The National Consumers League, Consumer Reports, the Consumer Federation of America, Public Citizen, US PIRG, and R. David Pittle, Ph.D., welcome the opportunity to comment on the report by U.S. Consumer Product Safety Commission (CPSC) staff titled, Table Saw Blade-Contact Injuries Special Study Report, 2017 (2017 Special Study or Special Study).
We have been advocating for the improvement of the safety of table saws for more than a decade. We applauded the CPSC’s decision to publish a Notice of Proposed Rulemaking (NPR) in 2017 to advance the safety of these products. We believed then—and still believe now—that the Commission’s proposed performance requirements will produce inherently safer saws, such as those that currently employ an Active Injury Mitigation (AIM) system. This would be a dramatic safety improvement in a product market that is filled with unreasonably hazardous products that are involved in tens of thousands of injuries every year.
As part of its decision on April 27, 2017, the Commission directed agency staff to complete and publish for comment a Special Study regarding the type of table saws (bench, contractor, or cabinet) that produce injuries identified in the National Electronic Injury Surveillance System (NEISS). On December 4, 2018, the agency sought public comment on the Special Study, which evaluated table saw injuries that occurred in 2017.
With one glaring exception, we believe the overall results in the Special Study reinforce key findings of the Commission’s NPR and, thus, further support its proposal for a mandatory safety standard requiring safer performance of all three types of saws.
One aspect of the study—the claim that the relative-risk ratio associated with table saws with Modular Blade Guards (MBGs) is only 1/7th the risk of table saws with Traditional Blade Guards (TBGs)—defies common sense and is flatly refuted by other more reliable data. Were this claim accurate, it would be reasonable to expect the number of injuries to have dropped substantially between 2010 and 2017. Instead, the number of injuries remained virtually the same. This claim should be rejected outright.
For the full comments, click here.