

mm above floor level unless: 

i. The cord guide will stay attached to 

the wall when subjected to 70 N applied 

in any direction for 10 seconds. 

ii. The cord is sufficiently secured or 

tensioned to prevent the formation of a 

loop 220 mm or longer. 

d. If a cleat is used to secure a cord, 

it must be installed at least 1600 mm 

above the floor level. 

CPSC does not believe the use of a 

cord cleat is effective to address the 

strangulation risk.20 First, a cord cleat 

needs to be actively installed and used 

every time. Second, the cord cleat needs 

to be installed at a height not accessible 

to a child. If the child had access to the 

cord cleat, the resulting hazard would 

be similar to hazard 5: Loop created 

when pull-cord was tied to another 

object, usually on the wall. Finally the 

cord cleat needs to take up all the excess 

slack in the cord; excess cord slack 

could pose a hazard similar to the 

hazard created by loops created by 

knotted or tangled cord or one or more 

long cords which the child wrapped 

around the neck (see Table 3). 

2. Canadian Standard 

Canada’s most recent standard, CAN/ 

CSA–Z600–14, is the 2012 ANSI/WCMA 

standard with the inclusion of cord 

cleats. Cord cleats are required for 

window coverings with accessible cords 

and shall allow complete cording length 

to be accumulated on the cleat. 

Instructions on how to properly use the 

cord cleats are also required. Consumers 

will be advised that the cord cleats that 

are external to the product should be 

installed at a height of 1.6 m above the 

floor, while cord cleats integral to the 

product shall be within 18 inches of the 

head rail. CPSC maintains the same 

opinion about cord cleats as explained 

above in section V.B.2 regarding the 

Australian standard. 

3. European Standard 

Many differences exist between the 

WCMA and European standards, with 

each standard having areas of strength 

and weakness. Table 5 compares the 

operating cord requirements of the 

ANSI/WCMA standard and the 

European standard. 


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TABLE 5—COMPARISON OF ANSI/WCMA STANDARD WITH THE EUROPEAN STANDARD

Test ANSI/WCMA 

A100.1–2014 EN Standard Summary 

Cord Release Device/Cord Shear 

Device vs. Breakaway System.

Cord Release Device & Cord Shear Device: 

*Create a 3.5 foot loop from the cord and 

hook a force gage onto it 

*Twist the force gauge 360 degrees and 

draw the force gauge at a speed between 

.1 and 1 inch per second. The cord shall 

release within 10 seconds. 

*Repeat for 50 products 

*The average release force shall not exceed 

3 pounds for the 50 products and all products shall have a release force below 5 

pounds. 

Breakaway system: 

*If installation height is not 

given, the length of pull 

cord(s) shall be less than 

or equal to 2⁄3 of the 

height of the curtain. 

*If the installation height is 

given, the pull cords shall 

be at least .6 m above the 

floor. 

*The hazardous loop shall 

be eliminated when a 

mass of 13.22 pounds is 

gradually applied to the 

pull cords within 5 seconds of application. 

The ANSI/WCMA standard appears to be more conservative 

because it requires the cord to 

break away at an average of 3 

pounds, compared to EN’s 

13.22 pounds. 

Cord tension vs. 

Fixed Tensioning 

system.

*The tension device shall at least partially 

prevent the window covering from functioning for light control or privacy when not 

installed. 

*The tension device shall have a minimum 

tested release force of 20 pounds off the 

wall. 

*Using a force gage gently pull the loop cord 

horizontally over a period of 5 seconds to 

create an opening. Stop pulling the gauge 

when it reads 5 pounds or the pulled pull 

distance = 25 inches, whichever comes 

first. 

*Determine whether the head probe can be 

inserted into the created with an insertion 

force of 10 pounds. If the probe can be inserted, then the loop is hazardous. 

*If the blind’s height is ≤2.5 

m, then pull cords shall be 

≤1 m. 

*If the blind’s height is >2.5 

m, then the pull cords 

shall be ≤ the height of 

the curtain minus 1.5 m. 

*The distance between the 

two strands of the loop 

shall be no more than 50 

mm adjacent to the tensioning device. 

*Allows for a breakaway 

system for the continuous 

corded system 

The ANSI/WCMA standard is 

stronger because: 

*It requires the product to be 

installed by partially limiting the product’s 

functionality while the EN 

does not. 

