Consumer Product Safety Commission
Better Data Collection and Assessment of Consumer Information Efforts Could Help Protect Minority Children Gao ID: GAO-09-731 August 5, 2009In 2004, the U.S. Consumer Product Safety Commission (CPSC) estimated that 29,400 deaths in the United States were related to consumer products. As required under Section 107 of the Consumer Product Safety Improvement Act of 2008, this study reviews what is known about the relative incidence of preventable injuries and deaths among minority children associated with products intended for children's use and also examines what actions CPSC has taken through its public information and education initiatives to minimize these injuries and deaths. To address these issues, we assessed injury and death data sources used by CPSC, compared CPSC's consumer education efforts with key practices, and interviewed federal officials and groups representing the health and consumer interests of minority populations.
Few studies have assessed racial and ethnic differences in child death rates from injuries related to consumer products, and CPSC has not analyzed whether specific racial or ethnic groups are disproportionately affected by product hazards because of data limitations. These limitations include incomplete and inconsistent race and ethnicity data on emergency room reports and the inconsistent presence of product-related information on death certificates. In 2007, race and ethnicity data were not coded in about 31 percent of cases in CPSC's National Electronic Injury Surveillance System (NEISS), which collects data from a nationally representative sample of hospital emergency rooms. In addition, the hospitals that do record race and ethnicity information in CPSC's NEISS system do so inconsistently, in part because of limited CPSC guidance. While death certificates may include more complete race and ethnicity information compared with nonfatal injury data from hospitals, related product information is not consistently documented on the certificates. Despite this lack of data, CPSC has developed or modified some consumer information efforts to reach specific minority populations, but it has not assessed the results of these efforts. CPSC provides information in Spanish for many of its outreach efforts, including its telephone hotline, Web site, television, radio, and print publications. CPSC has also identified and established relationships with other organizations to help disseminate consumer safety information to minority communities. And while CPSC has used some consumer input to develop safety information, it has not assessed outreach efforts for specific audiences. CPSC has also established goals for its overall consumer information efforts, but not for its messages targeted to specific populations. In addition, CPSC relies on its Neighborhood Safety Network, a group of organizations that have expressed interest in receiving product safety information, to share information with audiences that can be hard to reach, but the agency has not assessed whether these populations are receiving and using the information. Organizations we contacted for this report, including Neighborhood Safety Network members and children's safety groups, generally reported using safety information provided by CPSC, but some offered suggestions for improvement of efforts to reach minority communities, such as providing safety information in other languages and additional exposure through broadcast media.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-09-731, Consumer Product Safety Commission: Better Data Collection and Assessment of Consumer Information Efforts Could Help Protect Minority Children
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Report to Congressional Committees:
United States Government Accountability Office:
GAO:
August 2009:
Consumer Product Safety Commission:
Better Data Collection and Assessment of Consumer Information Efforts
Could Help Protect Minority Children:
GAO-09-731:
GAO Highlights:
Highlights of GAO-09-731, a report to congressional committees.
Why GAO Did This Study:
In 2004, the U.S. Consumer Product Safety Commission (CPSC) estimated
that 29,400 deaths in the United States were related to consumer
products. As required under Section 107 of the Consumer Product Safety
Improvement Act of 2008, this study reviews what is known about the
relative incidence of preventable injuries and deaths among minority
children associated with products intended for children's use and also
examines what actions CPSC has taken through its public information and
education initiatives to minimize these injuries and deaths. To address
these issues, we assessed injury and death data sources used by CPSC,
compared CPSC‘s consumer education efforts with key practices, and
interviewed federal officials and groups representing the health and
consumer interests of minority populations.
What GAO Found:
Few studies have assessed racial and ethnic differences in child death
rates from injuries related to consumer products, and CPSC has not
analyzed whether specific racial or ethnic groups are
disproportionately affected by product hazards because of data
limitations. These limitations include incomplete and inconsistent race
and ethnicity data on emergency room reports and the inconsistent
presence of product-related information on death certificates. In 2007,
race and ethnicity data were not coded in about 31 percent of cases in
CPSC‘s National Electronic Injury Surveillance System (NEISS), which
collects data from a nationally representative sample of hospital
emergency rooms. In addition, the hospitals that do record race and
ethnicity information in CPSC‘s NEISS system do so inconsistently, in
part because of limited CPSC guidance. While death certificates may
include more complete race and ethnicity information compared with
nonfatal injury data from hospitals, related product information is not
consistently documented on the certificates.
Despite this lack of data, CPSC has developed or modified some consumer
information efforts to reach specific minority populations, but it has
not assessed the results of these efforts. CPSC provides information in
Spanish for many of its outreach efforts, including its telephone
hotline, Web site, television, radio, and print publications. CPSC has
also identified and established relationships with other organizations
to help disseminate consumer safety information to minority
communities. And while CPSC has used some consumer input to develop
safety information, it has not assessed outreach efforts for specific
audiences. CPSC has also established goals for its overall consumer
information efforts, but not for its messages targeted to specific
populations. In addition, CPSC relies on its Neighborhood Safety
Network, a group of organizations that have expressed interest in
receiving product safety information, to share information with
audiences that can be hard to reach, but the agency has not assessed
whether these populations are receiving and using the information.
Organizations we contacted for this report, including Neighborhood
Safety Network members and children‘s safety groups, generally reported
using safety information provided by CPSC, but some offered suggestions
for improvement of efforts to reach minority communities, such as
providing safety information in other languages and additional exposure
through broadcast media.
What GAO Recommends:
GAO recommends that CPSC develop and implement cost-effective means of
improving data collection on factors that may contribute to any
differences in the incidence of consumer product-related injury and
death. GAO also recommends that CPSC develop and implement cost-
effective ways to enhance and assess the likelihood that safety
messages are received and implemented by all the intended audiences.
CPSC and the Department of Health and Human Services (HHS) agreed with
GAO‘s recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-09-731] or key
components. For more information, contact Cornelia M. Ashby at (202)
512-7215 or ashbyc@gao.gov.
[End of section]
Contents:
Letter:
Background:
Few Studies Assess Racial and Ethnic Differences in Children's Risk of
Death from Injuries Related to Consumer Products, and Data Limitations
Constrain CPSC Analysis:
CPSC Has Developed or Modified Some Consumer Information Efforts to
Reach Specific Minority Populations, but Has Not Assessed the Results
of These Efforts:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Key Practices for Consumer Education Planning:
Appendix III: Comments from the Department of Health and Human
Services:
Appendix IV: GAO Contact and Staff Acknowledgments:
Related GAO Products:
Table:
Table 1: Key Practices for Planning Consumer Education Campaigns:
Figures:
Figure 1: CPSC Consumer Information Methods:
Figure 2: Estimated Percentage of NEISS Cases Missing Race and
Ethnicity Information, 1999-2007:
Figure 3: Portion of NEISS Hospitals with Various Percentages of Cases
Not Coded for Race and Ethnicity, 2007:
Figure 4: Examples of CPSC Consumer Information:
Abbreviations:
CDC: Centers for Disease Control and Prevention:
CPSC: U.S. Consumer Product Safety Commission:
CPSIA: Consumer Product Safety Improvement Act:
HHS: Department of Health and Human Services:
IHS: Indian Health Service:
MCHB: Maternal and Child Health Bureau:
NEISS: National Electronic Injury Surveillance System:
NCHS: National Center for Health Statistics:
NSN: Neighborhood Safety Network:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
August 5, 2009:
Congressional Committees:
The U.S. Consumer Product Safety Commission (CPSC), an independent
federal agency charged with protecting the public from consumer
products that pose an unreasonable risk of injury and death, estimated
that 29,400 deaths in the United States related to consumer products
occurred in 2004.[Footnote 1] CPSC works to fulfill its broad mission
in part by conducting research into the causes and prevention of
product-related deaths, illnesses, and injury and assisting consumers
in evaluating the comparative safety of consumer products. CPSC has
identified certain populations as vulnerable or hard to reach with
safety information, including older Americans, urban and rural low-
income families, new parents, and minority groups. Consumer groups and
researchers have also suggested that minority children, particularly
those living in low-income communities, may face an increased risk of
death from injuries because of factors associated with living in
poverty, such as poor living conditions and less access to health care,
quality recreational activities, and safety devices. Similarly, reports
from the Centers for Disease Control and Prevention (CDC) have
documented racial disparities in injury-related death rates among
children.
