Letter to Mr. Ralph Vasami, Executive Director of the Window Covering Manufacturers Association - Provide Strong Child Safety Protections for Window Coverings

Letter

In June, I welcomed your announcement that the Window Covering Manufacturers Association (WCMA) would revise the current voluntary window covering standard to effectively address the significant strangulation risk to children posed by accessible window covering cords. Your commitment to develop and submit for ballot, in accordance with American National Standards Institute guidelines, a revised standard by the end of 2016 is commendable. However, as we near the end of 2016, and in the midst of four recent window covering cord child deaths, I write requesting the data supporting your proposal to segment the market and the applicability of the voluntary standard based on whether the product is "stock" or "custom." This data is critical to helping those involved in the standard-setting process to understand your reasoning behind this proposal and to keep us on schedule to finalize a revised standard by the year's end.

As you know, I have pledged to do all I can to comprehensively eliminate the preventable danger posed by dangerous window covering cords. Part of my work has included working with relevant federal agencies, including the Department of Defense (DOD) and the Department of Housing and Urban Development (HUD), both of whom provide housing to particularly vulnerable segments of the population. I have urged both agencies to replace window coverings in the housing they oversee in order to safeguard young children from such dangers. Despite progress on these fronts, WCMA's revisiting of the voluntary standard represents a significant and important opportunity to put an end to the tragically predictable and over two-decade long trend of one child dying each month from window covering cords.

According to the most recent draft of the standard, only "stock" window coverings will be required to be cordless. Any so-called "custom" window coverings will be exempt from cordless requirements that would significantly reduce the strangulation hazard posed to children by corded window coverings. A "custom" order may include any window covering orders for an irregular window size, particular material, an order of a large quantity, or any order where the window covering is fabricated after the order is made by the consumer. Such "custom" orders are often made online, where customers can be presented with many options. Thus, it is important to those involved in revising the current standard to have a clear understanding of the current window covering market and its trajectory, including what share of the market is sold as "custom" and as "stock," including online sales in both categories, so that we can accurately assess to what extent the new standard will effectively protect young children.

Accordingly, I respectfully request any data and reports supporting WCMA's assertions that this proposed segmentation of the market into "stock" and "custom" would allow the standard to address the vast majority of the window covering market. This information should include what percent of sales are made online and in-stores, units for any data, such as whether it is in terms of sales volume or sales dollars, as well as methodology explaining how data was gathered.

Thank you in advance for your prompt attention to this request. I respectfully request the data requested no later than Wednesday, December 21, 2016.

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