*Even though the EN allows 

for a break away, the tested release force is 13.2 

pounds, which is more 

than the ANSI/WCMA 

version. 

*The ANSI/WCMA standard 

only allows products into 

which a head probe can’t 

be inserted, while the EN 

does not. 


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2346 Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Proposed Rules 

TABLE 5—COMPARISON OF ANSI/WCMA STANDARD WITH THE EUROPEAN STANDARD—Continued 

Test ANSI/WCMA 

A100.1–2014 EN Standard Summary 

Pull Cords ................. Section 4.3 of the standard specifies that window 

coverings with an exposed operating cord or 

continuous loop operating system shall meet 

one of the following requirements: 

4.3.1: Product shall have no accessible operating cords 

4.3.2: Product shall have one or more separate operating cords 

4.3.3: Product shall contain a cord release 

device in the loop or head rail 

4.3.4: Product shall contain a permanently 

attached cord retraction device 

4.3.5: Product shall contain a cord shear device 

4.3.6: Product shall contain a cord shroud 

device 

4.3.7: Product shall contain a cord tension 

device 

4.3.8: Product shall contain a loop cord or 

bead chain-restraining device 

4.3.9: If the product requires a cord connector, i.e. stop ball, the exposed loop 

above the cord connector shall be limited 

to less than 3 in below the bottom of the 

cord lock when the bottom rail is fully lowered. 

When the bottom rail is fully lowered: 

*If the blind height is ≤2.5 m, 

the pull cords shall be ≤1 

m. 

*If the blind height is >2.5 

m, the pull cord length 

shall be no longer than 

the curtain height minus 

1.5 m. 

If the product has two pull cords: 

*Pull cords shall not tangle. 

*If cords tangle, the loop 

shall be eliminated within 

5 seconds of a 6 kg mass 

application. 

*Pull cords shall be connected using a breakaway 

system. The hazardous 

loop shall be eliminated 

within 5 seconds of a 6kg 

mass application. 

If the product has more than two 

pull cords: 

*Pull cords shall be connected together using a 

breakaway system. 

*The hazardous loop shall 

be eliminated within 5 

seconds of a 6kg mass 

application. 

If the product has more than four 

pull cords in the absence of a 

suitable breakaway connector: 

*Cords may be connected to 

a single pull cord positioned <50 mm from the 

head rail when the bottom 

rail is fully lowered. 

WCMA is standard is stronger as 

it requires the cord release device to release the cord at an 

average force of 3 pounds 

while the WCMA allow for 

forces up to 13.3 pounds. 

The EN standard is stronger in 

terms of the following: 

*It ensures that tangled 

cords become eliminated 

within 5 seconds of a 

13.22-pound application, 

WCMA has no such requirement. 

*It restricts the length on 

continuous loop and 

breakaway pull cords to 

reduce access to the cord. 

If the product does not 

meet the length requirements, then the product 

must be fitted with an accumulation system to contain all of the excess cord, 

not allowing more than 

100 mm of cord when 

60N is applied to it. The 

WCMA standard does not 

restrict the pull cord length 

and the cord retractor is 

an optional requirement. 

*In addition to the length requirement, it requires the 

pull cords to either be 

connected with a breakaway device, for less than 

four pull cords, or connected less than 50 mm 

below the head rail for 

more than four pull cords. 

WCMA standard does not 

have this requirement. 

*Does not allow for multiple 

separate cords without 

any other protection devices. WCMA standard allows for multiple cords. 

Inner Cords .............. Section 4.4 of the standard specifies that window 

coverings containing inner cords shall meet 

one of the following requirements: 

4.4.1: Product shall have no inner cords. 

4.4.2: Product shall have no accessible inner 

cords using a test probe with a diameter of 

51 mm for open construction and 102 mm 

for closed construction. Any cord that the 

probe can touch is considered accessible. 

If the inner cords are accessible, then pull 

on the cord with a force gage until it reads 

22.24 N or 635 mm of slack is pulled, 

whichever comes first. The head probe, dimensions of W 148 mm by H 110 mm by 

H 150 mm, shall not be able to be inserted 

in the loop with a force of 44.5 N. 

4.4.3: Products that have accessible inner 

cords shall incorporate an inner cord stop 

device or cord connector 76.2 mm or less 

below head rail when bottom rail is fully 

lowered. 