The Consumer Product Safety Improvement Act of 2008 (CPSIA) established
consumer product safety standards and other safety requirements for
children's products. It also contained a provision requiring GAO to
study disparities in the risks and incidence of preventable injuries
and deaths among children of minority populations related to consumer
products intended for children's use.[Footnote 2] Specifically, GAO is
to look at preventable injuries and deaths related to suffocation,
poisoning, and drowning, including those associated with the use of
swimming pools and spas; toys; cribs, mattresses, and bedding
materials; and other products intended for children's use. Minority
populations specified in the mandate include Black, Hispanic, American
Indian, Alaska Native, Native Hawaiian, and Asian/Pacific Islander.
[Footnote 3] The mandate also required GAO to provide information about
ways to minimize risks of preventable injuries and deaths among
minority children, including through consumer education initiatives. To
address this mandate, we examined (1) what is known about the relative
incidence of preventable injuries and deaths related to drowning,
poisoning, and suffocation associated with products intended for
children's use among minority children compared with nonminority
children, and (2) what actions CPSC has taken through its public
information and education initiatives to minimize child injuries and
deaths, including those in minority populations, related to products
intended for children's use.
To answer these questions, we reviewed studies and reports by the
Institute of Medicine, federal agencies, researchers, and other
organizations that assessed racial or ethnic differences in injury and
death among children and related studies that discussed injury
prevention programs targeted to minority populations.[Footnote 4] We
reviewed injury and death data sources used by CPSC to estimate product-
related injuries and deaths. We interviewed federal officials at CPSC
and five Department of Health and Human Services (HHS) organizations to
learn about their related programs and initiatives. In addition, we
obtained information about injury data, racial and ethnic disparity
issues, and injury prevention campaigns from researchers,
representatives of injury prevention programs, consumer groups, and
groups representing the health and consumer interests of minority
populations. Finally, we reviewed CPSC documents and interviewed CPSC
officials regarding the development, operation, and evaluation of the
agency's consumer information efforts. We compared the processes used
by CPSC with key practices identified by experts in GAO's previous work
on consumer information and education.[Footnote 5] The key practices
include defining goals and objectives; analyzing the situation;
identifying stakeholders; identifying resources; researching target
audiences; developing consistent, clear messages; identifying credible
messengers; designing media mix; and establishing metrics to measure
success. Appendix I explains our scope and methodology in more detail.
We conducted this performance audit from December 2008 through August
2009 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Background:
CPSC was created in 1972 under the Consumer Product Safety Act to
regulate consumer products that pose an unreasonable risk of injury,
assist consumers in using products safely, develop uniform safety
standards for consumer products, minimize conflicting state and local
regulations, and promote research and investigation into product-
related deaths, injuries, and illnesses. CPSC oversees about 15,000
types of consumer products used in the home, in schools, and in sports
and recreation. In fiscal year 2008, CPSC carried out its mission with
a budget of about $80 million and 396 full-time employees. Prior to
2008, CPSC experienced significant budget cuts and a sharp decline in
its staffing level from a high of 978 employees in 1980. Congress
appropriated increased funding totaling about $105 million for fiscal
year 2009. This appropriation funds a staffing level of 483 full-time
employees, according to CPSC's 2010 budget request.
CPSC Efforts to Inform Consumers about Product Hazards:
CPSC uses different methods to inform the public about product recalls
and safety practices that can help prevent product-related injuries
(see figure 1). CPSC maintains a National Injury Information
Clearinghouse that disseminates information to the public related to
deaths and injuries associated with consumer products under the
agency's jurisdiction. CPSC also warns the public about product hazards
by announcing product recalls and providing other safety information
through print and electronic media, a telephone hotline, electronic
mail, and the Internet. For example, CPSC works with manufacturers to
provide public notice of product recalls, in which a defective item is
to be removed from store shelves and consumers are alerted to return
the item for repair, replacement, or refund, or otherwise dispose of
them. To further its reach, CPSC also provides safety information to
broadcast outlets, such as radio and television stations, and to print
media outlets. According to CPSC officials, CPSC has allocated
approximately $1 million annually to support its consumer information
efforts and has nine employees in the Office of Public Affairs, the
office responsible for developing and implementing CPSC's consumer
information efforts in consultation with CPSC's technical experts and
other CPSC staff. Congress appropriated funding in 2009 to help CPSC
administer the Virginia Graeme Baker Pool and Spa Safety Act, including
about $2.4 million for a state grant program and over $4 million for a
program to inform the public and pool owners of pool and spa hazards to
prevent children from drowning.
Figure 1: CPSC Consumer Information Methods:
[Refer to PDF for image: illustrated table]
CPSC Consumer Information Methods:
* Telephone hotline;
* Web site (Press releases, recall alerts, wireless cell phone access,
podcast recordings, video news releases,e-publications for download);
* E-mail notification service;
* Television (broadcast interviews, video news releases);
* Radio news releases;
* Print publications (CPSC posters/safety information, newspaper and
magazine articles).
Sources: CPSC and Art Explosion (photos).
[End of figure]
Recently passed legislation requires CPSC to improve its consumer
information activities. For example, the Consumer Product Safety
Improvement Act (CPSIA) requires CPSC to develop an online database
that is publicly available and searchable by date, product name, model,
and manufacturer. The database must contain reports of harm relating to
the use of consumer products. CPSIA also specifies the information that
must be included in a mandatory product recall notice, including
details about related injuries and deaths. The act also authorizes CPSC
to require manufacturers to give public notice in languages other than
English, although this provision applies only to mandatory recalls,
according to CPSC officials.[Footnote 6]
Related Department of Health and Human Services Efforts:
While CPSC is charged with protecting the public from unreasonable
risks of injury and death from the thousands of types of consumer
products under the agency's jurisdiction, HHS offices and agencies also
play a role in injury prevention by conducting injury prevention
research and information campaigns, collecting injury data, and
promoting the health of minority populations. For example, according to
agency officials and documents, CDC and the National Institutes of
Health support research on a variety of topics, including injury
prevention, and have conducted public information campaigns to reduce
childhood injury. CDC's National Center for Health Statistics (NCHS)
collects information about injuries, including race and ethnicity
characteristics, from death certificates in all 50 states and the
District of Columbia, as well as from household surveys and health care
provider surveys. The Maternal and Child Health Bureau (MCHB) and the
Indian Health Service (IHS) finance public health services, including
injury prevention programs. HHS offices and agencies also lead efforts
aimed at understanding and addressing racial and ethnic disparities in
health care, including rates of unintentional injury among minority
groups. For example, HHS's Office of Minority Health serves as a focal
point within HHS to coordinate efforts to improve racial/ethnic
minority health and eliminate racial/ethnic health disparities. The
Office of Minority Health is charged with providing leadership and
coordination for offices of minority health operating in other HHS
agencies and in states to reduce racial and ethnic health disparities,
according to agency officials. CDC is the lead agency charged with
measuring progress toward national HHS goals to eliminate disparities
in injuries, disabilities, and deaths due to unintentional injuries and
violence.
