UNITED STATES CONSUMER PRODUCT SAFETY COMMISSION 

In re: 16 CFR § 1051 Petition for Rulemaking 

Eliminating Accessible Cords 

On Window Covering Products 

Petitioners: 

Parents for Window Blind Safety, 

Consumer Federation of America, 

Consumers Union, 

Kids in Danger, 

Public Citizen, 

U.S. PIRG, 

Independent Safety Consulting, 

Safety Behavior Analysis, Inc., 

Onder, Shelton, O'Leary & Peterson, 

PETITION FOR RULEMAKING 

Petitioners, Parents for Window Blind Safety, Consumer Federation of America, 

Consumers Union, Kids in Danger, Public Citizen, U.S. PIRG, Independent Safety Consulting, 

Safety Behavior Analysis, Inc., and Onder, Shelton, O'Leary & Peterson, LLC (hereinafter 

"Petitioners"), pursuant to 16 CFR § 1051 state to the U.S. Consumer Product Safety 

Commission as follows: 

INTRODUCTION 

The U.S. Consumer Product Safety Commission (hereinafter "CPSC") has long 

recognized window covering cords as a hidden strangulation and asphyxiation hazard to 

children and today continues to include it as one of the top five hidden hazards in the home. 

(CPSC, 2007, CPSC 2013a) Since 1985, the CPSC has worked with and repeatedly pressed 

the window covering industry (hereinafter "Industry") to eliminate these hazards, through 

public education, multiple corrective actions, and the voluntary standards development 

process. Despite these efforts, the voluntary standard (first passed in 1996 and most recently 

revised in 2012) remains inadequate and continues to permit window coverings with 

hazardous accessible cords that injure and kill young children. 

The unresolved issue of window covering cord injuries and deaths is not limited to 

the United States. Indeed, global frustration over this on-going hazard resulted in the June 
15, 2010 joint action by the CPSC, Health Canada and the European Commission wherein 

they joined together "in agreement on the need for immediate action," and made a trilateral 

request to the Industry for "support [of] a swift and comprehensive process that concurrently 

eliminates the risk factors causing deaths and injuries from all types of corded window 

covering products." (CPSC, HC, DO SANCO, 2010) 

Acting upon the trilateral request, the Window Covering Manufacturers Association 

(hereinafter "WCMA") undertook a fifth revision of the voluntary standard, ANSVWCMA 

A100.1 American National Standard for Safety of Corded Window Covering Products. 

When it appeared that the renewed standards writing efforts were not satisfactorily addressing 

the major hazards responsible for injury and death, CPSC Chair Inez Tenenbaum wrote to the 

Industry on June 1, 2011, re-invoking the international call for a standard that eliminates 

window covering hazards, and stating, "I reaffirm to you my call for a comprehensive revised 

voluntary standard that eliminates- not just reduces- the strangulation risks from window 

coverings." (CPSC, 2011a) Ultimately, the inadequacy of the voluntary standards process, as 

well as the inadequate result toward which it was clearly heading, led consumer organizations 

reluctantly to take the unusual step ofwalking out of the process. (CFA 2011) 

Indeed, the call for a standard that would finally eliminate window covering hazards 

was disregarded. The voluntary ANSI standards development process failed again, when the 

fifth revision ofthe ANSIIWCMA A100.1 standard was approved in late 2012 with critical 

inadequacies. As will be shown below, 28 years after the CPSC first began working with 

Industry to address these hazards, the latest version of the standard still does not eliminate the 

major hazards that have caused approximately 40 percent of the deaths and injuries that have 

occurred since 1996. In fact, the new standard allows for increasing numbers of hazardous 

accessible cords to be loaded onto new window coverings. If the ANSVWCMA A100.1 

voluntary standard is allowed to stand as the de facto industry safety standard, children will 

continue to strangle and asphyxiate on unsafe corded window covering products. · 

Due to Industry's failure to develop a standard that adequately mitigates the risk of 

strangulation on corded window coverings, the Petitioners hereby formally Petition for 

Rulemaking under the authority and process set forth in 16 CFR § 1 051, et seq. and request 

the Commission to promulgate a mandatory standard that prohibits any window covering 

cords where a feasible cordless alternative exists, and for those instances where a feasible 

cordless alternative does not exist, requires that all cords be made inaccessible through the use 

of passive guarding devices. 

HISTORY: 

THE FAILURE OF THE VOLUNTARY STANDARDS PROCESS 

1985 Safety Alert 

Following the reporting of 41 deaths on window covering cords between 1973 and 1980 

and an additional report of another 35 deaths between 1981 and 1984, the CPSC approached 

Industry requesting its cooperative effort in issuing a joint Safety Alert. (CPSC, 1985a) CPSC 

staff met with representatives of Industry on September 13, 1985 and presented a proposed 

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Safety Alert that made several recommendations including the cutting of cord loops. (CPSC, 

1985b) 

A joint Safety Alert was issued on December 20, 1985, but the recommendation to cut 

cord loops was not included. In fact, Industry did not accept the recommendation to cut cord 

loops for another nine years. The recommendations that were incorporated into the 1985 Safety 

Alert were: I) Keep cords out of the reach of children and utilize safety devices such as cord 

cleats; 2) Adjust cords to the shortest possible length for the application; and 3) Do not place 

cribs or other furniture near windows, for furniture gives children added height to reach cords. 

(CPSC, 1985c) 

A year after the 1985 Safety Alert was issued, the WCMA created camera-ready 

warnings incorporating some of these safety recommendations and made them available for use 

by manufacturers as bottom rail labels, hang tags and warning sheets. (DWC, 1988) These 

warnings were used from 1986 until the adoption of the first voluntary standard in 1996, 

ANSVWCMA AIOO.l- 1996. 

Warnings alone failed and children continued to be injured and killed: 

1985: II fatalities 2 non-fatalities' 

1986: 9 fatalities 0 non-fatalities 2 

1987: 8 fatalities 2 non-fatalities 3 

1988: 8 fatalities 0 non-fatalities 4 

1989: II fatalities 4 non-fatalities 5 

1990: II fatalities I non-fatality 6 

1991: 18 fatalities I non-fatality 7 

1992: 19 fatalities 0 non-fatalities 8 

1993: 13 fatalities I non-fatality 9 

1994 Cord Loops Efforts and Voluntary Corrective Action Plan 

Faced with continuing deaths, the CPSC once again engaged Industry, requesting that 

window covering hazards be addressed through design changes, including the elimination of 

cord loops as CPSC first brought to Industry's attention in 1985. 

In September 1994, Industry, through the newly-created Window Covering Safety 

Council, (hereinafter "WCSC") agreed to enter into a CPSC Voluntary Corrective Action Plan 

(hereinafter "VCAP") consisting of public education and outreach, retrofit product distribution, 

and product design modifications eliminating looped outer cords on certain horizontal window 

coverings. (WCSC, 1994) Simultaneously, Industry agreed to "look at future design changes to 

all window covering products (i.e., multiple cord products, vertical, cellular and pleated designs) 

to incorporate [CPSC] staff approved changes" and "to work under the auspices of ANSI to 

formalize future design changes that incorporate safer design." (CPSC, 1994a) 

In 1993 and1994, both the CPSC and Industry safety consultants had warned that 

separating outer cord loops on some window coverings was not sufficient by itself to prevent 

further fatalities and injuries. Both CPSC Human Factors evaluations of the proposed separated 

tassel/safety tassel redesign, and private studies performed for manufacturers, indicated that 

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these limited redesigns would not eliminate cord risks or stop fatalities. (FAA, 1993; CPSC, 

1994b; CPSC, 1994c; CPSC, 1994d; CPSC, 1994e) Industry was warned that pull cords would 

re-tangle and knot with use, recreating the cord loop hazard. Similarly, Industry was advised 

that single cords can wrap around a child's neck, resulting in serious injury or death. 

Accordingly, the VCAP indicated that it was simply an "interim solution" until better technology 

could be developed. 

Industry codified the efforts of the VCAP into the voluntary standard, ANSIIWCMA 

A 100.1-1996. The 1996 ANSI standard required the elimination of some outer cord loops, 

which was accomplished by most manufacturers through the use of outer cords with separated 

tassels and/or a breakaway safety tassel on limited types of window coverings. Also, tie-down 

devices were required on continuous loop operating systems. 

Further, leading up to the 1996 ANSI standard, by letter dated November 21, 1995, the 

CPSC requested the new standard include warnings for not just outer cord hazards but inner cord 

hazards, as well. (CPSC, 1995) Industry rejected CPSC' s recommendation to include a 

pictogram educating consumers about the existence of hidden inner cords and failed to create a 

design standard to prevent inner cord hazards. The only reference to inner cord hazards in the 

1996 ANSI standard was the inclusion of a vague, unexplained warning statement about "cords 

that run through window coverings" on temporary hang tags (that are removed upon 

installation). The 1996 ANSI standard also did not address a number of other known hazards, 

including the loops on larger window coverings with more than two outer cords, unnecessarily 

long cords, multiple cord joiner hazards, exposed rear cords on roman shades, and lifting loops 

on roll-up shades. The 1997 standard also failed to establish warnings for many hazards that 

were not otherwise addressed. 