4.4.4: Product shall have an inner cord 

shroud. 

4.4.5: If the product is a roll up style, blind, 

accessible inner cords shall have a cord 

release device. 

*The maximum distance between two consecutive attachment/retention points 

of inner cords shall be 

≤200 mm. 

*It shall not be possible to 

insert the head probe (W 

148 mm by L 110 mm by 

H 150 mm) between the 

inner cords after 50 N is 

applied and released from 

the inner cords. The dimension of the loop shall 

not be increased when inserting the probe. 

If either of the above requirements are not met, the hazardous loop shall be eliminated when 58.83 N is applied 

within 5 seconds of application. 

The WCMA standard is stronger 

because: 

*The head probe is inserted 

while the inner cord loop 

is held open with the force 

gage. However, the EN 

standard releases the 

inner cord after it was 

pulled and then the head 

probe is inserted. The 

weight of the bottom rail 

could potentially remove 

the inner cord loop. 

*The WCMA standard also 

gives the option for inner 

cord stops, which the EN 

standard fails to mention. 

The EN standard is stronger because it pulls on the inner cord 

with 50 N vs WCMA’s 22.24 

N. 


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21Based on EC staff’s estimate that about 25 

percent of current market sales consist of cordless 

products, the increasing availability and sales of 

cordless products in recent years, and the 

assumption that only about one-third of curtains 

and draperies have cords. 

TABLE 5—COMPARISON OF ANSI/WCMA STANDARD WITH THE EUROPEAN STANDARD—Continued 

Test ANSI/WCMA 

A100.1–2014 EN Standard Summary 

Cord Accumulation 

System.

N/A ......................................................................... Accumulation systems (e.g., cord 

cleats) are required to be installed per the manufactures 

instructions which should be at 

least 1.5 m above the ground. 

In addition, no more than 100 

mm of cord shall be released 

after a force of 13.48 pounds 

is applied to any of the cords.

Neither the ANSI/WCMA, nor the 

EN standard is stronger standard. Having an accumulation 

system can possibly keep the 

cord out of a child’s reach and 

at the same time pose a hazard similar to, Hazard 5. Loop 

created when pull-cord was 

tied to another object, usually 

on the wall. 

C. International Alignment Agreement 

In February 2012, participating staff of 

the Australia Competition and 

Consumer Commission, Health Canada, 

European Commission Directorate 

General for Health & Consumers, and 

the CPSC reached consensus on a 

document that describes approaches to 

addressing the strangulation hazard 

related to corded window coverings. 

Petition Briefing Package, Briefing 

Memorandum at 13–14. The document 

includes a hierarchy of the various 

solutions, recognizing that different 

approaches may be necessary for 

making different types of products safer: 

To achieve the greatest permanent 

reductions in strangulations from corded 

window covering products, the product 

designs should eliminate exposure to the 

hazard or eliminate the hazard entirely. At 

the top of the hierarchy of safe solutions for 

window coverings are the following: 

• The product has no accessible cords 

under any conditions of foreseeable use or 

misuse. 

• The product has accessible cords that 

cannot form a hazardous loop under any 

conditions of foreseeable use or misuse, 

including failure to heed warnings or 

incorrect installation. 

The following approach provides for the 

next level in the hierarchy of solutions to 

reduce strangulation hazard: 

• The product is provided with safety 

devices to be installed ensuring that 

accessible cords cannot form a hazardous 

loop. Instructions and warnings are provided 

for correct installation. 

Due to variable factors, such as a 

consumer’s diligence and ability to follow all 

installation instructions and heed all 

warnings, there is a difference between this 

approach and the approach providing the 

highest level of safety. Finally, relying solely 

on warnings that the product contains 

hazardous loops that could strangle a child 

is considered insufficient to prevent 

fatalities. 

Warnings and instructions for safe use 

however should continue to be present on all 

corded window coverings, their packaging, 

and their instructions. Public education 

efforts should encourage the use of safe 

window coverings and removal of products 

with accessible cords that can form 

hazardous loops. 

VI. Relevant Statutory Provisions 

The Commission is conducting this 

proceeding under the Consumer Product 

Safety Act (‘‘CPSA’’). 15 U.S.C. 2051 et 

seq. Window covering products are 

consumer products. Id. 2052(a)(5). 