Injury and Death Data Sources Used by CPSC:
CPSC collects and analyzes data on consumer product-related injuries
and deaths for products under its jurisdiction to determine where
hazards exist and how to address them. CPSC obtains most of its
information on injuries from its National Electronic Injury
Surveillance System (NEISS), which gathers information from a
nationally representative sample of about 100 hospital emergency rooms.
NEISS provides national estimates of the number and severity of
emergency room-treated injuries associated with, although not
necessarily caused by, consumer products in the United States.
Characteristics coded in the NEISS system include the date of
treatment; the patient's age, gender, race and ethnicity, injury
diagnosis, body part affected, case disposition; incident location; as
well as the product involved. In 2000, NEISS was expanded to provide
data on all trauma-related injuries. The expanded data provide other
federal agencies, researchers, and the public with more comprehensive
information on injuries from all sources, not just consumer products.
CPSC receives approximately $2 million each year from CDC to support
this effort.
CPSC obtains most of its information on fatal injuries from death
certificates. Information recorded on death certificates includes the
date and place of death, cause of death, age, gender, race and
ethnicity, and residence of the deceased. CPSC estimates the number of
consumer product-related deaths from data collected by NCHS about all
deaths through the National Vital Statistics System. Because of the
complexity and volume of collecting information about all deaths, there
is over a 2 year lag before NCHS mortality data become available.
According to a CPSC official, to obtain more timely information, CPSC
annually purchases about 8,000 death certificates directly from states
for selected causes of death that the agency has determined are likely
to be product-related, such as bicycle accidents or falls involving
playground equipment.
CPSC supplements information from the NEISS system and death
certificates with reports from individual consumers and with data from
private organizations such as fire prevention groups and poison control
centers. CPSC collects approximately 4,600 additional reports from
participating medical examiners and coroners throughout the country,
about 7,400 news clips, and 14,300 other reports of product-related
injuries and deaths from consumers, lawyers, physicians, fire
departments, and other sources, according to its 2010 performance
budget request.
Few Studies Assess Racial and Ethnic Differences in Children's Risk of
Death from Injuries Related to Consumer Products, and Data Limitations
Constrain CPSC Analysis:
Few Studies Assess Racial and Ethnic Differences in Child Death Rates
from Injuries Related to Consumer Products:
Although some research suggests racial disparities in child death rates
resulting from general causes of injury--including drowning, poisoning,
and suffocation--we identified few studies that assessed racial and
ethnic differences in child death rates from injuries related to
consumer products. The studies we identified included two that
identified racial and ethnic disparities in drownings in swimming pools
and a study that identified a disparity between black and white infants
in the risk of suffocation or strangulation in bed. We did not identify
any studies that compared the incidence of poisoning related to
consumer products by children's race and ethnicity. While these studies
identified racial and ethnic differences in death rates related to
specific products, the researchers were not consistently able to
consider all factors that may contribute to these differences, such as
differences in exposure to the consumer products.
Drowning:
Mortality data reported by CDC suggest racial disparities in drowning
rates, although these data do not specify whether the deaths involved
consumer products. Drownings can occur in a variety of settings, such
as natural water settings, swimming pools, bathtubs, and buckets.
According to CDC, between 2000 and 2005, the fatal unintentional
drowning rate of black children ages 5 to 14 was 3.2 times that of
white children in the same age range. For American Indian and Alaska
Native children, the fatal drowning rate was 2.4 times higher than for
white children.
One study, conducted by researchers from HHS's National Institutes of
Health, CPSC, and a research institute, found racial and ethnic
disparities in swimming pool drowning rates.[Footnote 7] This study
examined circumstances surrounding 678 swimming pool drownings among
U.S. residents aged 5 to 24 years that occurred between 1995 and 1998.
The study used data collected by CPSC about drowning deaths from death
certificates, medical examiner reports, and newspaper clippings.
[Footnote 8] The study found that black non-Hispanic males and females
had higher swimming pool drowning rates compared with white non-
Hispanic males and females of comparable age. Drowning rates were
highest among black males, often occurring during the day at public
pools, and this increased risk persisted after controlling for
differences in neighborhood income. Hispanic males also had higher
rates of pool drowning compared with white non-Hispanic males, but they
had lower rates compared with black non-Hispanic males of comparable
age. The drowning rates among Hispanic females were similar to those of
white non-Hispanic females. The drowning rates among foreign-born
victims were higher than among American-born victims. The study
concluded that targeted interventions are needed to reduce the
incidence of swimming pool drownings across racial and ethnic groups;
it particularly recommended adult supervision at public pools and
swimming instruction to increase children's swimming ability.
Another study examining racial disparities in drowning rates in
specific locations found that after the age of 5 years, the risk of
drowning in a swimming pool was greater among black males compared with
white males.[Footnote 9] Specifically, this study analyzed death
certificate data collected by CPSC and NCHS about U.S. drowning deaths
of children aged up to 19 in 1995. This research found that among black
males aged 5 to 19 years, about 37 percent of drowning deaths with
known location of drowning were in swimming pools, while only 10
percent of similar drownings among white males occurred in pools.
Suffocation:
One study conducted by CDC researchers found that black infants were
disproportionately affected by accidental suffocation and strangulation
in bed (27.3 versus 8.5 deaths per 100,000 live births for blacks and
whites, respectively).[Footnote 10] This study analyzed infant deaths
occurring between 1984 and 2004 using CDC's National Center for Health
Statistics mortality files containing information from all death
certificates. Researchers only analyzed differences between black and
white infants in this study because of concerns about misreporting of
racial and ethnic identity on death certificates for other racial and
ethnic groups.[Footnote 11] Although not reported by racial group,
beds, cribs, and couches were reported overall as the most common sleep
surfaces where accidental suffocation and strangulation deaths
occurred.[Footnote 12] In addition, co-sleeping or bed sharing was
reported in over half of the cases. The study concluded that efforts
should target those at highest risk and focus on helping parents and
caregivers provide safer sleep environments.
