Letter to Elliot Kaye, Chairman of U.S. Consumer Product Safety Commission - Proposed Federal Rules That Could Threaten NH Recreational Vehicle Users

Letter

Dear Chairman Kaye:

We write to express our continued commitment to public safety and support the U.S. Consumer Product Safety Commission (CPSC)'s decision to defer its vote on the pending Notice of Proposed Rulemaking (NPRM) regarding a mandatory safety standard for recreational off-highway vehicles (ROVs).

On September 24, 2014 you received a briefing package from CPSC staff recommending the proposed NPRM on ROVs which was based on comparison to the voluntary standard from 2011. On that same day, the American National Standards Institute (ANSI) approved the updated voluntary standard for ROVs (ANSI/ROHVA 1-2014). The updated 2014 voluntary standard was pursued by the industry after years of discussions with the CPSC staff in order to meet some of the concerns that were raised about the 2011 voluntary standards.

The CPSC is required by statute to assess the adequacy of a voluntary standard before moving towards mandatory standards. However, the briefing package delivered to you and your fellow Commissioners on September 24th does not address the updated voluntary standard, instead it assesses the adequacy of the now superseded standards from 2011.

We appreciate that the CPSC has decided to defer its vote on the pending NPRM for a week but we encourage the CPSC to take any additional time necessary so that CPSC staff may have adequate time to assess the adequacy of ANSI/ROHVA 1-2014. During this time we recommend that the CPSC staff and the industry reach an agreement on voluntary standards that adequately address the risk of injury concerning ROVs. Thank you again for your attention to this critical issue.