Under section 7 of the CPSA, the 

Commission can issue a consumer 

product safety standard if the 

requirements of such a standard are 

‘‘reasonably necessary to prevent or 

reduce an unreasonable risk of injury 

associated with [a consumer product].’’ 

Id. 2056(a). Such a standard must be 

expressed in terms of performance 

requirements or requirements for 

warnings or instructions. Id. Under 

section 8 of the CPSA, the Commission 

can issue a rule declaring a product to 

be a banned hazardous product when 

the Commission finds that a consumer 

product is being, or will be, distributed 

in commerce and there is no feasible 

consumer product safety standard that 

would adequately protect the public 

from the unreasonable risk associated 

with the product. Id. 2057. 

Section 9 of the CPSA sets out the 

procedure that the Commission must 

follow to issue a standard or a banning 

rule. The rulemaking may begin with an 

ANPR that identifies the product and 

the nature of the risk of injury 

associated with the product, 

summarizes the regulatory alternatives 

considered by the Commission, and 

provides information about any relevant 

existing standards and a summary of the 

reasons the Commission believes they 

would not eliminate or adequately 

reduce the risk of injury. The ANPR also 

must invite comments concerning the 

risk of injury and regulatory alternatives 

and invite the public to submit an 

existing standard or a statement of 

intent to modify or develop a voluntary 

standard to address the risk of injury. Id. 

2058(a). 

The next step in the rulemaking 

would be for us to review comments 

submitted in response to the ANPR and 

decide whether to issue a proposed rule 

along with a preliminary regulatory 

analysis. The preliminary regulatory 

analysis would describe potential 

benefits and costs of the proposal, 

discuss reasonable alternatives, and 

summarize the potential benefits and 

costs of the alternatives. Id. 2058(c). We 

would then review comments on the 

proposed rule and decide whether to 

issue a final rule along with a final 

regulatory analysis. Id. 2058(d) through 

(g). 

VII. Preliminary Estimate of Societal 

Costs 

Tab G of the Petition Briefing Package 

estimates societal costs associated with 

deaths and injuries from corded 

window covering products. Based on 

deaths reported from 1999 through 

2010, and medically attended injuries 

from 1996 through 2012, the societal 

costs associated with deaths and 

injuries involving window covering 

cords may have amounted to an average 

of about $110.7 million annually. EC 

staff estimated that an average of about 

20 percent of the window coverings21

were cordless (or did not have 

accessible cords) during the 1996 

through 2012 time period, which 

suggests that these injuries and deaths 

were associated with the roughly 832 

million window coverings in use that 

had accessible cords. 

Based on the estimates provided in 

the Petition Briefing Package, the 

societal costs may have amounted to an 

average of about $0.13 per corded 

window covering per year (i.e., $110.7 

million ÷ 832 million window 

coverings) from 1996 through 2012. 

Additionally, because window 

coverings remain in use for an average 

of about 7 years, the expected present 


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value of the annual societal costs 

(discounted at a rate of 3.0 percent) 

would average about $0.85 per corded 

covering over its expected product life. 

VIII. Regulatory Alternatives 

The Commission is considering the 

following alternatives to address the risk 

of injury associated with corded 

window covering products: 

A. Mandatory Standard 

The Commission could issue a rule 

specifying performance requirements for 

corded window coverings to reduce the 

risk of injury identified with these 

products. For example, to address the 

pull cord and continuous loop hazards, 

one option may be to develop a 

mandatory rule that is similar to the 

current ANSI/WCMA standard, which 

provides manufacturers a list of options 

to make safe window coverings. Such a 

rule could require that pull cords and 

continuous loops be tested for 

accessibility similar to the inner cords 

that are currently required by the 

standard. If accessible cords are found, 

a hazardous loop test procedure similar 

to the current procedure, but with some 

modifications, could be applied to 

determine if cords can create a 

hazardous loop. 

Another option for a mandatory rule 

would be to issue a rule consistent with 

the petitioners’ request, which would 

prohibit window covering cords if a 

feasible cordless alternative exists; and 

for instances in which a feasible 

cordless alternative does not exist, 

require that all cords be made 

inaccessible by using a passive guarding 

device. 

A third option for a mandatory rule 

may be to model such a rule after one 

of the enumerated international 

standards in section VII, or relevant 

portions of such standards. 