As forewarned by the CPSC and safety experts, children continued to strangle on 

window covering cords with unaddressed hazards; the death and injury toll continued to rise: 

1994: 16 fatalities 

1995: 14 fatalities 

1996: 17 fatalities 

1997: 16 fatalities 

1998: 12 fatalities 

1999: 7 fatalities 

2000: 11 fatalities 

2000 Inner Cord/Lift Cord Efforts 

1 non-fatality10 

4 non-fatalities 11 

5 non-fatalities12 

3 non-fatalities 13 

2 non-fatality 14 

0 non-fatalities 15 

5 c: 1

. . 16 non-1ata 1t1es 

By letter dated September 3, 1999, CPSC staff wrote to Industry renewing its concern 

regarding inner cord strangulation hazards, and pressed for action. Faced with 14 recent inner 

cord deaths and one injury, the CPSC demanded that Industry also address the hazards associated 

with inner cord loop formation through design. (CPSC, 1999) 

In cooperation with the CPSC, Industry entered into a second Voluntary Corrective 

Action Plan in September of2000, again involving public education and outreach, retrofit 

product distribution, and new product modification. (WCSC, 2000a) Under this VCAP, inner 

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cord stops were placed on outer cords near the head rail to prevent the formation of an inner cord 

loop. The retrofit and public education efforts renewed with the continued distribution of safety 

tassels and continuous loop tie-down devices. 

Industry's public education and outreach efforts have consistently included the WCSC's 

website providing Industry safety recommendations adopted in 2000, including the 

recommendation that consumers "install only cordless" window coverings in homes with young 

children. (WCSC, 20II; WCSC, 2000b) 

Industry's 2000 VCAP efforts were then codified into a 2002 revision of the voluntary 

standard, ANSIIWCMA AIOO.l-2002. This revision ofthe standard continued to leave many 

accessible window cords unaddressed. 

The ANSIIWCMA AIOO.l Standard was again revised in 2007, and then again in 2009 

and 20IO following extensive CPSC recalls for un-addressed hazards of rear inner cords on 

roman shades and lifting loops on roll-up shades. 

Piecemeal redesign, retrofit, warnings and public education efforts had limited success, 

and the toll of injuries and deaths continued to rise: 

200I: II fatalities 7 non-fatalities 17 

2002: II fatalities 9 non-fatalities 18 

2003: I7 fatalities 2 non-fatalities 19 

2004: 6 fatalities 4 non-fatalities 20 

2005: 9 fatalities 6 non-fatalities 21 

2006: 7 fatalities 4non-fatalities 22 

2007: 9 fatalities 3 non-fatalities 23 

2008: I7 fatalities 9 non-fatalities 24 

2009: I4 fatalities 30 non-fatalities 25 

20IO: II fatalities I4 non-fatalities 26 

While governmental pressures mount, the voluntary standard remains inadequate 

Due to the continued inadequacies of the voluntary standard, the U.S. and foreign 

governments started to increase pressure on Industry. In the 20 I 0 trilateral letter referenced at 

the start of this petition, the CPSC, Health Canada and the European Commission made clear 

their directive to Industry that current voluntary standard provisions were not enough and 

requested they "eliminate the risk factors causing deaths and injuries from all types of corded 

window covering products." 

In 20 I 0, safety experts and consumer organizations, including representatives from 

Parents for Window Blind Safety, Independent Safety Consulting, Consumer Federation of 

America, and Consumers Union, were for the first time allowed a limited role in the voluntary 

standards writing process. All held out great hope for the voluntary process. However, one year 

later, these safety experts and consumer representatives reluctantly walked out of a voluntary 

standards meeting and removed themselves from this process, because Industry was ignoring 

their recommendations and refusing to give them meaningful participation in the standards 

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writing process. (NYT, 2011) 

During the standards writing process, it became clear that loopholes in the voluntary 

standard were responsible for many injuries and deaths, but were not going to be addressed by 

Industry. Accordingly, in an August 4, 2011 speech directed to Industry, CPSC Chair 

Tenenbaum again called Industry to task, declaring, "It is time to 'eliminate' the strangulation 

risk on window blind cords. Notice how I did not say, 'reduce the hazard,' I said eliminate the 

hazard." (CPSC 2011b) 

The Retailer Industry Leaders Association (hereinafter "RILA") was likewise alarmed, 

and by letter dated September 12, 2011, urged Industry to adopt standards that eliminate 

operational cords capable of forming hazardous loops and to address continuous loop tie-down 

devices. RILA urged Industry to finally agree to address these hazards, requesting that the 

WCMA "address concerns ofRILA, CPSC technical staff, and consumer advocacy groups as 

you work to develop the improved standard." (RILA 2011) 

CPSC Staff comments on the January 23, 2012 proposed version of the voluntary 

standard primarily addressed the serious remaining risks associated with operating cords and 

recommended the clear-cut solution of limiting the combined length of all accessible cords to no 

longer than the neck circumference of the youngest child at risk regardless of the position of the 

window covering (i.e., raised or lowered, opened or closed). However, as later noted by CPSC, 

these comments were largely ignored in the final version of the standard: "the major hazards 

associated with operating cords and looped cords remained the same as the originally proposed 

version." (CPSC, 2012; CPSC, 2013) 

When the ANSI/WCMA AlOO.l-2012 was approved on November 28,2012, yet again 

this standard failed to adequately address the strangulation hazard posed by accessible cords on 

window coverings. As further detailed below, the standard continues to permit window 

coverings with hazardous accessible cords that injure and kill young children. After this 

standard was promulgated, an analysis ofwindow covering incidents between 1996 (the date of 

the first voluntary standard) and 2012 was conducted. The purpose of this analysis was to 

identify both the cord characteristic of each window covering and the accident mechanism to 

determine what cord characteristic was involved, in order to determine whether the 2012 

ANSIIWCMA voluntary standard would have prevented the incident from occurring. Based on 

this analysis, approximately 40% of incidents would not have been prevented. Further, the 

2012 standard actually permits an increase in the number and types of hazardous accessible 

cords on some newer window coverings. 

And so, 28 years after Industry agreed to work with CPSC to address this hazard, and 

having been given clear direction and multiple opportunities to develop a meaningful standard, 

and having been duly warned of the inadequacies ofthe proposed standard, even this latest 

version (the sixth attempt) ofthe ANSIIWCMA A100.1-2012 standard fails to eliminate or 

adequately reduce the risk of injury and death from accessible window covering cords. 

In April of 1994, manufacturer Comfortex Window Fashions foreshadowed what has 

ultimately been borne out, namely that warning and redesign efforts will fail so long as they 

involve accessible cords. Comfortex warned, "Until all window coverings are free of cords for 

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their operation, there will be no true safety if cords are available to small children." (Comfortex, 

1994) Comfortex was right in 1994; those prophetic words have stood the test of time. 

Recent injury data continues to reflect deaths and injuries from window coverings: 

2011: 

2012: 

6 fatalities 

5 fatalities 

2 non-fatalities (data set incomplete) 27 

I non-fatalities (data set incomplete) 28 

MANDATORY RULEMAKING IS APPROPRIATE TO ELIMINATE ACCESSIBLE 

CORDS ON WINDOW COVERINGS 

By statute, efforts to address product hazards through voluntary consensus 

standards are necessary before a mandatory standard can be promulgated. According to 

CPSA Section 9(f)(3)(D), the promulgation of a mandatory standard is appropriate 

when: 

"(i) Compliance with such voluntary consumer product safety standard is not 

likely to result in the elimination or adequate reduction of such risk of injury; or 

(ii) It is unlikely that there will be substantial compliance with such voluntary 

consumer product safety standard." (15 U.S.C. Section 2058) 

Petitioners have carefully examined the injury and death data associated with 

window coverings and the record of compliance with the voluntary standard, and find 

that both of these criteria are met in the context of corded window coverings. 

Failure of ANSI/WCMA AlOO.l-2012 to Eliminate or Adequately Reduce Risk 

First, examination of available injury and death data reveals that a high number of 

incidents since passage of the first standard in 1996 would not have been prevented by even the 

most recent (2012) version of the ANSIIWCMA standard. (Exhibit 1) Of the total293 incidents 

between 1996 and 2012, 250 had sufficient information available to make such a determination. 

Ofthese 250 incidents, 102 ofthe injuries and deaths (approximately 40%) would not have been 

prevented by the current voluntary standard, indicating that an unreasonable risk of injury on 

corded window coverings continues to exist: 

55 Incidents on manufacturer separated outer cords (both pull cords and tilt cords) that 

caused injury or death via knotted/tangled loops, defective break-away devices, and cord 

wrap-around. 

29 Incidents on window coverings with looped outer cords but where the manufacturercreated loop did not cause the incident. These incidents involved either wrap-around 

incidents or children caught in tangled/knotted loops. 

7 
5 Continuous loop cord incidents where a tension/tie-down device was present at the scene 

but was either not installed, had pulled out of the wall, or had broken. (CPSC staff has 

criticized the effectiveness of the active tension device provision, since it is foreseeable 

that "tension devices may not be installed at all, uninstalled for some reason, or installed 

incorrectly ... " and therefore, "the proper installation of tension devices, a critical 

component for the safe use of the product, should not have to be done by consumers.") 

