NCHR Comment on Petition Requesting Rulemaking To Mandate Testing and Labeling Regarding Slip Resistance of Flooring, Floor Coatings and Treatments, Floor Cleaning Agents, and Footwear
April 22, 2024
Docket No. CPSC-2024-0003
We appreciate the opportunity to comment on the CPSC’s proposed rule regarding: “Petition Requesting Rulemaking To Mandate Testing and Labeling Regarding Slip Resistance of Flooring, Floor Coatings and Treatments, Floor Cleaning Agents, and Footwear”
The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health and safety issues, with a particular focus on which prevention strategies, treatments, and products are safest and most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
We support the CPCS’s proposal for the NFSI to require testing and labeling regarding slip resistance for flooring, floor coatings and treatments, floor cleaning agents, and footwear. We agree that the information should be clearly labeled and easy-to-understand, so that consumers can accurately assess the slip and fall risks associated with different products. These labels should indicate the product’s risk level for slipping and injury and should be consistent across all products. The labels should grade flooring and related products based on their traction so that those with higher traction are labeled as safer for consumers. In addition, flooring safety should take into account how the flooring material is used, since floor mats, bath mats, and area rugs pose a risk of tripping and falling regardless of the materials they are made of. Stringent testing for flooring and related products ensures they are safe for their intended use, leading to a safer home and work environment and reducing injuries. Each year, three million older adults visit the emergency department due to falls. While slip-and-fall accidents can’t be entirely avoided, strict safety standards and clear labels give consumers the information they need to make better choices about flooring for their workplaces and homes.
Although these are all important safeguards, it is important to note that slip resistant flooring materials are not the only flooring safety issue of concern to consumers. The proposed rule addresses slip and fall risks, but there are other dangers of flooring; in fact, rubber flooring may be less slippery but contains chemicals that may present major safety issues, especially for young children. Therefore, it would be misleading and potentially harmful to have a safety standard that focuses entirely on being slip resistant. CPSC and NFSI should simultaneously include safety standards regarding exposure to endocrine disrupting chemicals and other potentially dangerous exposures for flooring, especially indoor flooring. Recycled tire materials and “virgin rubber” used in flooring, especially playrooms, daycare centers, playgrounds, exercise areas, and garage flooring, contain PFAS and other hormone-disrupting chemicals and may contain lead and other heavy metals. These chemicals off gas from the flooring and are in the air that people breathe, and in the dust on the flooring surface that children will get on their skin and clothes. Exposure to these chemicals can lead to health issues such as attention deficits, obesity, asthma, allergies, early puberty, and cancer. This is a particular problem for indoor flooring since so many homes and daycare centers keep their windows closed most of the time. Therefore, CPSC needs to require testing of flooring materials to ensure they are safe for prolonged exposure, safeguarding children and adults of all ages who come into frequent contact with them. This will guide consumer choices and encourage safer material choices by manufacturers.
In summary, while we support testing and labeling to inform consumers about slip-and-fall risks from flooring and related products, the rulemaking on safety should extend beyond this. The CPSC and NFSI should ensure that floorings labeled as “safe” do not include toxic materials in their products, as is currently the case for rubber flooring, and especially those made from recycled tires. A more comprehensive safety standard would encourage flooring manufacturers to produce products that reduce slip and fall injuries as well as potentially harmful chemical exposures.
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