Poisoning:
We did not identify any studies that compared the incidence of
poisoning related to consumer products by children's race and
ethnicity. CPSC has assessed differences in the incidence of product-
related poisonings among children by age group and gender. A recent
study conducted by CPSC staff found that 70 percent of an estimated
86,194 child poisoning incidents involving children less than 5 years
of age treated in hospital emergency rooms that occurred in 2004
involved children 1 to 2 years of age; slightly more than one-half
involved boys; and about 60 percent involved oral prescription drugs,
nonprescription drugs, and supplements.[Footnote 13] The study
concluded that while fatal child poisonings involving drugs and other
hazardous household substances have decreased in recent years, nonfatal
child poisonings treated in hospital emergency rooms have remained at
high levels.
Poisoning can also occur when children swallow or put in their mouths
products that contain excessive levels of lead paint or lead content,
such as toys or children's costume jewelry; however, CPSC receives
little information about such incidents through its data systems.
[Footnote 14] According to CPSC officials, the agency rarely receives
reports of child lead poisoning through its data systems because lead
poisoning usually appears as a chronic illness rather than an acute
injury, and as we have previously reported, CPSC's data systems are not
set up to capture information about chronic illnesses.[Footnote 15]
CPSC Has Not Analyzed Racial and Ethnic Differences in Product-Related
Injury and Death because of Data Limitations:
CPSC estimates product-related injury and death rates by age group, but
because neither emergency room nor death certificate data provide
complete information about both race and ethnicity and related
products, CPSC has not analyzed product-related injury and death rates
by race and ethnicity or other characteristics that could identify
particularly vulnerable populations.[Footnote 16] While other federally
supported data collection efforts provide more, or more reliable,
information on the range of factors, including race and ethnicity, that
may contribute to injury risk, these efforts have not collected data on
consumer product involvement or CPSC has not been involved with them.
NEISS System:
While products related to patients' injuries are coded in the NEISS
system, limited patient race and ethnicity information has hindered
analysis of racial and ethnic differences in product-related injuries.
CPSC's NEISS system specifies the products involved in injuries treated
in hospital emergency rooms. NEISS coders can choose from approximately
900 product codes when identifying any products mentioned in hospital
emergency room records, such as toys, cribs, and swimming pools.
Consumer products are coded to allow for specificity. For example, a
baby bathtub seat would be specified differently from a baby bath. In
its 2008 performance report, CPSC reported conducting annual monitoring
visits to all of the NEISS hospitals in its sample, concluding that
data were collected on over 90 percent of product-related cases in
emergency room records through the NEISS system.
As shown in figure 2, our analysis of CPSC's NEISS data found that race
and ethnicity data were not coded in about 31 percent of cases in 2007.
The percentage of NEISS cases missing race and ethnicity information
has prevented CPSC and CDC from assessing racial and ethnic differences
in nonfatal injury rates, according to agency officials. According to a
CPSC official, the agency has been aware of the missing race and
ethnicity data and considered ways of statistically estimating race and
ethnicity information using existing data, but has not pursued such
analysis because of competing agency priorities.[Footnote 17]
Figure 2: Estimated Percentage of NEISS Cases Missing Race and
Ethnicity Information, 1999-2007:
[Refer to PDF for image: vertical bar graph]
Year: 1999;
Cases Missing Race and Ethnicity Information: 36%.
Year: 2000;
Cases Missing Race and Ethnicity Information: 21%.
Year: 2001;
Cases Missing Race and Ethnicity Information: 24%.
Year: 2002;
Cases Missing Race and Ethnicity Information: 24%.
Year: 2003;
Cases Missing Race and Ethnicity Information: 24%.
Year: 2004;
Cases Missing Race and Ethnicity Information: 23%.
Year: 2005;
Cases Missing Race and Ethnicity Information: 26%.
Year: 2006;
Cases Missing Race and Ethnicity Information: 29%.
Year: 2007;
Cases Missing Race and Ethnicity Information: 31%.
Source: GAO analysis of CPSC‘s NEISS data.
Note: Ninety-five percent confidence intervals are all less than or
equal to plus or minus 0.2 percent.
[End of figure]
Our analysis of CPSC's NEISS data found that some hospitals have a high
percentage of cases missing race and ethnicity information. As shown in
figure 3, about one-quarter of NEISS hospitals had more than 75 percent
of cases missing race and ethnicity information in 2007.
Figure 3: Portion of NEISS Hospitals with Various Percentages of Cases
Not Coded for Race and Ethnicity, 2007:
[Refer to PDF for image: pie-chart]
0 to 10 percent missing: 62%;
10 to 75 percent missing: 14%;
75 to 100 percent missing: 24%.
Source: GAO analysis of CPSC‘s NEISS data.
[End of figure]
In addition, NEISS hospitals that have recorded race and ethnicity
information do so inconsistently, in part because of limited CPSC
guidance. For example, a NEISS coder in one NEISS hospital we visited
reported that the hospital registrar would generally record the
patient's race and ethnicity using visual observation and rarely verify
this information with the patient. Staff at other NEISS hospitals
reported that the admitting staff may ask for race or ethnicity data
along with other information when the patient is checking into the
emergency room. In its manual, CPSC does not specify how hospital staff
should obtain the information about patient race and ethnicity,
although some researchers suggest that information reported by patients
or patient representatives is more accurate than visual observation by
hospital staff. In addition, CPSC's coding system for race and
ethnicity is limited to white, black, and a narrative field for "other"
categories, resulting in inconsistent coding and making data on other
categories challenging to analyze. Our review of NEISS data found that
NEISS hospitals use different terminology to code the same racial or
ethnic categories in the "other" category.
According to a few organizations we interviewed, hospital-based
collection of data on the race and ethnicity of patients is a challenge
for several reasons. A hospital staff member from one NEISS hospital we
visited said that these data are missing because hospital staff are
uncomfortable asking patients about race and ethnicity. CDC officials
and a researcher we interviewed said that hospital staff may not be
trained to collect race and ethnicity information or may not understand
that it is being used for purposes other than providing medical care.
Other studies have found incomplete and inconsistent collection of
information about patient race and ethnicity from hospitals. A panel
convened by the National Academy of Sciences conducted a survey of
hospitals and found that many hospitals report collecting race and
ethnicity information, but these data are not reported to state and
federal programs in a standardized format, and the information reported
for racial and ethnic groups other than white and black may be
unreliable.[Footnote 18] The panel recommended that HHS require health
insurers, hospitals, and private medical groups to collect data on
race, ethnicity, socioeconomic position, and acculturation and language
and provide leadership in developing standards for collecting these
data. Another qualitative study, funded by the California Endowment,
reviewed hospital efforts to provide culturally and linguistically
appropriate health care in 60 hospitals nationwide.[Footnote 19] The
majority of hospitals reviewed in this study had inconsistent methods
for collecting data on patient race, ethnicity, and primary language.
In some hospitals, systems were in place but not used; in others, staff
appeared not to have been trained on methods to accurately collect data
from patients.
Death Certificates:
Death certificates may include more complete and accurate race and
ethnicity information compared with nonfatal injury data from
hospitals, according to CDC officials, but concerns remain about the
accuracy of this information for some groups. The accuracy of race and
ethnicity information recorded on death certificates has been studied
over time. A recent evaluation conducted by CDC found that race and
ethnicity reporting on death certificates has been excellent for white
and black populations, poor for the American Indian or Alaska Native
populations, and reasonably good for the Hispanic and Asian or Pacific
Islander populations.[Footnote 20] According to CDC, studies have shown
that individuals who self-reported as American Indian, Asian, or
Hispanic on census and survey records were sometimes reported as white
or non-Hispanic on the death certificate, resulting in an
underestimation of deaths and death rates for the American Indian,
Asian, and Hispanic groups.
