Panel Statement:
The Panel has reviewed all comments and concludes that
requiring tamper-resistant receptacles will effectively reduce child burns and
electrocution. Specific responses to comments are as follows.
(1) Test data presented to the panel indicates insertion and withdrawal forces
will not be a problem for the aged or physically challenged. Insertion forces
necessary to open the shutter at 20-25% those necessary to insert a plug into a
receptacle and once the shutters are cleared no additional force is required to
engage the plug into the receptacle contacts.
(2) The safety justification is compelling. CPSC and CHIRPP use highly
sophisticated statistical models that allow accurate estimates of the total
universe. The fact that CPSC data was remarkable similar to a totally different
study in Canada corroborates both sets of data.
(3) The plastic safety caps mentioned in some substantiations have been
available during the entire time of the hospital emergency room data collection
in both the US and Canada and did not mitigate thousands of burn incidents
each year.
(4) The UL/ANSI standard has requirements and tests that attempt to defeat
the shutters. UL fully tests with a probe to try to manipulate opening. Similar
products have been in use for over 20 years in pediatric areas with no evidence
of them being defeated. Shutters are commonly used in European electrical
receptacle devices.
(5) The NEMA cost estimate was based on the cost adder for residential type
tamper resistant receptacles produced in the volumes this requirement would
result in. Cost estimates based on hospital
or specification grade products are based on today?s market size and do not
provide a valid comparison.
(6) The panel considered limiting the requirements. The hazard exists on vanity
and kitchen countertops on which children are placed and which have easily
accessed receptacles. Given the very few receptacles that would, under all
circumstances, not be accessible and the modest cost of the receptacles, it was
decided that a clear, unambiguous requirement would be easier to follow and
enforce.
(7) Neither AFCI nor GFCI eliminate the faults that result in the child burns.
Neither product is intended to protect against the type of burn incidents on
which this requirement is based.