Advocacy Comments on Safety Standard Addressing Blade-Contact Injuries on Table Saws
July 26, 2017
On May 12, 2017, the Consumer Product Safety Commission (CPSC) published a proposed rule titled: Safety Standard Addressing Blade-Contact Injuries on Table Saws. The proposed rule would require table saw manufacturers to incorporate active injury mitigation (AIM) technology in all types of table saws. The U.S. Small Business Administration’s Office of Advocacy (Advocacy) applauds CPSC’s efforts to mitigate blade contact injuries from table saws, and submits the following comments in response to the proposed rule. Safety when using table saws is a priority for small businesses; however CPSC’s proposed rule is overly broad and imposes stringent and cost-prohibitive requirements that will cause most if not all small table saw manufacturers to exit the market. Advocacy urges CPSC to consider the following, and in doing so, publish a supplemental Initial Regulatory Flexibility Analysis (IRFA) for notice and comment in respect to: (1) use of proprietary technology; (2) significant alternatives that minimize the impact on small businesses; (3) a reanalysis of voluntary standards data to ensure accuracy; and (4) supplementing the additional presentations of cost and benefit analysis. In addition, Advocacy requests that CPSC extend the comment period for the proposed rule until the conclusion of the oral presentation of comments, and until the latest Underwriters Laboratory (UL) injury data report has been released, thus allowing the public adequate opportunity to comment on both.