The CPSC data demonstrates that water beads present multiple serious risks, particularly for young children, due to the product’s propensity to expand and cause obstructions in various body systems. While CFA welcomes CPSC’s work to develop a mandatory standard for water beads, its comments identified areas requiring more CPSC action. First, while the proposed requirements to address ingestion, insertion, and aspiration hazards are a first step to mitigate the dangers of water beads, the 9.0 mm diameter funnel is not sufficient to address ingestion and aspiration hazards. Second, CFA urged the CPSC to consider a lower acrylamide limit. Third, CFA suggested CPSC continue to research water beads to determine the hazards, including acrylamide toxicity, of broken water beads.