For any mandatory rule, the 

Commission could issue a rule that 

focuses on performance requirements or 

issue a rule that includes both 

performance requirements and labeling 

requirements to address the risk of 

strangulation. The Commission is 

interested in comments on the 

approaches described above, as well as 

any other suggestions to develop a 

mandatory standard to address the risk 

of injury associated with window 

covering cords. To issue a mandatory 

standard, the Commission would need 

to assess the costs and benefits of the 

requirements. Accordingly, the CPSC is 

interested in an assessment of the costs 

and benefits associated with options for 

a mandatory rule. 

B. Labeling Rule 

The Commission could issue a 

mandatory rule that relies on warning 

labels. CPSC staff is concerned that 

warning labels have limited 

effectiveness for a product that is 

familiar, used frequently, and contains a 

hidden hazard, as explained in Section 

IV.C.2 of this notice. 

C. Banning Rule 

The Commission could issue a rule 

declaring window covering products 

with cords to be banned hazardous 

products, if we found that no feasible 

consumer product safety standard 

would adequately protect the public 

from the unreasonable risk of injury 

associated with these products. 

D. Reliance on Voluntary Standard 

If the Commission determines that a 

voluntary standard is adequate to 

address the risk of injury associated 

with corded window covering products, 

and that substantial compliance with 

the standard exists in the industry, we 

must rely on the voluntary standard, in 

lieu of issuing a mandatory rule. 15 

U.S.C. 2058(b)(2). 

If the Commission announces in the 

Federal Register its intention to rely on 

the voluntary standard, this would 

obligate manufacturers, distributors, and 

retailers to report any product that does 

not comply with the standard, even a 

product with no incidents. 15 U.S.C. 

2064(b)(1). Failure to report could result 

in penalties. 15 U.S.C. 2068(a)(4). 

As explained in the Petition Briefing 

Package, CPSC engineering staff believes 

the current version of the ANSI/WCMA 

voluntary standard would fail to 

eliminate or adequately reduce the 

strangulation hazard to children because 

at least 57 percent of the incidents that 

occurred could still occur with pull 

cords and continuous loops on window 

coverings that meet the current version 

of the ANSI/WCMA standard. 

E. No Regulatory Action 

The Commission could take no 

regulatory action but continue to rely on 

corrective actions under section 15 of 

the CPSA and/or public education 

campaigns to address the risk of injury 

associated with corded window 

covering products. The Commission 

could continue to rely on recalls to 

address hazards associated with 

window coverings. For example, CPSC 

and WCMA announced joint recalls to 

eliminate the loops on pull cords ending 

in one tassel by offering free tassels; to 

reduce the incidents associated with 

horizontal blind inner cords by offering 

free inner cord stops, and repair kits to 

remove inner cords from Roman shades. 

The ANSI/WCMA standard was revised 

accordingly after these recalls to add 

performance requirements associated 

with these hazards. 

To date, no recalls have addressed the 

issue of pull cords ending in separate 

tassels or continuous loops that did not 

require an external tension device to be 

installed. Accordingly, just like a 

mandatory rule, relying on recalls to 

address hazards associated with 

continuous loops and pull cords would 

also require a solution from 

manufacturers to implement for the 

products that have been sold and for 

future production. We are also 

concerned that relying on recalls 

requires staff to establish independently 

that each window covering in question 

presents a substantial product hazard. In 

addition, a recall of an individual 

manufacturer’s window covering has no 

binding effect on other manufacturers 

who may have similar products that 

present the same hazard. 

The Commission could also continue 

to pursue public information and 

education campaigns. In addition to 

compliance activities, CPSC has been 

warning parents of the danger of child 

strangulation due to corded window 

coverings since the first safety alert that 

was issued in 1985. CPSC has identified 

window coverings as one of the top five 

hidden home hazards.22 Every October, 

CPSC participates in National Window 

Covering Safety Month to urge parents 

and caregivers to check their window 

coverings for exposed and dangling 

cords and to take precautions. Both 

CPSC and the Window Covering Safety 

Council (WCSC) recommend cordless 

window coverings at homes where 

young children live or visit. CPSC 

reaches out to consumers to create 

awareness of the hazards associated 

with corded window coverings. Staff 

does not have information to assess the 

effectiveness of public education 

campaigns to date; however, the lack of 

an observable trend in the data over this 

time period indicates that such 

campaigns are not effectively reducing 

the risk. 

