BEE 17 Ensure Manufacturer Instructions for Pool Safety Products are Accessible to Consumers
Require manufacturers of pool fences and secondary safety barriers (e.g., pool safety covers, alarms) to provide easily accessible hard copy or digital instructions on product installation, use, and maintenance. Instructions should be made available to consumers.
Spectrum level: Changing Organizational Practices Strengthening Individual Knowledge and Skills
Evidence level: Low
Implementation levels: National
Rationale:
Requiring digital access to installation and maintenance instructions allows buyers and installers of the product, building inspectors and subsequent owners to have equal access to instructions. Proper pool barrier product installation and maintenance will extend the product’s material durability, functionality, and will reduce the number of immersion injuries and deaths. Additionally, this information is critical to alert consumers about the risk of altering the safety product (such as disabling a door alarm or altering any of the safety barriers for personal convenience).
Anticipated Impact:
After implementing this recommendation, you can expect to experience the following outcomes.
- Access to digital instructions leads to pool barrier product installation and maintenance being completed appropriately.
- Effective pool barrier product installation and maintenance leads to extended product material durability and functionality.
- Enhanced pool barrier product durability and functionality leads to reduced immersion injuries and drowning deaths.
Evidence:
Since the complete text of voluntary standards must be purchased from the generating organization, lack of funding to purchase these standards makes reviewing them impossible at this time. However, the risk of safety barriers malfunctioning and leading to a drowning incident is very high for products that are not installed correctly. Installation guides are generally included within conformance testing where the tester follows the guide/video to install the product and then performs a test/tests. Products shall not pass conformance standards if they do not include accurate installation procedures.
Evidence Sources:
U.S. Consumer Product Safety Commission. (1999). CPSC, Newco Announce Recall to Repair Bunk Bed Assembly Kits. https://www.cpsc.gov/Recalls/1999/cpsc-newco-announce-recall-to-repair-bunk-bed-assembly-kits
U.S. Consumer Product Safety Commission. (2009). Fitness Balls Recalled by EB Brands Due to Fall Hazard; New Assembly Instructions Provided. https://www.cpsc.gov/Recalls/2009/fitness-balls-recalled-by-eb-brands-due-to-fall-hazard-new-assembly-instructions
U.S. Consumer Product Safety Commission. (2010). CPSC Announces Recall to Repair Child Craft Brand Stationary-Side Cribs with Dowel Due to Entrapment and Strangulation Hazards. https://www.cpsc.gov/Recalls/2010/cpsc-announces-recall-to-repair-child-craft-brand-stationary-side-cribs-with-dowel-due
Ross, K. (2015). The Role of Product Instructions in Product Liability. IN Compliance Magazine. https://incompliancemag.com/article/the-role-of-product-instructions-in-product-liability-prevention/
U.S. Consumer Product Safety Commission. (2003). Manufacturer’s Guide to Developing Consumer Product Instructions. http://www.cpsc.gov/PageFiles/103077/guide.pdf
High Risk Populations Addressed:
Populations whose risk of drowning decreases the most with the implementation of this recommendation may have one or more of the following characteristics:
- Buyers of homes with existing pools
- Children who live in or visit homes with pools
Evaluation Metrics:
Indicators of long-term impact:
- An easily accessible database, inclusive of installation and maintenance instructions for pool and spa safety products has been developed, disseminated and is being sustained
Implementation:
Consider the following to ensure successful implementation:
- Search existing manufacturer and owner manual databases to compile links to barrier products so pool owners and other interested parties have access to a limited list of product information and instructions.
- Work alongside manufacturers, consumers, and government agencies to ensure that clear and complete instructions are included with each product type (written and digital).
- Monitor consumer complaint and injury databases such as the CPSC website www.saferproducts.gov, which allows product owners and tradesmen to report product complaints and related injuries, including those associated with installation and maintenance failures.
- Consider the development of a national database of pool and spa safety products inclusive of installation and maintenance information.
Challenges to Implementation:
When implementing this recommendation, you might encounter challenges related to the following factors.
- The funding, resources and staffing necessary to maintain a database may be challenging to acquire.
Potential Facilitators:
The following factors might facilitate the implementation of this recommendation.
- The following groups may play a role in facilitating access to the information: product manufacturers, real estate agencies
- Product manufacturers could enhance and expand current content on their websites addressing installation and maintenance.
GAP Recommendation:
Currently there are no consistent databases containing pool barrier product installation and maintenance information.