While death certificates may contain more complete and accurate race
and ethnicity data than the NEISS system, according to CPSC and CDC
officials, related product information is not consistently documented
on the certificates. Unlike coders who enter data into CPSC's NEISS
system, individuals who complete death certificates are not prompted or
required to record information identifying specific consumer products
related to the death. Information about product involvement may be
found in the narrative recorded on the certificate; however, this
information is not consistently recorded, according to both CPSC and
CDC officials. CPSC has developed national estimates of consumer
product-related death rates by age group using HHS data containing
information about all deaths; but CPSC has not analyzed these deaths by
race and ethnicity, according to CPSC officials. A CPSC official told
us that CPSC staff could analyze consumer product-related deaths by
race and ethnicity, although the agency has not done so to date. CDC
officials said that given the limited information about product
involvement found on death certificates, estimating product-related
death rates by race and ethnicity could produce underestimates.
Some states are collecting information about product-related deaths as
part of investigations to understand the causes of child deaths;
however, CPSC has not been involved in this effort. HHS's Maternal and
Child Health Bureau funds a Web-based system and technical assistance
center to support state collection of data from child death reviews,
including race and ethnicity, type of injury, and details on product
involvement. Child death reviews involve state and local officials from
multiple disciplines sharing information to better understand child
deaths and prevent future deaths. Since 2002, HHS's Maternal and Child
Health Bureau has funded the National Maternal Child Health Center for
Child Death Review, a technical assistance center that developed the
Child Death Review Case Reporting System. As of February 2009, 28
states have used the system, and states vary in the types of deaths
reviewed, the timing of entry into the system, and the amount of detail
entered into the system, according to officials. The system prompts the
user to record whether the death was a consequence of a problem with a
consumer product and, if so, collects information about the product and
whether the incident was reported to CPSC. However, according to
officials, CPSC has not been involved in the development and
implementation of this system. CPSC does not currently receive updates
from HHS or the states directly through the Child Death Review Case
Reporting System.
According to CDC, injury data collected from household interviews
through its National Health Interview Survey may include more accurate
data on race and ethnicity compared with medical records-based data
collection efforts because the information is self-reported or reported
by a knowledgeable representative. The National Health Interview Survey
also contains information about other factors that could account for
health conditions, such as socioeconomic status, but lacks consistently
reported information about product involvement, according to CDC
officials. A CPSC official said the agency has not pursued working with
CDC to augment its data collection efforts by modifying this survey,
citing doubts that the data collected could include sufficient detail
about product involvement even if the survey were modified.
CPSC Has Developed or Modified Some Consumer Information Efforts to
Reach Specific Minority Populations, but Has Not Assessed the Results
of These Efforts:
CPSC has incorporated some elements of key consumer education practices
to provide consumer product safety information to minority populations,
such as periodically using consumer and other stakeholder input to
inform its outreach efforts, but it has not specifically defined goals
or developed measures to assess whether these efforts are effectively
reaching minority populations (see appendix II for further detail on
the key practices).
CPSC Has Tailored Some Outreach for Hispanic Communities and
Established Relationships to Assist in Reaching Other Minority
Populations:
CPSC's consumer information efforts are intended to provide notice of
product recalls and guidance on safely using products to the general
public, although some of its safety information regarding children's
products has also been targeted to minority populations, particularly
the Hispanic community. CPSC provides information in Spanish for many
of its outreach efforts, and according to CPSC officials, has hired a
Hispanic media consumer outreach specialist to assist with translations
and to work with the Hispanic media, and has established practices to
develop and disseminate safety information to this community. CPSC
officials also told us that they provide information to Spanish-
language television and radio stations, use Spanish-speaking telephone
operators for CPSC's toll-free hotline, and maintain a language bank to
provide assistance for calls in other languages.[Footnote 21] During
fiscal year 2008, CPSC records indicate that CPSC hotline staff
answered 1,570 calls in Spanish. The main CPSC Web site also includes a
section called El Mundo Hispano de la CPSC with recall notices and
other product safety information in Spanish. See figure 4 for examples
of CPSC consumer information in Spanish and English.
Figure 28: Examples of CPSC Consumer Information:
[Refer to PDF for image: 4 illustrations]
The four examples are:
NSN poster on safe sleep (in English);
NSN poster on safe sleep (in Spanish);
NSN poster on drowning prevention (in English);
NSN poster on drowning prevention (in Spanish).
Source: CPSC Web site.
CPSC has also identified and established relationships with other
organizations to help disseminate consumer safety information to
additional minority communities through electronic, broadcast, and
print media. For example, CPSC officials noted that in 2000, CPSC
worked with the Bureau of Primary Health Care, Gerber, and Black
Entertainment Television (BET) to launch a safe sleep campaign to help
lower sudden infant death syndrome (SIDS) rates, especially among
African-Americans. The campaign included a nationwide television public
service announcement about placing babies to sleep on their backs to
prevent SIDS, and special programming to be televised on BET. CPSC has
also worked on media outreach campaigns with other organizations such
as public health agencies, industry groups, and child safety
organizations. In 2004, CPSC launched the Neighborhood Safety Network
(NSN), to enlist support from community-based organizations in
extending its messages to communities it designated as hard to reach,
including older Americans, urban and rural low-income families, new
parents, and minority groups. According to CPSC officials, CPSC uses
NSN, now numbering about 5,600 member organizations, to deliver
information to minority populations. Membership in NSN is free and
enrollment is voluntary. Some of the member organizations include HHS,
hospitals and health clinics, day care centers, fire stations, parent
organizations, and American Indian reservations. CPSC has developed a
Web page offering online safety materials that NSN members can modify
for use with specific groups. NSN member organizations receive CPSC's e-
mail updates with product safety information on topics such as drowning
prevention, crib and toy safety, and poison prevention and may elect to
employ these in their own outreach efforts.
Organizations we contacted for this report, including NSN members,
consumer groups, and organizations that conduct injury prevention
research or implement injury prevention programs in diverse communities
generally reported using safety information provided by CPSC, and some
offered suggestions for improving efforts to reach minority
communities. Some of the organizations said that they receive
information from CPSC via e-mail notifications, and some mentioned
distributing flyers or posters provided by CPSC and incorporating
information from CPSC into their own pamphlets and brochures. Some
suggestions to improve consumer information efforts for minority
populations included additional exposure through broadcast media
because access to electronic information via computers may be limited.
Some NSN members also said it would be useful if safety information
were provided in additional languages. According to CPSC officials, the
agency does not have the resources to translate information into
additional languages, but one NSN member we interviewed mentioned that
their organization had translated some CPSC materials for its
audiences. Some organizations also expressed interest in collaborating
more closely with CPSC on its consumer information efforts.