(CPSC, 2012) 

6 Other instances caused by a hazardous cord allowed by the standard - such as reverse 

inner cord incidents and incidents where the victim was caught in a cord joiner loop 

on a multi-corded window covering. 

7 Incidents caused by the manufacturer's failure to make the product according to the 

voluntary standard in effect at time of manufacture. 

Second, even though Industry had already developed cordless window coverings in 1996, 

and by 2000 was recommending cordless window coverings for families with young children, the 

voluntary standard still allows corded window coverings. 

Third, some manufacturers have taken advantage of weaknesses in the standard to 

actually increase the number and types of long, accessible cords on newer window coverings, 

thereby making blinds more hazardous than ever. For example, CPSC In-Depth Investigation 

(IDI) 120727CCC290 involves the 7/10/12 death of a 3-year-old girl who strangled when she 

wrapped the tilt cord of a 20 I 0 faux wood horizontal blind around her neck. The blind was 

manufactured by a large, well-known window covering manufacturer, and was sold and installed 

by a major home-improvement retailer. Not only does this blind have the hazards of most 

corded window blinds, such as long pull cords, but it also has a number of newer and 

functionally unnecessary hazards allowed by the 2012 WCMN ANSI standard. This blind is 

more dangerous than traditional corded blinds in at least five different ways: 

• It has 2 tasseled tilt cords instead oftraditional tilt wand to rotate the slats of the 

blind. This extra set of cords puts hazardous accessible outer cords on both the left 

and right side of the blinds (as opposed to only one side with standard pull cords). 

• It has unnecessarily long tilt cords that are 2/3 the window's height, even though only 

a few inches of cord are needed to perform the tilt function. 

• It has large flat-topped tassels that are more likely to snag/catch on a single cord 

wrapped around a child's neck to create deadly loop, and have been implicated by the 

CPSC in-depth-investigation as a cause ofthis 7110112 death and at least one other 

death {080915HNE3763). 

• It has "inner cords" strung along the outside of both front and back of the blind, 

instead of through holes in the center of the slats, that are more accessible and 

attached in a less secure manner. This style of 'inner cords strung on outside of blind' 

was involved the 10/4/11 death of a child on a 2009 blind (CPSC IDI 

111018CCC2027). 

• It has doubled the number of pull cords used on each blind, because the traditional 

single inner cord that run through the slats was replaced with two cords, at both front 

and back of the slats. 

8 
Instead of this blind having two traditional outer cords and a tilt wand, it has six long 

outer cords, each with a large flat top tassel, that tangle easily, and has moved the inner cords 

from inside slats to the far more accessible, outside front and back locations. This example 

illustrates how the voluntary standard does not prohibit Industry from actually increasing the 

number of hazardous accessible window covering cords. 

In all of these respects, the voluntary standard fails to eliminate or adequately reduce 

the unreasonable risk of injury or death associated with accessible cords on window 

coverings. 

Lack of Substantial Compliance with Voluntary Standards 

There is substantial non-compliance with the voluntary standard. A number of 

manufacturers have ignored basic safety provisions of the voluntary standard, and have 

manufactured non-compliant window coverings for years and even decades. Since 2007, there 

have been at least 16 CPSC recalls involving blinds that were not manufactured in compliance 

with the voluntary standard. 

Disturbingly, most of these instances of non-compliance (13 of 16) appear to have been 

discovered unintentionally as a by-product ofCPSC's 2008-2010 focus on roman shade and 

roll-up shade rear inner cord/lifting loop issues. While evaluating manufacturers' products for 

roman shade back cord hazards and roll-up shade lift loop issues, CPSC staff caught numerous 

other violations of the voluntary standard, including looped pull cords, no inner cord stops, no 

tension devices provided with continuous loop products, and failure to attach a tension device 

to a continuous loop cord. Almost all of these findings violated voluntary standard 

requirements that had been in effect since the first standard was published in 1996. Many of 

these non-complying products were on the market for years, and in one case, for two decades, 

before they were detected and recalled. (Exhibit 2) 

The CPSC does not have the resources to maintain this level of enforcement. This 

example of how one short-term enforcement effort uncovered numerous standard violations 

implies that many more undiscovered instances of non-compliance by Industry exist, and 

that at least some portion of Industry cannot be relied upon to meet voluntary standards and 

to manufacture compliant products. 

DESPITE FEASIBLE SAFE ALTERNATIVES, VOLUNTARY STANDARDS 

HAVE FAILED 

Feasible Safe Alternatives 

Safe alternatives exist and are feasible. For example: 

Cordless technology 

Cordless window covering designs that eliminate pull cords are available and 

9 
economically viable. Cordless window coverings, such as pleated shades, horizontal blinds, 

cellular shades, wood blinds, and roman shades, have been made by a number of firms since 

approximately 2000 (CPSC, 2000; Hunter Douglas, 2000; Levolor, 2001). Cordless products 

of up to 78 inches wide and 84 inches long are available in all designs. Our research indicates 

that the manufacturer's cost of such alternative cordless technology is only $2.00- $3.00 more 

than the cost of an unsafe corded one-inch vinyl or aluminum blind. The manufacturer's cost 

for such cordless operating systems on a two-inch faux wood blind is in the $7.00- $9.00 

range. While the current design of cordless products may include size limitations, these sizes 

encompass the overwhelming majority of all applications. 

Furthermore, feasible and cost-effective alternative designs exist which likewise 

address this issue. This issue can be solved by utilizing a wand-type device similar to those 

used to tilt slats for light control. 

Cord cover designs 

In the 1990s, major window covering manufacturers developed and patented cord 

cover devices to render the pull cords of window coverings inaccessible. (Springs, 1995a; 

Springs, 1995b; Newell, 1996) However, major manufacturers never brought products with 

this feature to market, and cord covers were essentially abandoned once the CPSC allowed 

separated cord tassels to serve as a compliant design alternative. 

More recently, one manufacturer has created and brought to market a cord cover design 

aimed at eliminating accessible pull cords, at a price point that is affordable and cost effective 

for both new-product and retrofit applications. (Safe-T -Shade, 201 0; Safe-T -Shade website) 

This cord cover design renders pull cords inaccessible, while at the same time eliminating 

concerns regarding the ability of cordless technology to meet very large applications, and 

applications where furniture is placed in front of window coverings. Such cord cover designs 

can accommodate any window size currently being served by cord-accessible products, and its 

positioning in the same location as traditional pull cords accomplishes the same functionality 

and accessibility as traditional corded products. 

Voluntary standard efforts have failed 

The economic reality is that the window covering industry is very competitive, 

particularly in the area of stock products. If one manufacturer wants to adequately address 

safety issues and render cords inaccessible at a slightly higher cost, it risks being undercut by 

another manufacturer willing to sell less safe but cheaper products. Big box retailer contracts 

can be lost over a matter of pennies, nickels, or dimes as major retailers seek the lowest 

possible entry level price point in the window covering market. Absent a mandatory standard, 

manufacturers seeking to introduce safer cordless and cord inaccessible products will suffer 

from a competitive disadvantage against manufacturers willing to sell unsafe corded products. 

Further, the large window covering manufacturers who dominate the WCMA and ANSI 

standards writing process have a vested interest in maintaining low industry standards. Those 

manufacturers have advanced custom product designs featuring cordless and cord inaccessible 

10 
coverings, on which they are able to maintain premium pricing- but only so long as there is an 

absence of competition. Should standards mandate cordless or cord inaccessible product 

designs, this feature will no longer be able to command a premium price. 

Absent mandatory rulemaking that eliminates accessible window covering 

cords, Industry has not and will not act alone. ANSilWCMA A100.1-2012 was 

Industry's sixth attempt to address exposed operational cords, and it has again chosen 

not to do so meaningfully, despite extreme U.S. pressure and an international mandate. 

For all these reasons, it is evident that the only way to achieve safety is to invoke CPSC 

rulemaking. 

PETITION REQUEST 

Despite the availability of feasible and cost effective design alternatives, Industry has 

failed to adopt a voluntary standard which engages the first tiers of the safety design 

hierarchy, i.e. to eliminate or guard against the hazard. It is only through design strategies 

that the cord hazard will be adequately addressed and true safety achieved. The repeated 

failure of Industry to adopt an effective voluntary standard over the last 28 years 

demonstrates that CPSC rulemaking is required to eliminate the hazard posed by accessible 

cords in window coverings. 

As previously discussed, the latest voluntary standard is inadequate due to its allowance 

of products with accessible cords, even when cordless and/or inaccessible cord options are 

feasible. We believe a mandatory standard should eliminate all accessible cords: 

The standard should prohibit the use of cords on window coverings when non-cord 

design options are feasible. For example, cords are not necessary for the tilting operation 

of horizontal blinds since wands can perform this function. Also, exterior pull cords on 

window coverings are unnecessary for products that have cordless options - currently all 

products measuring less than 78 inches wide and 84 inches long. 

Ifthere are products for which accessible cords cannot be currently eliminated, due to 

the large size of the product or other reasons, the standard should require that such cords 

be made inaccessible through passive guarding devices, such as a cord cover. 

We defer to the CPSC as to what is the best approach for this standard. For example, 

one approach would be to ban all accessible cords, and to develop a mandatory standard to 

define what constitutes an accessible cord. Since the CPSC staff has been working on this 

issue in earnest since at least 1994, there is vast in-house expertise in this subject matter. 