IX. Solicitation of Information and 

Comments 

This ANPR is the first step of a 

proceeding that could result in a 

mandatory rule for corded window 

covering products. We invite interested 

persons to submit comments on any 

aspect of the alternatives discussed 

above. 


asabaliauskas on DSK5VPTVN1PROD with FRONTMATTER
Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Proposed Rules 2349 

A. CPSA Requirements 

In accordance with section 9(a) of the 

CPSA, we also invite comments on: 

1. The risk of injury identified by the 

Commission, the regulatory alternatives 

being considered, and other possible 

alternatives for addressing the risk. 

2. Any existing standard or portion of 

a standard that could be issued as a 

proposed regulation. 

3. A statement of intention to modify 

or develop a voluntary standard to 

address the risk of injury discussed in 

this notice, along with a description of 

a plan (including a schedule) to do so. 

B. Information Specific to Corded 

Window Coverings 

In addition, we invite comments and 

information concerning the following: 

1. What corded window covering 

products should we include or exclude 

from the rulemaking and why? For 

example, we can include all corded 

window covering products, or we could 

just include products most likely to be 

found in homes and residences, and 

exclude larger products intended for 

commercial use. 

2. What possible warnings or 

instructions for corded window 

coverings could address the risk of 

injury? The current ANSI/WCMA 

standard requires warning labels, yet 

injuries and deaths continue. Are there 

additional warnings that could address 

the risk of injury? 

3. What possible performance 

requirements for window covering cords 

could address the risk of injury? 

4. Are there sections in a foreign or 

international standard that can be 

adopted as part of a mandatory rule? 

5. What are the current costs to 

manufacturers to comply with the 

labeling requirements in the current 

ANSI/WCMA voluntary standard? What 

are the potential costs to manufacturers 

of labeling or performance 

requirements? 

6. What are the potential benefits of 

a rule that would require warnings or 

instructions for corded window 

coverings? 

7. What are the potential benefits of 

a rule that would establish performance 

requirements for corded window 

coverings? 

8. What are the potential costs, 

economic and societal, of banning cords 

on window covering products? What 

alternative products would remain 

available? 

9. What is the potential impact on 

small entities of a rule based on the 

options presented above? 

10. Do consumers actually install and 

consistently use cord cleats and cord 

tensioning devices correctly? Are there 

other actions consumers take to reduce 

access to loops or cords? 

11. How can public education 

campaigns on window covering safety 

be improved? How can the effectiveness 

of such campaigns be measured? 

Market Information 

12. What percent or share of the 

market or how many products are in use 

for curtains and drapes are corded, 

cordless, or have inaccessible cords? 

13. How many window coverings are 

in use in U.S. households, by window 

covering type, if possible? 

14. What proportion of the window 

coverings in use are cordless, by 

window covering type, if possible? 

Cordless Products and Products With 

Inaccessible Cords 

15. What percent of the market (as 

measured by sales volume) constitutes 

cordless products? 

16. What percent of the market (as 

measured by sales volume) constitute 

products with inaccessible cords? 

17. What are annual dollar sales and 

unit sales volumes of cordless products, 

in total, and by product type, e.g. 

vertical blinds, horizontal blinds, 

curtains, and the various types of 

shades, such as cellular, pleated, roller, 

roll-up and Roman shades? 

18. What are annual dollar sales and 

unit sales volumes of products with 

inaccessible cords, in total and by 

product type, e.g. vertical blinds, 

horizontal blinds, curtains, and the 

various types of shades, such as cellular, 

pleated, roller, roll-up and Roman 

shades? 

19. What efforts have been made to 

market these solutions to consumers 

both at retail, online, and through direct 

outreach? 

20. What proportion of curtains or 

drapery coverings are used with looped 

or other types of cords for opening and 

closing? 

21. Information on size limitation(s) 

for cordless products. For example, 

would certain types of blinds or shades 

be too large or too heavy to be made into 

a cordless product? 

22. Information on size limitation(s) 

for products with inaccessible cords. 

For example, would certain types of 

blinds or shades be too large or too 

heavy to be made into products with 

inaccessible cords? 

23. Are there any other factors that 

would limit the production or use of 

cordless products and products with 

inaccessible cords? 