CPSC Has Used Some Consumer Input to Develop Safety Information, but
Has Not Assessed Outreach Efforts to Specific Audiences:
CPSC has periodically conducted audience research to strengthen its
consumer information efforts. In 2003, the agency funded a literature
review to examine the factors influencing consumers' understanding of
and responses to recall notices and other safety information. The study
findings suggested ways product recall communications could be improved
to help consumers eliminate or reduce product hazards, such as using
pictures and signal language like "warning" or "danger" to help
consumers attend to and understand safety messages. CPSC also created
an online Consumer Opinion Forum that consumers can join to provide
feedback on product safety issues, such as how a recall notice could be
written more clearly; however, consumers must have Internet access to
participate in this forum. In addition, CPSC recognizes that to
understand the culture and diversity within the Hispanic community, it
must take certain steps such as interviewing members of the community,
reviewing related research, and consulting with colleagues from other
federal agencies. For example, to translate and adapt materials for one
of its outreach campaigns for different segments of the Spanish-
speaking audience, CPSC conducted interviews with members of the
Hispanic community from varying educational backgrounds. Although CPSC
has periodically conducted audience research, agency officials told us
they do not have the resources to regularly pretest safety messages.
However, officials from a few organizations we interviewed noted that
CPSC could conduct focus groups with members of the target audience or
include representatives of organizations that work with the target
audience on an advisory committee to help design and implement safety
campaigns.
CPSC has also established goals for its overall consumer information
efforts, but not for its messages targeted to specific populations. In
its 2008 performance and accountability report, CPSC stated that its
goal for using consumer information was to alert the public to
children's and other hazards through consumer outreach, press releases,
and conducting nine public information efforts that included topics
such as drowning and poisoning prevention. CPSC sets annual performance
goals that measure the success for each of these consumer information
methods according to the total number of items issued, viewed, or
conducted during that fiscal year. For example, CPSC set a fiscal year
2008 goal to receive 450 million views of its safety messages through
television appearances, video news releases, and downloads of e-
publications.
CPSC relies on the Neighborhood Safety Network to share product safety
information with audiences that can be hard to reach, but the agency
has not formally assessed whether these populations are receiving and
using the information. And while CPSC tracks the number of views its
safety messages receive, CPSC officials stated that they do not collect
information on audience demographics, which could indicate the target
audiences being reached. Likewise, CPSC has conducted surveys to assess
customer satisfaction with its toll-free hotline, Web site, and
partnerships with state government agencies, and these surveys indicate
a high level of satisfaction with CPSC services; however, these surveys
do not collect information about the demographic characteristics of the
consumers using CPSC's services to determine the extent to which they
are representative of the general population. According to CPSC
officials, CPSC has also not identified outcome measures to evaluate
how well its campaigns affected the attitudes and behaviors of the
target audiences it set out to influence. We previously identified
strategies used by other federal agencies to evaluate the effectiveness
of information campaigns, including analyzing findings from previous
research, collaborating with program partners to help meet the
information needs of diverse audiences and expand the usefulness of
evaluations, and surveying the intended audience to ask about program
exposure, knowledge, and attitude change.[Footnote 22] CPSC officials
have also cited a lack of resources as a challenge to establishing
evaluation programs to measure results; however, CPSC has recently
received more resources from the fiscal year 2009 appropriation for the
Virginia Graeme Baker Pool and Spa Safety Act. In the course of our
review, CPSC officials stated that with this new funding for the act,
they planned to include an evaluation component, but as of the writing
of this report, it was not yet known how CPSC planned to implement this
component.
Conclusions:
Protecting children from dangerous consumer products is a critical part
of CPSC's mission. Some research suggests that there are racial and
ethnic disparities in child death rates due to injuries related to
particular consumer products; however, CPSC does not routinely assess
whether such disparities exist, primarily because data limitations make
it challenging to conduct such analyses. In addition, the lack of
information about other characteristics of individuals who are injured
or die from involvement with a consumer product, such as socioeconomic
status, prevents CPSC from identifying potential underlying causes of
racial and ethnic differences in injury and death rates. Without
efforts to augment or improve existing data, CPSC may not know which
groups are most vulnerable to product-related injury or death. If
available data are improved, CPSC may be better able to identify
hazards that disproportionately affect certain communities and develop
ways to reduce those hazards.
Despite limited information on racial and ethnic differences in product-
related injury and death, CPSC has made some special efforts to deliver
some of its consumer information to audiences the agency identified as
hard to reach, including minority groups. However, CPSC has not
collected information on whether these targeted groups are receiving
and acting on the safety information. Without fully assessing its
consumer education and public outreach campaigns, CPSC cannot know how
effective these initiatives are at reaching intended audiences, some of
which may be at an elevated risk of injury or death.
Recommendations for Executive Action:
To better understand the relative risk of product-related injury among
minority and nonminority children, we recommend that the Commission, in
consultation with HHS,
* Develop and implement cost-effective means of improving CPSC's data
collection on factors that may contribute to differences in the
incidence of injury and death related to specific types of consumer
products, including race, ethnicity, and other patient characteristics.
For example, steps CPSC could consider include improving the NEISS
racial and ethnic classification system; working with NEISS hospitals
to improve collection of data on patient race and ethnicity; and
leveraging related data collection efforts, such as those sponsored by
the Maternal and Child Health Bureau, the National Center for Health
Statistics, or the National Institutes of Health.
To improve the effectiveness of consumer information efforts, we
recommend that the Commission,
* Develop and implement cost-effective ways to enhance and assess the
likelihood that CPSC's safety messages are received and implemented by
all the intended audiences. For example, CPSC could consider convening
groups of consumers or Neighborhood Safety Network members to advise on
the design and implementation of campaigns targeted to specific
communities, surveying NSN members, establishing metrics to measure
NSN's success, and evaluating the effectiveness of information
campaigns targeted to the racial and ethnic groups at highest risk of
drowning as part of its implementation of the Virginia Graeme Baker
Pool and Spa Safety Act.
Agency Comments and Our Evaluation:
We provided a draft of this report to CPSC and HHS for review and
comment. CPSC and HHS concurred with our recommendations and provided
technical comments, which we incorporated as appropriate. A letter
conveying HHS's comments is reproduced in appendix III.
We are sending copies of this report to the appropriate congressional
committees, the Chairman of the U.S. Consumer Product Safety
Commission, the Secretary of Health and Human Services, and other
interested parties. In addition, the report will be available at no
charge on GAO's Web site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions regarding this report, please
contact me at (202) 512-7215 or ashbyc@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributors to
this report are listed in appendix IV.
Signed by:
Cornelia M. Ashby:
Director, Education, Workforce, and Income Security Issues:
List of Committees:
The Honorable John D. Rockefeller, IV:
Chairman:
The Honorable Kay Bailey Hutchison:
Ranking Member:
Committee on Commerce, Science and Transportation:
United States Senate:
The Honorable Henry A. Waxman:
Chairman:
The Honorable Joe Barton:
Ranking Member:
Committee on Energy and Commerce:
House of Representatives:
The Honorable Mark Pryor:
Chairman:
The Honorable Roger Wicker:
Ranking Member:
Subcommittee on Consumer Protection, Product Safety, and Insurance:
Committee on Commerce, Science and Transportation:
United States Senate:
The Honorable Bobby L. Rush:
Chairman:
The Honorable George Radanovich:
Ranking Member:
Subcommittee on Commerce, Trade and Consumer Protection:
Committee on Energy and Commerce:
House of Representatives:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
The objectives of this report were to examine (1) what is known about
the relative incidence of preventable injuries and deaths related to
drowning, poisoning, and suffocation associated with products intended
for children's use among minority children compared with nonminority
children, and (2) what actions the Consumer Product Safety Commission
(CPSC) has taken through its public information and education
initiatives to minimize child injuries and deaths, including those in
minority populations, related to products intended for children's use.