In closing, due to Industry's repeated failure to develop a standard that adequately 

mitigates the risk of strangulation on corded window coverings, the Petitioners hereby 

formally Petition for Rulemaking under the authority and process set forth in 16 CFR § 

1051, et seq. and request the Commission to promulgate a mandatory standard that 

prohibits any window covering cords where a feasible cordless alternative exists, and for 

11 
those instances where a feasible cordless alternative does not exist, requires that all cords 

be made inaccessible through the use of passive guarding devices. 

The Petitioners appreciate the Commission's consideration ofthis request. We 

are available to discuss this petition at your convenience. 

Respectfully submitted, 

Petitioners: 

Parents for Window Blind Safety 

By: Linda Kaiser 

President 

PO Box 205 

Barnhart, MO 63012 

314-494-7890 

linda@pfwbs.org 

Consumer Federation of America 

By: Rachel Weintraub 

Legislative Director and Senior Counsel 

1620 Eye Street, NW, Suite 200 

Washington, DC 20006 

202-939-1012 

rweintraub@consumerfed.org 

Consumers Union 

By: George P. Slover 

Senior Policy Counsel 

1101 17th Street NW, Suite 500 

Washington, DC 20036 

202-462-6262 

gslover@consumer.org 

Kids In Danger 

By: Nancy Cowles 

Executive Director 

116 West Illinois St, Suite 4E 

Chicago, IL 70754 

312-595-0649 

Nancy@KidslnDanger .org 

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Public Citizen 

Congress Watch 

By: Christine Hines 

Consumer and Civil Justice Counsel 

215 Pennsylvania Ave, SE 

Washington, DC 20003 

202-454-5135 

chines@citizen.org 

U.S.PIRG 

By: Nasima Hossain 

Public Health Advocate 

218 D Street SE, 1st Fl. 

Washington, DC 20003 

(202) 546-9707 

nhossain@pirg.org 

Independent Safety Consulting 

By: Carol Pollack-Nelson, Ph.D. 

13713 Valley Drive 

Rockville, MD 20850 

301-340-2912 

pollacknel@comcast.net 

Safety Behavior Analysis, Inc. 

By: Shelley Waters Deppa 

18417 Shady View Lane 

Brookeville, MD 20833 

301-774-9682 

sdeppa@safetybehavior.com 

Onder, Shelton, O'Leary & Peterson, LLC 

By: James G. Onder 

11 0 E. Lockwood, 2nd Floor 

St. Louis, MO 63119 

314-963-9000 

onder@onderlaw .com 

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Interest of Petitioners 

This petition is brought by nine organizations on behalf of all children and their families affected 

by window covering cords: 

Parents for Window Blind Safety (PFWBS) is a nonprofit organization that supports parents 

whose children have been seriously injured or killed by dangerous cords, educates consumers 

about the dangers of accessible window covering cords in homes, daycare facilities, and military 

housing, helps create safer standards in the industry, encourages innovation of safer products in 

the industry, and tests window covering products for safety. 

Consumer Federation of America (CFA) is the nation's largest consumer advocacy 

organization representing more than 260 state, local, and national consumer organizations that 

was established in 1968 to advance the consumer interest through research, advocacy, and 

education. 

Consumers Union (CU) is the policy and advocacy division of Consumer Reports, an expert, 

independent, nonprofit organization, whose mission is to work for a fair, safe, and just 

marketplace for all consumers. 

Kids In Danger (KID) is a nonprofit organization dedicated to protecting children by improving 

children's product safety. KID was founded in 1998 by the parents of sixteen-month-old Danny 

Keysar who died in his Chicago childcare home when a portable crib collapsed around his neck. 

Public Citizen is a nonprofit consumer advocacy organization based in Washington, D.C. 

founded more than 40 years ago and with more than 300,000 members and supporters nationwide. 

U.S. PIRG, the Public Interest Research Group, is a non-profit, non-partisan public interest 

advocacy organization that takes on powerful interests on behalf of its members, working to win 

concrete results for our health and well-being. 

Independent Safety Consulting (ISC), through its principal, Carol Pollack-Nelson, provides 

14 
human factors consulting specializing in consumer product safety, by evaluating product designs, 

warnings and instructions in order to identify hazards and reduce risks to consumers. Ms. 

Pollack-Nelson was a Human Factors Psychologist at the CPSC from 1988 through 1993. 

Safety Behavior Analysis, Inc. (SBAI), through its principal, Shelley Waters Deppa, provides 

human factors consulting on the safety of consumer products, with a specialty in children's 

hazards, such as choking, suffocation, and strangulation. SBAI analyzes injury data, evaluates 

product designs, and develops and tests safety labels for effectiveness. Ms. Deppa worked in the 

CPSC's Human Factors Division from 1979 through 1992. 

Onder, Shelton, O'Leary & Peterson, LLC pursues this petition on behalf of the over 50 

families with whom they have worked whose children have strangled on window covering cords, 

that window covering cord hazards might be eliminated. 

15 
Exhibits 

Exhibit 1 -2013-04-26, SBAI, Incidents That Would Not Have Been Prevented By 

ANSI/WCMA A100.1. 

Exhibit 2-2013-4-26, SBAI, Standard Is Not Adequate Because Manufacturers Are Ignoring 

The Voluntary Standard. 

References 

Listed in order of appearance in petition 

Available upon request 

CPSC (2007). 2007-08-01, CPSC Release #07-256 "Top Five Hidden Home 

Hazards." CPSC (2013a). CPSC Website, CPSC Safety Alert, "Are Your Window 

Coverings Safe?" 

CPSC, HC, DG SANCO (2010). 2010-06-15, Letter from CPSC, Health Canada and 

DG SANCO to WCMA, ANSI, CEN-CENELEC and CSA Standards regarding joining 

together and requesting industry support for "a swift and comprehensive process that 

concurrently eliminates the risk factors causing deaths and injuries from all types of 

corded window covering products". 

CPSC (20 11 a). 2011-06-01, Letter from CPSC Chair, Inez Tenenbaum to Ralph 

Vasami, Executive Director ofWCMA reaffirming her call "for a more comprehensive 

revised voluntary standard that eliminates-not just reduces-the strangulation risks 

from window coverings." 

CF A (20 11 ). 2011-09-0 1, Press Release of Consumer Federation of America, 

Consumers Union, Independent Safety Consulting, and Parents for Window Blind 

Safety, available on the web at: 

http://www.consumerfed.org/pdfs/WindowCoveringsStandardPressRelease.pdf 

CPSC (1985a). 1985-07-03, Memorandum of Telephone Conversation between Stan 

Marrow and Peter Rush- determining Association's interest in issuing a joint 

consumer safety alert. 

CPSC (1985b ). 1985-09-13, Agenda of Meeting between A WCMA and CPSC Staff 

- Proposed Safety Alert recommending parents to "Cut off any excess cord, or cut it 

to lengths that will not be able to be reached by children". 

CPSC (1985c). 1985-12-00, CPSC Consumer Product Safety Alert "Parents Warned 

16 
about the Danger of Strangulation if Children Become Entangled in Window Blind 

or Drapery Cords." 

DWC (1988). 1988-01-00, Draperies and Window Coverings: Warning Tags from 

A WCMA- Bottom rail labels and hang tags. 

WCSC (1994). 1994-09-00, WCSC Voluntary Corrective Action Plan submitted to 

CPSC. 

CPSC (1994a). 1994-10-03, Letter from David Schmeltzer, CPSC Office of Compliance 

to Peter Rush, WCSC re: Window Covering Corrective Action Plan. 

FAA (1993). 1993-12-00 Evaluation and Testing of Three Cord Management Devices, 

prepared for Levolor by Failure Analysis Associates, Inc. 

CPSC (1994b ). 1994-03-31 Memorandum from Renae Rauchschwalbe to The 

Commission Re: Minutes ofMeeting between CPSC Staff and WCMA. 

CPSC (1994c). 1994-04-05 Memorandum from Scott Heh, ESME to Renae 

Rauchschwalbe Re: ESME Response to PSA No. 9124, Hunter Douglas, Inc. 

CPSC (1994d). 1994-05-24 Memorandum from Celestine Trainor to Renae Rauchswalbe 

re: PSA 9287; Springs Window Fashions- Two Cord blind Fix. 

CPSC (1994e). 1994-06-02 Memorandum from Scott Heh, ESME to Renae 

Rauschwalbe, CECA Re: PSA No. 9293, Spring Window Fashions, Blind Cords. 

CPSC (1995). 1995-11-21, Letter from Marc Schoem, CPSC Division of Corrective 

Actions to Peter Rush, WCMA re: Follow-up to WCMA meeting ofNovember 14, 1985. 

CPSC (1999). 1999-09-03, Letter from Renae Rauchschwalbe, CPSC Office of 

Compliance to Peter Rush, WCSC re: WCSC Strangulations Due to Cords that Run 

Through Window Coverings. 

WCSC (2000a). 2000-09-12, WCSC Voluntary Corrective Action Plan submitted to 

CPSC. 

WCSC (2011). 2011, Window Covering Safety Council Website- Basic Cord SafetyUrges parents to "Install only cordless window coverings in young children's bedrooms 

and sleeping areas." 

