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Therefore, the cost-benefit analysis assumes that there will be 100% compliance with the Regulations after the coming into force. This cost is counted as a one-time expense imposed by the advent of the Regulations to achieve compliance and is not considered an annual cost thereafter.By combining the incremental costs outlined above, we estimate the total cost to be $29.1 million in the first year of the Regulations, and $14.0 million per year thereafter, with cumulative costs of $267 million over a 20-year period.Discounting future costs at 7% annually provides a present cost of $145 million.
Assuming that manufacturers do not bear any of the cost increases themselves, thus passing on 100% of the cost increase directly to consumers, demand would fall by about 2.1%. In 2012, an additional hazardous loop test for inner cords was introduced in the American voluntary standard. Health Canada has determined that no changes or exemptions are necessary to address these concerns.Comments were received from manufacturers, retailers, and an industry association stating that costs imposed by complying with the requirements of the Regulations would be excessively high, and that the increased production costs would effectively be passed on to consumers as price increases. It is unreasonable to expect caregivers to maintain visual contact with a child at all times. This reduction in annual sales by 83 388 units is estimated to result in annual lost profits valued at $2.66 million.Safer alternative window coverings already exist in the Canadian market and continue to be developed for all sizes of windows. The webinars provided details on the technical requirements of the proposed Regulations, along with instructions for submitting comments.Responses from 241 stakeholders were received on the Responses from 21 stakeholders were received on the cost-benefit analysis consultation. The CWCPR and the new American voluntary standard both continue to allow this hazard.In 2014, Health Canada completed a risk assessment on CWCs to assess the effectiveness of the CWCPR to address the strangulation hazard.
One possible explanation offered by the author of the study is that in the winter it is dark when people wake up and dark when they return home from work, so there is no reason to adjust window coverings.
Health Canada will continue to collaborate with the U.S. CPSC to help continue to improve the safety of this product category.Strangulation from CWCs is a preventable hazard that affects a vulnerable population. Over the past nine years, since the CWCPR has been in force, Health Canada is aware of 9 fatalities in Canada for an average fatality rate of 1.0 child fatalities per year.According to the WCMA, the target lifespan is 10 years for custom CWCs and 3–5 years for stock CWCs (WCMA 2015a and 2015b). Submission on the “Corded Window Coverings; Request for Comments and Information”, Window Covering Manufacturers Association 2018. Injuries and fatalities have occurred even with a typical level of supervision. As a result, it is both possible and likely that industry will consider, and be able to manufacture going forward, more of their products as custom. When this force is removed, cords that can be reached must retract to less than 22 cm in length or 44 cm in circumference.Further to the above-mentioned restrictions, the Regulations will require a warning on the product, packaging, instructions, and associated advertisements that speak to the hazards and specifications outlined above, with instructions to immediately remove the product should those hazards become present.To provide flexibility for small businesses and help address concerns expressed during consultations, the Regulations will come into force 24 months after the day on which they are published in the Under the status quo, CWCs in Canada would continue to be subject to the legislative requirements of the CWCPR. This estimate is, broadly speaking, in line with WCMA’s statement that “stock products account for more than 80% of all window covering products sold in the U.S. and Canada” (WCMA 2018).
This analysis also assumes that the Canadian market consists of 75% stock and 25% custom products. Health Canada funded a CSA committee to draft the national standard (CAN/CSA Z600 — Throughout more than a decade of standards-development processes, including amendments and updates to the CWC standards in Canada and the United States, Health Canada has consistently pointed out gaps related to strangulation. Products which are not completely assembled prior to distribution (not “substantially fabricated” as the definition of stock requires) thus become custom-ordered and later assembled with cords. CPSC administers and enforces several federal laws.
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