To address the first objective, we reviewed injury and death data
sources used by CPSC to estimate product-related injuries and deaths.
We reviewed data and documentation obtained from CPSC concerning its
databases that contain injury and death data, including the Death
Certificates database, National Electronic Injury Surveillance System
(NEISS), Injury or Potential Injury Incidents file, and In-Depth
Investigations file.[Footnote 23] We reviewed information describing
Department of Health and Human Services (HHS) mortality data, which
includes information from death certificates filed in the United States
collected through the National Vital Statistics System. We also
reviewed HHS household and health care provider surveys that include
injury data, such as the National Health Interview Survey and the
National Hospital Discharge Survey. We also interviewed CPSC officials,
HHS officials, and researchers to gather information about the
strengths and weaknesses of available data sources.
We assessed the completeness and reliability of the NEISS data set by
(1) reviewing NEISS's technical documentation and methodological
reports, (2) interviewing CPSC officials, (3) examining these data for
obvious inconsistencies, and (4) visiting three NEISS hospitals to
better understand how the data are coded. We determined that these data
were sufficiently reliable to use as sources of summary statistics
about the extent of missing race and ethnicity information in the NEISS
system. To determine the extent of missing race and ethnicity
information in CPSC's NEISS system, we analyzed NEISS data obtained
from CPSC for the years 1999-2007.
To explore available data published in related studies, we searched
relevant databases, including PubMed, ProQuest, PsycFirst, and
ScienceDirect. We also consulted with CPSC and HHS staff to identify
related studies. We limited the scope of our work by looking at studies
published since 1999. Through this process, our literature search
identified about 70 studies, but only 3 studies published data on
racial and/or ethnic differences in child injury or death rates related
to specific consumer products, and we conducted detailed reviews of
these studies. Our reviews entailed an assessment of each study's
research methodology, including its data quality, research design, and
analytic techniques, as well as a summary of each study's major
findings and conclusions. We also assessed the extent to which each
study's data and methods supported its findings and conclusions.
To address the second objective, we reviewed CPSC documents and
interviewed CPSC officials regarding the development, operation, and
evaluation of the agency's consumer information efforts. Specifically,
we reviewed CPSC's Web site, and documents such as CPSC customer
satisfaction surveys, press releases, strategic plans, and performance
and accountability reports. We compared the processes used by CPSC with
key practices identified by experts in GAO's previous work as important
to planning a consumer education campaign, motivating a target
audience, and alleviating challenges in a campaign (see appendix II for
a description of these practices). We interviewed federal officials at
CPSC and five HHS organizations--Centers for Disease Control and
Prevention, Indian Health Service, Maternal and Child Health Bureau,
National Institutes of Health, and the Office of Minority Health--to
learn about their related programs and initiatives. In addition, we
interviewed representatives of injury prevention programs, consumer
groups, and members of CPSC's Neighborhood Safety Network to obtain
their views on CPSC's efforts to provide product safety information to
minority communities.
We conducted this performance audit from December 2008 through August
2009 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Key Practices for Consumer Education Planning:
In a 2007 GAO report on consumer issues pertaining to the digital
television transition, a panel of 14 senior management-level experts in
strategic communications identified and came to consensus on key
planning components for consumer education and outreach (see table 1).
Table 1: Key Practices for Planning Consumer Education Campaigns:
Key practice: Define goals and objectives;
Description: Define the goals of the communications campaign, e.g., to
increase awareness or motivate a change in behavior. Define the
objectives that will help the campaign meet those goals.
Key practice: Analyze the situation;
Description: Analyze the situation, including any competing voices or
messages, related market conditions, and key dates or timing
constraints. Review relevant past experiences and examples to identify
applicable "lessons learned" that may help to guide efforts.
Key practice: Identify stakeholders;
Description: Identify and engage all the key stakeholders who will be
involved in communications efforts. Clarify the roles and
responsibilities of each stakeholder, including which entity or
entities will lead overall efforts.
Key practice: Identify resources;
Description: Identify available short-and long-term budgetary and other
resources.
Key practice: Research target audiences;
Description: Conduct audience research, such as dividing the audience
into smaller groups of people who have relevant needs, preferences and
characteristics, as well as measuring awareness, beliefs, competing
behaviors, and motivators. Also, identify any potential audience-
specific obstacles, such as access to information.
Key practice: Develop consistent, clear messages;
Description: Determine what messages to develop based on budget, goals,
and audience research findings. Develop clear and consistent audience
messages; test and refine them.
Key practice: Identify credible messengers;
Description: Identify who will be delivering the messages and ensure
that the source is credible with audiences.
Key practice: Design media mix;
Description: Plan the media mix to optimize different types of media
such as news stories, opinion editorials, and broadcast, print, and
Internet advertising. Identify through which methods (e.g., advertising
in newsprint ads), how often (e.g., weekly or monthly) and over what
duration (e.g., 1 year) messages will reach audiences.
Key practice: Establish metrics to measure success;
Description: Establish both process and outcome metrics to measure
success in achieving objectives of the outreach campaign. Process
metrics ensure the quality, quantity, and timeliness of the
contractor's work. Outcome metrics evaluate how well the campaign
influenced the attitudes and behaviors of the target audience(s) that
it set out to influence.
Source: GAO-08-43.
[End of table]
[End of section]
Appendix III: Comments from the Department of Health and Human
Services:
Department Of Health& Human Services:
Office Of The Secretary:
Assistant Secretary for Legislation:
Washington, DC 20201:
July 14, 2009:
Cornelia M. Ashby:
Director, Education, Workforce and Income Security:
U.S. Government Accountability Office:
441 G Street N.W.
Washington, DC 20548:
Dear Ms. Ashby:
Enclosed are comments on the U.S. Government Accountability Office's
(GAO) report entitled: "Consumer Product Safety Commission: Better Data
Collection and Assessment of Consumer Information Efforts Could Help
Protect Minority Children" (GAO-09-731).
The Department appreciates the opportunity to review this report before
its publication.
Sincerely,
Signed by:
Barbara Pisaro Clark:
Acting Assistant Secretary for Legislation:
Attachment:
[End of letter]
General Comments Of The Department Of Health And Human Services (HHS)
On The Government Accountability Office's (GAO) Draft Report Entitled:
Better Data Collection And Assessment Of Consumer Information Efforts
Could Help Protect Minority Children (GAO-09-731):
The Centers for Disease Control and Prevention (CDC) wishes to thank
the GAO for the opportunity to review and comment on this Draft Report.
CDC concurs with the GAO's recommendations and respectfully submits the
following general comments.
The National Center for Health Statistics (NCHS) has a history of
working with the Consumer Product Safety Commission (CPSC) to provide
death certificate information to assist the CPSC in its mission.
Mortality data from NCHS are a fundamental source of demographic,
geographic, and cause of death information including the
characteristics of individuals dying in the United States. The death
certificate is not intended, however, to provide detailed information
about consumer products that may contribute to death. NCHS will
continue to assist the CPSC in using death certificate data to monitor
the safety of consumer products.