WCSC (2000b). 2000-11-01 WCSC Release: WCSC Alerts Consumers To New 

Window-Blind Hazard; Free Repair Kit is Available. 

NYT (20 11 ). 2011-09-01, NYTimes.com, "Consumer Advocates Withdraw from Talks 

on Improving the Safety of Window Blinds." 

17 
CPSC (20 11 b). 2011-08-04, International Consumer Product Health and Safety 

Organization Conference -CPSC Chair Inez Tenebaum in reference to the industry states 

"It's time to 'eliminate' the strangulation risk on window blind cords." 

RILA (2011). 2011-09-12, Letter from Jim Neill, RILA to Ralph Vasami, WCMA 

urging industry to adopt standard that includes: eliminating any cord, including 

operational cord that can form a hazardous loop and address continuous loop tie down 

devices. 

CPSC (2012). 2012-02-06, Letter from Rana Balci-Sinha, CPSC Division of Human 

Factors to Ralph Vasami, WCMA comments on the ANSIIWCMA A1100.1-2010 

American National Standard for Safety of Window Covering Products. 

CPSC, 2013b). 2013-03-18 CPSC Memorandum from Colin Church, Voluntary 

Standards Coordinator to The Commission re: Voluntary Standards Activities FY2012 

Annual Report- Blind Cords- Revise ANSI/WCMA A 100.1 to reduce strangulation 

hazards associated with window covering cords. 

Comfortex (1994). 1994-04-03, Letter from John Schnebly, Comfortex to Ann Brown, 

CPSC urging the "Commission to rethink its potential endorsement of the Hunter 

Douglas Breakthrough Safety Tassel." 

CPSC (2000), 11/1/00, CPSC Release #01-023, "CPSC, Window Covering Industry 

Announce Recall to Repair Window Blinds- New Investigation of Children's Deaths 

Leads t Redesigned Window Blinds." 

Levolor (2001), 3/26, Cordless Technology Provides Safest Alternative in Window 

Blinds and Shades, www.prnewsire.com/news-releases, 71825207.html. 

Hunter Douglas (2000) http://www.hunterdouglasgroup.com/company/history.jsp 

Springs (1995a). 1995-11-04 United States Patent: 5,465,775 Venetian Blind with Wand 

Operator - Assigned to Springs Window Fashions Division, Inc. 

Springs (1995b). 1995-12-05 United States Patent: 5,472,035 Window Blind with Wand 

Operator - Assigned to Springs Window Fashions Division, Inc. 

Newell (1996). 1996-05-07 United States Patent: 5,513687 Safety Device for Pull Cords 

of Window Coverings- Assigned to Newell Operating Company. 

Safe-T-Shade (2010). 2010-03-27 Press Release: New Lift System For Window Shades 

Engineered to Protect Children's Lives. 

Safe-T-Shade (website). www.fashionwand.com 

18 
Footnotes 

I 1985: 8539000973, 8527004494, 850510WES4198, 8537017776,8506093927,8549005084, 8512080995 

8501024422,8521023686,8512090059, G85A0131A, 8548102449, C4C5034A1 

2 1986: 8606003626,8604009348,8636028540, X655212A1, 8612060372,8648060413, 900816HCN2237, 

8602001593, 72S2234A1 

3 1987: 8790630230-S, 870604023 7, 8740008599, 8704014317, 8751029702, 739064029, 8718041406 

G87B0176A, 8712123753 

4 1988: 8837000499, 890711HCC1348, 890808HCC3233, 8838002200, 890808HCC3234, X89B0329A, 

890711HCC1347, 890829HCC3254 

5 1989: 890526HCC1327, 891107HCC3351, 890060HCC1836, 890829HCC3258, 900531HCC3564, 

890816HCC1384, 890828BEP0009, 900130HCC3418, 890926HBB3259, 900105HWE4005, 901115HCC2043, 

891103HCC1544, 901219HCC0085, 891120HWE5013, 900119HCC1616 

6 1990: 900524HCC2219, 900920HCC2015, 9020005539, 921119HCC1912, 900530HNE5188, 

00724HWE5019, 900723HCC3611, 901218HCC1095, 901101HCC0033, 901218HCC2062, 901213HCC0074, 

901227HEP9001 

7 1991: 910123HCC0118, 910305HCC0153, 910213HCC1140, C94B0041A, 910503HCC0210, 

920529HCC0188, 910521HEP2641, 971009CCC2057, 910712HCC2229, 910718HCC1333, 910807HCN1881, 

910905CWE7078, 950224CCC2392, X9196730A, 910912HCN2234, 911211HCC0052, 911031HCC1464, 

920722HCC2207, 920722HCC2208 

8 1992: 92030HNE5088, 920901HCC3229, 930303HCC3140, 920721HCC1775, 920422HEP1281 

930222HCC3127, 930322HCC3159, 920720HCC1774, 930127HCC3090, 9206113354,920811CWE5005, 

920928HCN2681, 921028HCC3034, 930303HCC3141, 930126HCC3087,921119CWE5024, 930409HCC1096, 

930201HCC1027, 930126HCC3086 

9 1993: 930614HCC3232, 930310HCC1065, 9338001173, 9301015308, 930518HCC1131, 930915HCC3310, 

930715CWE50 10, 940126HCC2056, 930920HCC 1775, 930923HCN2539, 960327CCC5075,940421 CCN1236, 

G93C0218A, 9401 03CWE500 1 

10 1994: 940302CWE5007, 940420CCC1437, 940415CCN1214, 940421CCN1237, 940603HNE5149, 

950328CCC1521, 951208CCC1228, 941116HCC3016, 940623CBB2564, 951214CCC3246, P9714316A, 

940802CBB3670, 940802CBB3669, 941101 CWE5006, 960805HCC5429, 951122CCC3190, 950330CCC3537 

11 1995: 950301CCC1401, 950216CCC1367, 961205CCC5112, 950410CCC3574, 950407CEP9005, 

950615CWE5009, 950710CCC3842, 960108CCC3273, 950626CCN2286, 950721CEP9014, 950906CCC1961, 

950727CWE1400, 951011 CBB 1085, 970319CCC1 036, 951128CWE7315, 960305CCC7064, 9511 08HCN0229, 

9601 08CBB2261 

12 1996: 970814CCC2375, 960326CBB5070, 960304HCN0685, 960227CWE5006, 960403CCC5089, 

960403CEP9003, C9650020A, 960611CCC5239, 960827CBB5576, 960520CNE5140, 960524CCC5190, 

19 
96061ICCC5238, 970218CCC5320, 960717CCC5351, 970619CCC3227, 961114CBB5049, 961023CCC5005, 

9611 07CCC5040, 9611 07CCC5036, 961125CWE7249, 970319CCC I 026, 970708CCC3254 

13 1997: 981020CCC3026, 970127CNE5071, 980115HCC3534, 97032ICWE4110, 9801 13CCC2220, 

9720005138, 970916CWE4149, 970418CEP900 I, 98 I 001 CCC40 14, 970522CCC3168, 970709CCC3258, 

970808CCC3288, 980508HCC2533, 971015CCC1584, 971 I I 9CCC1679, 971 I 19CWE5009, 980105CCNOI 16, 

980 I 09CCC2 I 77, 980 I I 2CCNO I 31 

14 1998: 980209CCC3581, 980218CCC0073, 980305CBB5364, H9840074A, 980522CCCI437, 

980326CCC023 I, 9803 I OCBB6684, 980528CCC6842, 98070ICWE71 75, 980813CBB5779, 980821 CBB0662, 

981222CCC2128, 001013CBB0041, 990818CCC0674 

15 1999: 990325CCC0369, 990728HCC3423, 990 I 2 I CBB2205, 990520CNE5 I 72, 990618CWE6004, 

00101 7CBB2033, 0101 I 7CCC0232 

16 2000: 001 I 17CBB3055, 00225CBB2293, 000331CWE6005, 000714CNE5665, 010628CCC3361, 

010323CCC3221, 10040144A, 000518CNE5554, 00083ICNE5737, 010614HCC2573, 001121CCC3068, 

001108CCC0089, 001 102CNE5849, 001213CCC3106, 010111CCC3134, 030908CCC3405 

17 2001: 010109CBB0204, 010125CNE6092, 1/30/01, H0130329A, 010205CCN0282, 010607CCC3331, 

010614CBB2575, 010510CNE6334, 010615CNE6462, 010625CCN0689, 010713CCC1724, 011212CCC21 I 8, 

010723CCC2641, 2/25/09 Sauk Rapids MN, 010815CNE6651, 01121 ICCC1174, 020301CCC1368, 

020 122CEP9002, 030 122CCC 1285 

18 2002: 020107CCN0223, 021016CCC3022, 020719CEP9009, 02061 1CEP9004, 020417CEP9003, 

020610CCC1605, 020716HCC3266, 020604CNE7347, 020619CCN0542, 020807CCN0684, 020812CNE7432, 

020905CCN0794, 020924CWE5017, 9120102 Wichita KS, 021 112CCN0097, 021 107CNE7560, 030123CCC2290, 