24. What is the size of the market for 

custom made cordless products, in 

annual dollar sales value or unit sales 

volume? 

25. What is the size of the market for 

custom-made products with 

inaccessible cords, in annual dollar 

sales value or unit sales volume? 

26. What is the expected product life 

of the various types of blinds and 

shades that are currently being sold in 

the marketplace? 

27. How does the product life of 

cordless products compare to (or differ 

from) the product life of corded 

products? 

28. How does the product life of 

products with inaccessible cords 

compare to (or differ from) the product 

life of corded products? 

29. Are cordless options available that 

would be inappropriate for populations 

with limited mobility or the elderly? 

30. Are products with inaccessible 

cords available that would be 

inappropriate for populations with 

limited mobility or the elderly? 

31. What technologies are available as 

alternatives to a corded operating 

system? 

32. What are the methods by which 

corded products can be converted into 

cordless products in the production 

process? What would the change in unit 

cost be for such conversions? 

33. What are the methods by which 

corded products can be converted into 

products with inaccessible cords in the 

production process? What would the 

change in unit cost be for such 

conversions? 

34. What are the potential benefits 

and limitations of tensioning devices 

that would render the window 

coverings completely inoperable if not 

installed properly? 

Information on Compliance With the 

Voluntary Standard 

35. As described in section VIII, one 

regulatory alternative is reliance on the 

voluntary standard issued by ANSI/

WCMA. 

a. Is the ANSI/WCMA standard likely 

to result in the elimination or adequate 

reduction of the risk of injury associated 

with window covering cords? 

b. What effect, if any; would the 

obligation to report non-compliant 

products under 15 U.S.C. 2064(b)(l) 

have on compliance with the standard? 

36. What percentage of the market (in 

terms of sales) or producers comply 

with the voluntary standard? Should the 

Commission consider this percentage to 

be ‘‘substantial compliance’’ within the 

meaning of the CPSA? 

37. Does the current level of 

conformance to the voluntary standard 

differ for the various types of window 

coverings? If so, to what levels? 


asabaliauskas on DSK5VPTVN1PROD with FRONTMATTER
2350 Federal Register / Vol. 80, No. 11 / Friday, January 16, 2015 / Proposed Rules 

Information on Manufacturer Cost 

38. What is the typical difference in 

cost to produce cordless products, 

products with inaccessible cords, and 

corded window coverings? If possible, 

please provide the information by 

window covering type (e.g. vertical 

blinds, horizontal blinds, and the 

various types of shades, such as cellular, 

pleated, roller, roll-up and Roman)? 

39. What is the manufacturer’s cost to 

produce various safety technologies, 

including research and development 

costs, and components, such as a 

retractable cord operating system, cord 

cleat, or cord shroud? 

40. How would manufacturing these 

products in large quantities change the 

cost? Please provide examples in terms 

of quantity and price change (%). 

Alberta E. Mills, 

Acting Secretary, Consumer Product Safety 

Commission. 

[FR Doc. 2015–00566 Filed 1–15–15; 8:45 am] 

BILLING CODE 6355–01–P 

DEPARTMENT OF HOMELAND 

SECURITY 

Coast Guard 

46 CFR Part 70 

[Docket No. USCG–2011–0357] 

RIN 1625–AB91 

Cruise Vessel Security and Safety Act 

of 2010; Implementation 

AGENCY: Coast Guard, DHS. 

ACTION: Notice of proposed rulemaking. 

SUMMARY: The Coast Guard proposes 

amending its passenger vessel 

regulations to implement the Cruise 

Vessel Security and Safety Act of 2010 

with respect to deck rails, systems for 

detecting or recording falls overboard 

and for recording evidence of possible 

crimes, hailing devices, security guides, 

sexual assault response, and crime 

scene preservation training. The 

proposed regulations promote the Coast 

Guard’s maritime safety and security 

missions. 

DATES: Comments and related material 

must either be submitted to our online 

docket via http://www.regulations.gov 

on or before April 16, 2015 or reach the 

Docket Management Facility by that 

date. Comments sent to the Office of 

Management and Budget (OMB) on 

collection of information must reach 

OMB on or before April 16, 2015. 

ADDRESSES: You may submit comments 

identified by docket number USCG– 

2011–0357 using any one of the 

following methods: 

(1) Online: http://

www.regulations.gov. 

