Consumer Federation of America, Consumer Reports, National Center for Health Research, American Academy of Pediatrics, and Safe Infant Sleep submitted comments to the Consumer Product Safety Commission in connection to its request for information on reducing regulatory burdens. The comments argue that framing essential consumer safety protections as a regulatory burden distorts the protections’ societal value and potentially undermines public safety. For example, CPSC regulations implementing the Poison Prevention Packaging Act requiring child-resistant packaging for medications and certain household products resulted in an 80% decline in childhood poisonings from 1972 to 2020. Improved safety standards for automatic garage doors have largely eliminated deaths from garage door incidents. Strengthened standards for baby walkers have reduced walker-related injuries by 88%. This small sampling of CPSC’s work demonstrates that agency rules have proven their worth in real-world outcomes that have saved lives and prevented injuries.
Indeed, the comments illustrated the fundamental condtradction the CPSC’s request for information rests on acknowledging that deaths, injuries, and property damage from consumer product incidents cost the nation more than $1 trillion annually, while simultaneously suggesting that the regulations designed to prevent these very harms are ideologically driven and unnecessarily burdensome. This trillion-dollar figure represents a clear need for robust regulatory action to protect US consumers from physical harm and financial losses, indicating that the true burden facing Americans is the annual cost of harms, not the regulations that demonstrably mitigate such harms.