030123CCC2289, 021218CCC3132, 021219CCN0213 

19 2003: 030707CWE4337, 030515CEP9004, 03042ICCC2409, 030402CCCI421, 03031ICWE5004, 

030515CEP9003, 030723CCC1740, 030418CCN0479, 030521CBB2460, 030519CWE6003, 030612CCN0613, 

030708CCC3335, 031113CCC3048, 030828CNE8057, 030903CCN0864, 030902CCN0848, 040423CCC3268, 

0337093050-S, 040106CCC1316 

20 2004: 040319CNEI406, 040629CEP9007, 040505CCC2500, 070914CCC1818, 040729CCC3405, 

040722CCC2648, 0425981140-S, 041 I 19CCC2143, 041117CCC2129, 050124CCC3175 

21 2005: 050119CWE3007, 050303CCC1535, 060202CCC2315, 050407CCC3309, 050414CNE2280, 

050426CCC3334, 7/14/05, 050804CCC1029, 7117105 Chillicothe OH, 050923CCC3504, 1012IOCCC1179, 

Xl050632A, 051206CCC3182, 0527035661, 060830CCC1755 

22 2006: 060124CCC1326, 060118CWE5081, 060308CBB1394, 060328CCC2466, 070213CCC3245, 

060502CCC3480, 060602CCC 1567, 0608 I 1 CCC3785, 060920CCC3892, 061207CCC1153, 070213CCC3243 

23 2007: 070221CCC3260, 070719CCC2643, 070308CCC2346, 071219CCC3250, 07053ICCC2538, 

070703CCC1583, 100106CCC2286, 070828CCC2757, 0742086600, 090811CCC3851, 071127HNE2987, 2007 

(month and day unknown) Houston, TX 

24 2008: 080122HNE3082, 080124CCC1351, 090811CCC3850, 0803IOCCCI480, 080423CCCI551, 

080415CCC1535, 081112HWE7844, 080424CCC2597, 100106CCC3229, 080530CCC2699, 080625CCC3646, 

611 I /08 Atlanta GA, 080702CCC 1707, 080812CNE367 5, 109C I 052A, 090204CCC 1402, 080729CCC3 726, 

110421CCC3667, 081002CCC2008, 081 I06CWE7837, 080915HNE3763, 090108CWE7977, I 1/13/08 Shelton 

20 
WA, 081120CCC2142, 090115CCC1355, 090121CCC2276 

25 2009: 090921CCC1073, 2/1/09 Flagstaff AZ, 2/9/09 Supply NC, 090227CCC3369, 111116CCC3139, 

090602CCC3635, 090728CCC2797, 090407CCC3500, 4/?/09 Bennettsville, SC, 090827CCC3926, 

090410CCC2531, 090414HWE8180, 090416CCC2545, 090528CCC3624, 090901CCC3939, 100324CWE2013, 

090910CWE8430, 090710CCC3731,100111CCC3235, 6/15/09 Creve Coeur MO, 090901CCC1033, 

090629CNE4548, 091008CBB1013, 109C1086A, 091009CCC2026, 090728CCC2792, 0949020967, 

100324CWE2012, 090817CNE4677, 090903CBB2900, I0981284A, 090921CCC1076, 090915CCC3962, 

091223CCC1197, 091102CNE4799, 091106CCC3071, H09B0125A, 100714HWE2255, 100105CCC3221,, 

I09C1024A, 091210CCC3160, 091215CCC2238, 100106CCC2286, 100111CCC3232 

26 2010: 100405CCC3517, 100125CWE1054, 100217CCC3328, 100219CCC2387, 120402CCC2594, 

100304CCC1300, 100308CCC2444, 100322CNE0248, 4/6/10 Springfield OH, 100413CCC3564, 100427CCC2639, 

100519CWE2035, 100708CWE2246, 100803CCC1015, 101018CCC2063, 101207CCC3281, 101103HWE2393, 

100915CBB3131, 100920CBB1174, 101123CCC2136, 101104CCC1094, 110103CCC3322, 101214CCC1191, 

11 0204CCC3423, 110 103CCC3319 

27 2 011: 110601 CNEOOO 1, 11 0315CCC1402, 11 0404CCC2425, 11 0516CCC3728, 11 0607CCC3794, 

111206CCC3198, 111018CCC2027, 111024CNE1400, 

28 2012: 120501CCC1644, 120709CCC3743, 120727CCC2904, 120816CWE5001, 120918HWE3109, 9117112 

Sioux Falls SD 

21 
Exhibit 1 

Incidents That Would Not Have Been Prevented by ANSI/WCMA A100.1-2012 

Analysis by Safety Behavior Analysis, Inc. (412611 3) 

TOTAL NUMBER OF WINDOW COVERING INCIDENTS 

293 Total number of window covering incidents between 1996 and 2012 (2010- 2012 

information incomplete): 

-=--.1J. Incidents where unknown/inadequate info to indicate whether in the outer cord 

loop, inner cord loop, or wrap-around and therefore can't tell whether separate 

cords/tassels would have made a difference. 

= 250 Incidents with enough information to determine whether outer cord loop, inner 

cord loop, or wrap-around was involved 

KNOWN INCIDENTS BETWEEN 1996- 2012 (2010 to 2012 info incomplete) 

THAT WOULD NOT HAVE BEEN PREVENTED BY CURRENT VOLUNTARY 

STANDARD 

55 (Table A) Incidents on manufacturer separated outer cords, including those with 

breakaway tassels or breakaway cord joiners, which caused injury or death via 

knotted/tangled loop, defective break away, or wrap-around. 

A( 1) Incidents on pull cords with separate tassels = 51 

A(2) Incidents on tilt cords with separate tassels = 4 

29 (Table B) Incidents on looped outer cords where the manufacturer created loop 

did not cause the incident, This includes following categories 

B(l) incidents on looped outer cords where child not caught in manufacturer 

created loop but was wrap-around = 16 

B(2) incidents in looped outer cords where child not caught in manufacturer 

created loop but caught in tangle/knot above tassel = 13 

5 (Table C) Continuous loop incidents where a tension/tie-down device was present 

but either not installed, had pulled out of wall or broken (number doesn't include 

1 possible but unverified incident listed on sub-table) 

6 (Table D) Other instances where caused by a hazardous cord allowed by the 

standard - such as reverse inner cord incidents, caught in cord joiner loop on 

multi-corded window coverings 

1 (Table E) Incidents which occurred where manufacturer's failure to make 

according the voluntary standard contributed to the cause of incident 

= 102 Incidents would not have prevented by the voluntary standard. 

More than 40% (1 02 of 250) of all incidents would not have prevented by the current 

2012 voluntary standard. 
Injury Data Table A (1996-2012 w/2010-2012 dataset incomplete)-

Known Outer Cord Incidents Involving Manufacturer Separated Cords 

i.e. Separate Tassels, Breakaway Tassels, Breakaway Cord Joiners & Tilt Cords 

(in knotted/tangled loop, defective break away, or wrap-around) 

55 total incidents (32 fatal, 4 severe injuries, 19 other injuries) 

A(1) Incidents occurring on pull cords with separate tassels, breakaway tassels or 

breakaway cord joiners 

Case# Date Age/ Outcome 

Sex 

970319CCC 1026 10/29/96 4 yrs/ F Injury 

Rome, NY 

970418CEP900 1 4/8/97 21 mos I M Injury 

Chicago, IL 

981001CCC4014 4/17/97 14 mos I M Fatal 

El Cajon, CA 

970808CCC3288 7/28/97 4 yrsl M Injury 

Kirkland (Bellevue), W A 

990121CBB2205 1116/99 15 mos /M Fatal 

Roselle (Chicago) (Glendale 

Heights), IL 

010628CCC3361 3/20/00 4 yrsl F Fatal 

0008006909 or 

3/21/00 

Douglas, WY 

Denver, CO 

000518CNE5554 4/16/00 15 mos I M Injury 

Columbia, TN 

000831CNE5737 8126100 2yrsiM Fatal 

Ambrid_g_e _(Pittsburgh}, PA 

001108CCC0089 10119100 2.5 yrsl M Injury 

Peabody, MA 

010614CBB2575 4122101 1 yrl F Fatal 

Sealy (Austin), TX 

01 0723CCC2641 7121101 4 yrs I M Injury 

Utica MI 
Case# Date Age/ Outcome 

Sex 

010815CNE6651 8/10/01 6 yrs/ F Fatal 

Newnan, GA 

020301CCC1368 10/27/01 20 mos/M Fatal 

X0210720A 

Old Bridge, NJ 

020107CCN0223 1/5/02 3 yrs I M Injury 

Lincoln, NE 

02061 occc 1605 4/8/02 8 mos IF Fatal 

Carriere (Picayune), MS 

020812CNE7432 8/8/02 18 mos I M Injury - Severe 

Bridgewater, MA 

020905CCN0794 913102 4 yrs I M Fatal 

Corinth, TX 

030707CWE4337 1/7103 17 mos /M Fatal 

Phoenix, AZ 

030418CCN0479 4116103 14 mos IM Fatal 

Sheboygan, WI 

030708CCC3335 6116103 4 yrsiM Fatal 

San Francisco, CA 

030828CNE8057 8126103 16 mos IM Fatal 

Charlotte, NC 

030902CCN0848 08131103 4 yrs/ M Fatal 

Middletown (Cincinnati) 

lrButler County), OH 

040423CCC3268 9130103 17 mos I M Fatal 

0344194240-S 

0341024944 (DC 1011/03) 