(2) Fax: 202–493–2251. 

(3) Mail: Docket Management Facility 

(M–30), U.S. Department of 

Transportation, West Building Ground 

Floor, Room W12–140, 1200 New Jersey 

Avenue SE., Washington, DC 20590– 

0001. 

(4) Hand delivery: Same as mail 

address above, between 9 a.m. and 5 

p.m., Monday through Friday, except 

Federal holidays. The telephone number 

is 202–366–9329. 

To avoid duplication, please use only 

one of these four methods. See the 

‘‘Public Participation and Request for 

Comments’’ portion of the 

SUPPLEMENTARY INFORMATION section 

below for instructions on submitting 

comments. 

Collection of Information Comments: 

If you have comments on the collection 

of information discussed in section VI.D 

of this NPRM, you must also send 

comments to the Office of Information 

and Regulatory Affairs (OIRA), Office of 

Management and Budget. To ensure that 

your comments to OIRA are received on 

time, the preferred methods are by email 

to oira_submission@omb.eop.gov 

(include the docket number and 

‘‘Attention: Desk Officer for Coast 

Guard, DHS’’ in the subject line of the 

email) or fax at 202–395–6566. An 

alternate, though slower, method is by 

U.S. mail to the Office of Information 

and Regulatory Affairs, Office of 

Management and Budget, 725 17th 

Street NW., Washington, DC 20503, 

ATTN: Desk Officer, U.S. Coast Guard. 

FOR FURTHER INFORMATION CONTACT: If 

you have questions on this proposed 

rule, call or email LT Jason Kling, U.S. 

Coast Guard Office of Design and 

Engineering Standards, telephone 202– 

372–1361, email jason.m.kling@

uscg.mil. If you have questions on 

viewing or submitting material to the 

docket, call Cheryl Collins, Program 

Manager, Docket Operations, telephone 

202–366–9826. 

SUPPLEMENTARY INFORMATION: 

Table of Contents for Preamble 

I. Public Participation and Request for 

Comments 

A. Submitting Comments 

B. Viewing Comments and Documents 

C. Privacy Act 

D. Public Meeting 

II. Abbreviations 

III. Background 

IV. Comments on 2011 Notice 

V. Discussion of CVSSA and Proposed Rule 

VI. Regulatory Analyses 

A. Regulatory Planning and Review 

B. Small Entities 

C. Assistance for Small Entities 

D. Collection of Information 

E. Federalism 

F. Unfunded Mandates Reform Act 

G. Taking of Private Property 

H. Civil Justice Reform 

I. Protection of Children 

J. Indian Tribal Governments 

K. Energy Effects 

L. Technical Standards 

M. Environment 

I. Public Participation and Request for 

Comments 

We encourage you to participate in 

this rulemaking by submitting 

comments and related materials. All 

comments received will be posted 

without change to http://

www.regulations.gov and will include 

any personal information you have 

provided. 

A. Submitting Comments 

If you submit a comment, please 

include the docket number for this 

rulemaking (USCG–2011–0357), 

indicate the specific section of this 

document to which each comment 

applies, and provide a reason for each 

suggestion or recommendation. You 

may submit your comments and 

material online or by fax, mail, or hand 

delivery, but please use only one of 

these means. We recommend that you 

include your name and a mailing 

address, an email address, or a phone 

number in the body of your document 

so that we can contact you if we have 

questions regarding your submission. 

To submit your comment online, go to 

http://www.regulations.gov, and follow 

the instructions on that Web site. If you 

submit your comments by mail or hand 

delivery, submit them in an unbound 

format, no larger than 81⁄2 by 11 inches, 

suitable for copying and electronic 

filing. If you submit comments by mail 

and would like to know that they 

reached the Facility, please enclose a 

stamped, self-addressed postcard or 

envelope. 

We will consider all comments and 

material received during the comment 

period and may change this proposed 

rule based on your comments. 

B. Viewing Comments and Documents 

Public comments and relevant 

documents mentioned in this notice 

will all be available in the public 

docket. To see the public docket, go to 

http://www.regulations.gov, and follow 

the instructions on that Web site. If you 

do not have access to the internet, you 

may view the docket online by visiting 

the Docket Management Facility in 

Room W12–140 on the ground floor of 

the Department of Transportation West 


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