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Joint comments to CPSC on the proposed rule for Button Cell or Coin Batteries and Consumer Products Containing Such Batteries

Our coalition of medical and consumer organizations welcomes the opportunity to submit the following comments to the Consumer Product Safety Commission (CPSC) regarding the agency’s notice of proposed rulemaking to establish a safety standard and notification requirements for button cell or coin batteries and consumer products containing such batteries pursuant to Reese’s Law. We commend the CPSC’s work on the proposed safety standard and submit to the agency the following comments.

Button batteries are ubiquitous and useful; powering toys, tools, and consumer products that we all use on a daily basis. While these batteries have important uses, they also come with serious risks that require specific protections for children. Children face potentially deadly ingestion hazards from button cell or coin batteries taken out of common household products, such as small remote controls, garage door openers, bathroom scales, cell phones, flameless candles, watches, cameras, and digital thermometers.

If swallowed, these batteries can come in contact with a child’s airway or esophagus, increasing the risk of possible choking as well as a greater likelihood of the battery immediately discharging electricity. This can lead to life-threatening burns, perforations, and necrosis of the child’s soft tissue surrounding these batteries. Symptoms of ingestion in children are often overlooked or mimic other common conditions, such as croup, colds, or upset stomachs. In addition, given their ubiquity, these batteries are often ingested without an adult being aware a loose battery was within reach. Because symptoms can resemble common conditions and parents are often unaware of the battery ingestion, they may only be able to provide the physician with a partial health history and the child’s condition can end up diagnosed as another common condition. This results in a preventable hazard harming thousands of children every year who suffer serious, life-threatening burns to their throats and other soft tissue and can go undetected.

This is why our coalition was proud to support Reese’s Law, which Congress passed to protect children against hazardous button and coin cell battery ingestion in 2022. This bipartisan law requires the CPSC to promulgate a safety standard for button cell or coin batteries and consumer products containing button cell or coin batteries. This standard would require consumer products to secure these batteries in a manner that prevents children from accessing them. The law also improves warning label requirements to communicate the hazard of ingestion and requires button cell or coin batteries to be sold using child-resistant packaging. These measures will help prevent children from accessing button batteries in the first place, which will save lives.

For full comments, click here.