Eugene (Portland), OR 

050303CCC1535 214/05 3.5 yrs IF Fatal 

Naples (Golden Gate), FL 215105 

050426CCC3334 4121105 3 yrsiM Injury 

Pacifica, CA 
Case# Date Age/ Outcome 

Sex 

Xl050632A 11118/05 4 yrs I M Injury 

Parent email to PWBS 

El Cajon, CA 

0603 28CCC2466 3/10/06 2 yrs /M Injury 

Gulfport, MS (IDI- typo, says 

3110104) 

060502CCC3480 4/11/06 15 mos IF Fatal 

Elk Grove, CA lfJ4 mos) 

I 00 I 06CCC2286 8/8/07 2 yrs I M Injury 

Minonk, IL 

070828CCC2757 8/20/07 14 mos IF Fatal 

Helena, AL 

080122HNE3082 1/17/08 3 yrs/ M Fatal 

Crystal Lake, IL 

090204CCC 1402 7/5/08 4 yrs/ M Fatal 

Essex, MD (Baltimore), 

MD) 

090602CCC3635 3/1/09 2.5 yrs I M Injury 

Phoenix, AZ 

09041 OCCC2531 4/8/09 5yrs/F Injury 

Ft. Benning, GA 

090528CCC3624 4/29/09 3 yrs/M Fatal 

Garland, TX 

090817CNE4677 8/9/09 2 yrs I M Fatal 

Gaithersburg, MD (DC- 8/11/09) 

Washington, DC 

1 00217CCC3328 1/30/10 or 2 yrs IF Injury 

1/31/10 

Colorado Springs, CO 

I 00219CCC23 87 2114/10 3yrs/M Injury 

X1020251A 

Saltillo, MS 
Case# Date Age/ Outcome 

Sex 

1 00519CWE2035 5/16/10 22 mos /M Fatal 

CPSC Release #11-036, 

11/10/2010 (5/25/1 0) 

Cedar Falls (Iowa City), 

lA 

I 00708CWE2246 6/9110 3 yrs IF Fatal 

Great Falls, MT 

I 009I5CBB313I 9/10/IO 5 yrs I M Injury - Severe 

XI090325A 

League City (Dickinson), 

TX 

IOII23CCC2136 I 0/30/I 0 2I mos IF Fatal 

Medway (New Carlisle) (DC- I8 mos I F) 

(Dayton), OH 

IOII04CCCI094 II/2/1 0 22 mos IF Injury - Severe 

Burlington (Burlington 

TWP), NJ 

IIOI03CCC3322 II/I0/10 4yrs/M Injury 

Albany, OR 

IIOI03CCC33I9 I2/3IIl 0 I2 mos IF Injury 

Spring, TX 

II 060 I CNEOOO I 3/3/II 2-~ yrs IF Injury - Severe 

Richlands (Camp Lejuene), 

NC 

II03I5CCCI402 3/5/II 11 mos IF Fatal 

Ellicott City (Columbia) (DC- 3/11/II) 

Baltimore City), MD 

II 0404CCC2425 3/I8/II 20 mos /M Fatal 

Delavan (Geneva), WI 

III206CCC3I98 8/27/II 2yrs/M Fatal 

Seattle, WA 
Case# Date Age/ Outcome 

Sex 

Ill 0 18CCC2027 I 0/4/11 3 yrs /M Fatal 

Bonaire, GA 

120918HWE31 09 9/3/12 5yrs/M Fatal 

Kenosha, WI 

A(2) Incidents occurring on the separate tilt cords (not pull cords) of horizontal blinds 

Case# Date Age/ Outcome 

Sex 

080915HNE3763 9/13/08 3yrs/M Fatal 

Miramar (Pembroke Pines), 

FL) 

090728CCC2797 315/09 2 yrs I M Injury 

Rockford, IL 

I 00308CCC2444 3/5/10 4 yrs I M Injury 

Elk River, MN 

120727CCC2904 7/10/12 3 yrs/F Fatal 

Clarksville, TN 
Injury Data Table B (1996 -2012 w/2010 to 2012 incomplete): Window Coverin2sIncidents on window coverin2s with looped pull cords but involvin2 wrap-around or knot 

in loop cord 

29 incidents total 

B(1) Wrap-Around Incidents includes one that may be a combination cord joiner/wrap 

around (16 total, 8 fatal, 1 severe injury, 6 other injuries, 1 no injury) 

Case# Date Age/ Outcome 

Sex 

960304HCN0685 2/6/96 or 4.5 yrs/ F Fatal 

2/5/96 or or 

Veedersburg (Crawfordsville), 217/96 3yrs/F 

IN 

9611 07CCC5040 9/16/96 2 yrs/ F Fatal 

or 

Hunt Valley (Baltimore), MD 9/1/96 

980305CBB5364 2/4/98 2.75 yrs 1M Fatal 

Eddyville, lA 

H0130329A 2/1/01 3yrs/M Injury 

Ft. Leavenworth, KS 

010625CCN0689 6/7/01 4yrs/M !No injury 

Michigan City, IN 

020417CEP9003 3/28/02 22 mos/M Injury 

Everett, WA 

030515CEP9003 3/13/03 3 yrs/M Injury 

Lake Stevens, W A 

030723CCC1740 3/29/03 10 mos IF Fatal 

Philadelphia, P A 

050407CCC3309 3/17/05 4 yrs/ M Injury 

Broomfield, CO 

101210CCC1179 I 0/11/05 13 mos /M InjuryXIOC0115A Severe 

La Plata, MD 
Case# Date Age/ Outcome 

Sex 

051206CCC3182 12/1/05 18 mos IF Fatal 

Bothell (King County), W A 12 mos 

080530CCC2699 5/17/08 14 mos/M Fatal 

Loganville (Snellville), GA 

080625CCC3646 6/9/08 12 mol M Fatal 

Mesa, AZ lr15 moM) 

090407CCC3500 3/29/09 8 mos /M Fatal 

Oklahoma City, OK 

X09B0059A 11/4/09 3Y2 yrs I M Injury 

1114/09 email to PWBS 

Lynden, WA 

120501CCC1644 4/13112 2yrs/M Injury 

Jacksonville, NC (Camp 

LeJeune) 
B(2) Incidents involving a knotted or /tangled cord above manufacturer created 

loop -where child caught in loop above knots 

(13 incidents - 10 fatal, 1 severed injury, 2 other injuries) 

Case# Date Age/ Outcome 

Sex 

9801 09CCC2177 11127/97 20 mos IF Fatal 

or 

Mendota Heights (St. Paul), MN 12/01/96 (DC) 

980326CCC0231 2/28/98 20 mos IF Fatal 

Miami, FL 

980528CCC6842 05/14/98 3 yrs/ M Fatal 

Tacoma, WA 

981222CCC2128 9/1198 5 yrs/ F Fatal 

Roseville (Columbus), OH 

0010 13CBB0041 10/26/98 17 mos IF Fatal 

or 

Antrim (Peterborough) 16 mos IF 

lrManchester), NH 

001102CNE5849 1111100 13 mos I M Fatal 

Willingboro, NJ or 

14 mos I M 

01051 OCNE6334 5/8/01 3yrs/M Fatal 

Fayetteville, NC 

01 0723CCC2641 7/21101 4yrs/M Injury 

I0170330A 

Utica, MI 

020604CNE734 7 5/28/02 17 mos I M Fatal 

(or 19 mos/ M) 

Richmond, VA 

030402CCC1421 2/27/03 3 yrs/M Fatal 

(2 days short of 3rct 

Union City (Union), TN b'day) 

040722CCC2648 7/6/04 2.5 yrs I M Fatal 

Ennis (Waxahachie), TX 

041119CCC2143 9/30/04 2yrs/M Injury 

Wildwood (Chicago), IL 
Case# Date Age/ Outcome 

Sex 

Sheriffs Report, Photo & parents 11113/08 3yrs/F Injury- severe 

depositions 

Shelton WA 
Injury Data Table C (1996- 2012 w/20120- 2012 data set incomplete)- Window Coverin~:s 

Continuous loop incidents where there is a tension device present that 

was not installed/pulled out of wall or broken 

(5 confirmed incidents followed by sub-table of listed but 

not counted I possible unverified incident - all 6 incidents are fatal) 

Case# Date Age/ Outcome 

Sex 

02I 0 I6CCC3022 I/7/02 3 yrs/ F Fatal 

Wheatland, WY 

050804CCC I 029 7/5/05 3 yrs I M Fatal 

7/I5/05 

Portsmouth (Yorktown) (Langley AFB), 7/17/05 

VA 

0608IICCC3785 7/30/06 18 mos I Fatal 

M 

San Bernadino, CA (DC - 8/7 /06) 

lq7 mos) 

09092I CCC I 07 6 9/II/09 3 yrs I M Fatal 

Norfolk, VA 

II05I6CCC3728 4/8/li 5 yrs/M Fatal 

Mill Creek, W A 

Possible but unverified incidents: 

Case# Date Agel Outcome 

Sex 

060830CCC1755 12/31105 2yrs/M Fatal 

Virginia Beach (Norfolk). VA 
Injury Data TableD (1996 -2012 w/2010 to 2012 data set incomplete): Window Coverin~:s 

