October, 1997 The Honorable Thomas H. Moore, Commissioner United States Consumer Product Safety Commission 4330 East-West Highway Bethesda, MD 20814 Dear Commissioner Moore: I have just recently learned of the CPSC's decision to relax the flammability standards for children's sleepwear. America's children have been protected from the risk of fire from their sleepwear for nearly twenty-five years. The decision by the Commission may put infants and children at a higher risk from burns. Available injury and death data demonstrates that the sleepwear standard was working. There have been few injuries or deaths involving ignition of children's sleepwear since the enactment of the standard nearly twenty-five years ago. This low level of injuries and deaths can primarily be attributed to the established sleepwear standards. It is the Commission's responsibility under the flammable Fabrics Act to protect the public against unreasonable risk of fire leading to death, injury or significant property damage. The Commission's decision to relax the sleepwear flammability standards now places infants and children at potentially higher risk for burn injury. The CPSC had assured concerned individuals that there would be an extensive awareness and educational campaign developed and disseminated for consumers and sales personnel regarding the changes and the risk of non-flame resistant sleepwear. This lack of consumer education, as promised by the manufacturers apparel industry, makes it difficult for consumers to obtain accurate information about safe sleepwear choices. This may result in consumers making uniformed decisions which could jeopardize the well- being of their children. As a regulatory agency, the CPSC has the responsibility to provide clear, concise, accurate information to consumers. The initial requirement for clear and conspicuous warning labeling of non-flame resistant garments has also been removed from the amendments making it more difficult for consumers to differentiate between flame resistant and non-flame resistant garments at the point of sale. As a member of the health care profession (burn team, fire service, other) who must deal with the pain, suffering and cost of burn injuries on a daily basis, I urge you to please reconsider this matter and take steps to bring back the previous standards that were clearly working to prevent death and disfigurement for numerous young children. There is no need to change what is working. Sincerely yours,