On April 21, the Tile Council of North America (TCNA) submitted comments opposing a petition by the National Floor Safety Institute (NFSI) that requested that the Consumer Product Safety Commission (CPSC) require manufacturers of flooring, cleaners, and footwear to label their products per an NFSI label and test products per NSFI-developed methods. As detailed in TCNA’s response, if the NFSI proposal were implemented by the federal government as proposed, while benefitting NFSI, it would put consumers at greater risk of slip/fall injuries and would cost manufacturers and retailers tens of millions of dollars to implement.
NSFI has made similar petitions to the CPSC before, in 2015 and 2018. Both were denied for numerous reasons based on CPSC staff recommendations as summarized in this staff notation from its 2018 briefing package to the CPSC Commissioners: “CPSC staff concludes that the 2018 petition does not resolve the Commission’s concerns in denying the 2016 petition, and therefore recommends that the Commission deny the 2018 petition. As with the 2016 petition, staff concludes that it is unlikely that the action requested by the petitioner will reduce injuries from slips and falls.”
TCNA’s response provides information to the CPSC, including:
- NFSI’s failure to address CPSC requirements and concerns raised with prior petitions;
- That the coefficient of friction (COF) measurements NSFI is proposing will not result in fewer slips and falls, but rather misinform the public;
- That the B101.2, B101.3, B101.5, and B101.7 documents (developed by NFSI and not accredited through ANSI nor ASTM) are deeply flawed and should not be utilized;
- That the measurement of DCOF proposed by NFSI does not equate to traction; and
- Examples of the tile industry already providing substantial information on where products can be used based on slip resistance characteristics per ANSI A326.3, American National Standard Test Method for Measuring Dynamic Coefficient of Friction of Hard Surface Flooring
“We hope that the irony of NFSI’s self-serving petition — benefiting NFSI and potentially harming those it claims it wants to protect — is apparent to the CPSC,” said Eric Astrachan, TCNA’s Executive Director. “The Tile Council is aligned in its opposition along with other flooring sectors, footwear manufacturers and retailers, manufacturers of floor cleaners, and numerous safety professionals.’
Read TCNA’s full response here.
“We must not assume that while prior self-serving petitions from NFSI failed, that this one will as well without industry comment,” said Grant Davidson, TCNA’s Standards Development Engineer. “We presented the CPSC with a robust industry response, noting the many shortcomings, deficiencies, and dangers of this latest NFSI petition.”