Other incidents caused by a cord that met the standard - such as reverse inner cord 

incidents, cau~ht in cord joiner loop on multi-corded window coverin~s 

6 incidents total (5 fatal, 1 injury) 

Case# Date Agel Outcome 

Sex 

990325CCC0369 113/99 1 yr/ F Fatal 

Whiteville, NC 

000714CNE5665 3/17/00 2 yrs/ M Fatal 

or 

Irvington, NY 3118/00 

Mt. Pleasant, NY 

060 124CCC 1326 113/06 2yrs/M Injury 

(3 yrs) 

Orlando, FL 

081112HWE7844 4/8/08 3yrs/M Fatal 

Wahiawa, HI 

Schofield Barrack, U.S. Army 

Military housing 

090121CCC2276 12/29/08 2yrs/M Fatal 

(12/30/08) 

Sartell,MN 

090921 CCC 1076 9/11/09 3yrs/M Fatal 

!Norfolk, VA 
Injury Data Table E (1996- 2012 w/2010 to 2012 dataset incomplete): Window Coverin&sIncidents caused or partially caused due to failure of manufacturer to comply with the 

voluntary standard 

7 incidents ( 4 fatal, 3 non-fatal) 

Case# Date Agel Outcome 

Sex 

060602CCC 1567 51I9106 4yrsiF Fatal 

CPSC Release# 09-329 

Pensacola, FL 

080702CCC I707 6126108 2 yrs IF Injury 

CPSC Release #09-05I 

(RI- N 

Bristol, CT I 012II08) 

09092I CCC I 073 I/1109 2 yrs/M No Injury 

CPSC Release # 09-325 (8126109) 

Philadelohia, PA 

09090ICCC3939 511109 5 yrs IM Injury 

CPSC Release #I0-307 

Tacoma, WA 

0907I OCCC3 73I 5121109 2 yrs 5 mosl F Fatal 

police reports, photos, ME report 

Mesa, AZ 

090629CNE4548 6126109 2yrsiF Fatal 

CPSC release I2-273 

Commerce Township, MI 

NIOI0309A; XIOI0430A 11211I 0 3 yrs I M Fatal 

I008003099 

Firestone CO 
Exhibit 2 

Standard is Not Adequate Because Manufacturers Are Ienorine The Voluntary Standar

Compiled by Safety Behavior Analysis, Inc. (4/26113) 

There are numerous recalls (16) involving blinds that were not manufactured in compliance with the volun

of these non-compliances (13 of 16) appear to have been found as a by-product ofCPSC's 2008-2010 focu

roll-up shade inner cord/lifting loop issues. While checking on manufacturers products for roman shade ba

and roll-up shade lifting loop issues; CPSC caught other violations of the voluntary standard including loo

inner cord stops, no tension devices provided with continuous loop products and/or failure to attach a tensi

continuous loop cord. Almost all of these violations were for standard requirements that were passed with 

standard in 1996. Many of these violations went on for years and in one case 2 decades before they were c

CPSC Recall Violation of Voluntary Standard Yearvol Dates 

Release/ Date: standard manufactured Recall# req. and/or sold 

passed 

#07-262 8/3/2007 CPSC and Springs Window Fashions announce recall of 1996 Manufactured 

Basic Blinds ® Window Blinds sold exclusively at Lowes November 2006 

which "have a [!Ull cord that is looQed, gosing a to July 2007. 

strangulation hazard to young children. CPSC File No. 

RP070430, p. 75 et seq. 

#09-051 11120/2008 "Near Strangulation of Child Prompts Recall to 1996 Sold 

Repair Window Blinds by Green Mountain nationwide 

Vista"Roller Shades have a continuous looped bead from June 2005 

chain that was either sold without a tension device or through 

tension device not attached to the continuous looped September 

cord. 2008 

---
CPSC Recall Violation of Voluntary Standard Yearvol Dates 

Release/ Date: standard manufactured Recall# req. and/or sold 

passed 

#09-090 1113/2009 Risk of Strangulation Prompts Recall of Window Blinds 1996 sold 

Sold at Cost Plus and World Market Stores nationwide 

nationwide from February 2006 through August 2008. from February 

Roman Shades and Roll-up blinds have a looped pull 2006 through 

cord August 2008. 

#09-329 8/26/2009 "Strangulation Death of a Child Prompts Recall To Repair 2002 sold in Panama 

Window Blinds By Vertical Land" Hazard: Horizontal City and 

Blinds: The blinds do not have inner cord stoQ devices to Pensacola, Fla. 

prevent the accessible inner cords from being pulled out. from January 

1992 through 

December 2006 

#09-325 8/26/2009 "Near Strangulation Prompts Recall of Roman Blinds; Sold 1996 sold nationwide 

Exclusively at IKEA'' MELINA Roman Blinds have a from August 

continuous looned null cord that did not have the tension 2006 through 

device attached or was sold without a tension device. June 2008. 

#09-328 8/26/2009 "Risk of Strangulation Prompts Recall to Repair Roller 1996 Sold January 

Shades by Lutron Shading Solutions Roller shade 2000 through 

annarently sold without either without a tension device or April2009 

without a tension device attached to the continuous looned 

bead chain. 
CPSC Recall Violation of Voluntary Standard Yearvol Dates 

Release/ Date: standard manufactured Recall# req. and/or sold 

passed 

#10-074 12115/2009 Risk of Strangulation Prompts Recall ofRoman Shades by 1996 Sold nationwide 

Draper Inc. Roman shade with continuous looQ clutch form March 

OQeration system. In addition to exQosed inner cords, there 2000 through 

was either no tie-down Qrovide and/or the tie-down was September 2009

not attached to the shade. 

"#1 0-071 12/15/2009 "Near Strangulation Prompts Recall to Repair Roman and 1996 sold January 

Roller Shades Sold at Pottery Barn, Pottery Barn Kids, and 2003 through 

PB Teens" Roller shade without tension device attached. October 2009. 

#10-070 12/15/2009 "Risk of Strangulation Prompts Recall to Repair 1996 from January 

Matchstick Roll-up Shades by International Merchandise; 2009 through 

Sold Exclusively at Big Lots" Looped pull cords June 2009. 

#10-711 12/17/2009 "Risk of Strangulation Prompts Recall to Repair Faux 1996 Sold in Texas 

wood blinds by American Vintage Group." Hazard: from April 2009 

Strangulation can occur when a child places his/her neck through 

between the cords of the pull cord above the breakaway September 2009

device and the device fails to breakaway. 

#10-149 3/2/2010 "Risk of Strangulation Prompts Recall to Repair Roman 1996 Sold nationwide 

Shades by Lutron Electronics" Sold without tension device from January 

attached to continuous looQed cord. 2000 through 

August 2009. 

--- - -- ------ 
CPSC Recall Violation of Voluntary Standard Yearvol Dates 

Release/ Date: standard manufactured Recall# req. and/or sold 

passed 

#10-261 6/10/2010 "IKEA Recalls Roller Blinds, all Roman Blinds and all 1996 Sold nationwide 

Roll-up Blinds Due to Risk of Strangulation" This recall from January 

involves roller blinds that do not have a tension device 1998 through 

attached to the bead chain, all Roman blinds and all roll-up June 2009. 

blinds. 

#10-307 7/22/2010 "Near Strangulation Prompts Recall of Roman and Roller 1996 Sold nationwide 

Shades by Smith+Noble" This recall involves all roller from 1998 

shades that do not have a tension device attached to the through April 

continuous loop cord and all custom, made-to-order 2010. 

Roman shades. 

#11-306 11/10/2010 "Strangulation Death of a Child Prompts Recall of Roman 1996 Sold from 

Shade, Roll-up Blinds, and Roller Blinds by Hanover January 1996-

Direct Domestications" This recall involves all styles of through October 

Roman shades with inner cords, all styles of roll-up blinds, 2009. 

and roller blinds that do not have a tension device. 

/ 

#12-273 9/6/2012 "Death of Child Prompts Recall of Window Blinds by 1996 Sold in 

Blind Xpress Two-year-old strangles in cord" This recall (attached Michigan, Ohio 

involves all Blind Xpress custom-made vertical blinds that cord tension and Indiana 

do not have a cord-tensioning device that attaches to the device) from January 

wall or floor, as well as all horizontal blinds that do not 2002 (inner 1995 through 

have inner cord stop devices. December 2011

cord stops) 

--- - - -------- -· --------------- ----
CPSC Recall Violation of Voluntary Standard Yearvol Dates 

Release/ Date: standard manufactured Recall# req. and/or sold 

passed 

#13-707 1112112012 Hunter Douglas Recalls to Repair Custom Cellular and 1996 Sold nationwide 

Pleated Window Coverings Due to Strangulation Hazard. from January 

No incident. Some of the cords inside the 2011 through 

breakawa:Y cord stoQ were tied in a single knot August 2012. 

which can 12revent the cord stoQ from functioning 

as designed to break awa:Y. A child can become 

entangled in a cord loop and strangle. Standard 

cordlock top-down/bottom-up Duette and 

Applause honeycomb shades; standard cordlock 

top-down/bottom-up Hunter Douglas pleated 

shades; Hunter Douglas Brilliance Privacy View 

pleated shades and standard cordlock Duette and 

Applause Duolite shades 

- -- - ----·----·-