Most Americans take safety for granted when they buy consumer products such as shampoo, sunscreen, couches, cribs, bike helmets, teething toys, or watch their children play on artificial turf or rubber play surfaces. We are educating families, communities, policy makers, and the public to take a more careful look at the safety claims of these products.
The Coalition expressed concerns that patients, health professionals, and industry-affiliated individuals are erroneously categorized as Consumer Representatives on FDA Advisory Committees.
We strongly support SB 0763, which would prohibit the use of state funds for artificial turf fields and playgrounds. At the House hearing on the companion bill, HB 505, I heard testimony from individuals who misrepresented the evidence regarding the safety of recycled tire material, other synthetic rubber, and other synthetic materials on playing fields and playgrounds.
We strongly support the safety and effectiveness clinical and nonclinical testing requirements to obtain generally recognized as safe and effective (GRASE) status, as they are articulated in the draft guidance. Americans are using sunscreens more frequently and on a more long-term basis than ever before. Our safety and efficacy standards must reflect that Americans of all ages rely on these products to protect them from skin cancer.
FDA should test drop-rail cribs for safety, since there are well-established and serious risks. We oppose the FDA proposed rule as currently written because it would not require any safety testing data be reviewed by the FDA. However, even if that part of the proposed rule were revised, the proposed rule would still create an enormous loophole that would allow widespread use of cribs outside of healthcare settings, as noted above.
We believe that pregnant women’s daily exposures to phthalates since 2005-6 are likely to be similar to other women of reproductive age (WORA). The new report indicates that some of those exposures have increased and others have decreased, presumably reflecting changes in products more than changes in women’s habits. It is alarming that the daily intake of DINP has increased. We strongly support the plan to make the interim ban on DINP a permanent one.
The coalition strongly supports most provisions of the proposed rule on the “Prohibition of Children’s Toys and Child Care Articles Containing Specified Phthalates.” However, we are disappointed with some of the provisions described above and strongly disagree with the CPSC regarding DIOP. In the final rule we recommend that the CPSC protect the health of consumers by permanently banning DIOP.
We strongly oppose the use of ASTM International Standard (F1917-12) as a safety standard for baby bumper pads. The standard is not a useful alternative to the Department of Health and Mental Hygiene’s (DHMH) proposed ban. As we stated in our July 19, 2012 letter to DHMH, we agree with DHMH that “the pads pose a risk of suffocation, strangulations, and death.”
We support most of the proposed guidance because it will help to protect the public, especially children, from the adverse effects of phthalates. Nevertheless, it would be better to explicitly protect children by not assuming fabric covers are adequate protection against phthalates.
Congressman Markey’s petition would provide extra safeguards to protect all babies and children. We know the focus of this “Notice of petition” is on amending regulations because BPA use has been abandoned in packaging for infant formula, but we encourage the FDA to release its separate assessment of the safety of BPA.
We strongly support the proposed ban. The risks of bumper pads in cribs are real (suffocation, strangulations, and entrapment) while the benefits are essentially nonexistent. The four doctors on Maryland’s expert advisory panel regarding crib baby bumpers concluded that there was no evidence for meaningful benefits of bumper pads to infants. This ban will help to protect more than 70,000 babies born in Maryland each year.