[End of section]
Appendix IV: GAO Contact and Staff Acknowledgments:
GAO Contact:
Cornelia M. Ashby, (202) 512-7215, ashbyc@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, individuals making key
contributions to this report include Betty Ward-Zukerman (Assistant
Director), Carl Barden, Mitch Karpman, Kristy Kennedy, Jim Rebbe, Cathy
Roark, Jay Smale, Gabriele Tonsil, and Kate van Gelder.
[End of section]
Related GAO Products:
Feasibility of Requiring Financial Assurances for the Recall or
Destruction of Unsafe Consumer Products. [hyperlink,
http://www.gao.gov/products/GAO-09-512R]. Washington, D.C.: April 22,
2009.
Traffic Safety: Improved Reporting and Performance Measures Would
Enhance Evaluation of High-Visibility Campaigns. [hyperlink,
http://www.gao.gov/products/GAO-08-477]. Washington, D.C.: April 25,
2008.
Digital Television Transition: Increased Federal Planning and Risk
Management Could Further Facilitate the DTV Transition. [hyperlink,
http://www.gao.gov/products/GAO-08-43]. Washington, D.C.: November 19,
2007.
Health Care: Approaches to Address Racial and Ethnic Disparities.
[hyperlink, http://www.gao.gov/products/GAO-03-862R]. Washington, D.C.:
July 8, 2003.
Program Evaluation: Strategies for Assessing How Information
Dissemination Contributes to Agency Goals. [hyperlink,
http://www.gao.gov/products/GAO-02-923]. Washington, D.C.: September
30, 2002.
Internet: Federal Web-based Complaint Handling. [hyperlink,
http://www.gao.gov/products/GAO/AIMD-00-238R]. Washington, D.C.: July
7, 2000.
Consumer Product Safety Commission: Injury Data Insufficient to Assess
the Effect of the Changes to the Children's Sleepwear Safety Standard.
[hyperlink, http://www.gao.gov/products/GAO/HEHS-99-64]. Washington,
D.C.: April 1, 1999.
Lead Poisoning: Federal Health Care Programs Are Not Effectively
Reaching At-Risk Children. GAO/HEHS-99-18. Washington, D.C.: January
15, 1999.
Children's Health: Elevated Blood Lead Levels in Medicaid and Hispanic
Children. [hyperlink, http://www.gao.gov/products/GAO/HEHS-98-169R].
Washington, D.C.: May 18, 1998.
Consumer Product Safety Commission: Better Data Needed to Help Identify
and Analyze Potential Hazards. [hyperlink,
http://www.gao.gov/products/GAO/HEHS-97-147]. Washington, D.C.:
September 29, 1997.
[End of section]
Footnotes:
[1] CPSC has jurisdiction over consumer products used in and around the
home and in sports, recreation, and schools, including many products
intended for children's use, such as toys, swimming pools, cribs, and
beds. However, CPSC does not have jurisdiction over all consumer
products, such as car seats protecting children in on-road vehicles,
automobiles, foods, drugs, cosmetics, and boats.
[2] Pub. L. No. 110-314, § 107.
[3] Racial and ethnic categories defined in Office of Management and
Budget standards for maintaining, collecting, and presenting federal
data on race include American Indian or Alaska Native, Asian, Black or
African-American, Native Hawaiian or Other Pacific Islander, and White.
There are two categories for data on ethnicity: Hispanic or Latino, and
Not Hispanic or Latino. Hispanic or Latino refers to a person of
Spanish culture or origin, regardless of race.
[4] The Institute of Medicine is a branch of the National Academy of
Sciences, a private nonprofit organization made up of subject matter
experts that advises the federal government on scientific and
technological matters.
[5] For details, see GAO, Digital Television Transition: Increased
Federal Planning and Risk Management Could Further Facilitate the DTV
Transition, [hyperlink, http://www.gao.gov/products/GAO-08-43]
(Washington, D.C.: Nov. 19, 2007).
[6] CPSC rarely uses its authority to seek a mandatory recall. All of
the 563 product recalls conducted in 2008 were voluntary, with CPSC
negotiating a corrective action plan with the responsible companies.
[7] Gitanjali Saluja, Ruth A. Brenner, Ann C. Trumble, Gordon S. Smith,
Tom Schroeder, and Christopher Cox, "Swimming Pool Drownings Among US
Residents Aged 5-24 Years: Understanding Racial/Ethnic Disparities,"
American Journal of Public Health (2006), 96(4):728-733.
[8] Although the race of the victim was included as a precoded field on
death certificates, researchers used data on death certificates about
place of birth, nationality, and country of origin to more specifically
code ethnicity.
[9] Ruth A. Brenner, Ann C. Trumble, Gordon S. Smith, Eileen P.
Kessler, and Mary D. Overpeck, "Where Children Drown, United States,
1995,"Pediatrics, (2001), 108: 85-89.
[10] Carrie K. Shapiro-Mendoza, Melissa Kimball, Kay M. Tomashek,
Robert N. Anderson, and Sarah Blanding, "US Infant Mortality Trends
Attributable to Accidental Suffocation and Strangulation in Bed From
1984 Through 2004: Are Rates Increasing?" Pediatrics (2009), No. 2,
123: 533-539.
[11] See also E. Arias, W. Schauman, K. Eschbach, P. Sorlie, and E.
Backlund, "The Validity of Race and Hispanic Origin Reporting on Death
Certificates in the United States," Centers for Disease Control and
Prevention, National Center for Health Statistics, Vital and Health
Statistics (2008), 2(148).
[12] Accidental suffocation and strangulation in bed is a subgroup of
sudden, unexpected infant deaths, a leading category of injury-related
infant deaths.
[13] Robert L. Franklin, MS, and Gregory B. Rodgers, PhD, Directorate
for Economic Analysis, US Consumer Product Safety Commission, Bethesda,
Maryland, "Unintentional Child Poisonings Treated in United States
Hospital Emergency Departments: National Estimates of Incident Cases,
Population-Based Poisoning Rates, and Product Involvement," Pediatrics
(2008), Vol. 122 No. 6.
[14] Elevated blood lead levels are associated with harmful health
effects in children, such as impaired mental and physical development.
[15] GAO, Consumer Product Safety Commission: Better Data Needed to
Help Identify and Analyze Potential Hazards, [hyperlink,
http://www.gao.gov/products/GAO/HEHS-97-147] (Washington, D.C.:
September 1997).
[16] We previously found that CPSC uses its data to identify rates of
injury and death by age group, but not other characteristics, to assess
which consumer product hazards have a disproportionate effect on
vulnerable populations, such as persons with disabilities. For details,
see [hyperlink, http://www.gao.gov/products/GAO/HEHS-97-147].
[17] Developing accurate estimates of product-related injury rates by
racial and ethnic group could be challenging given existing CPSC data
and data collection methods. Adequate numbers of cases from each racial
and ethnic group are needed to develop accurate rates of product-
related injury, and developing such rates could be a challenge in
smaller minority groups. In addition, CPSC data systems do not collect
other information that could explain differential rates of injuries
treated in hospital emergency rooms, such as access to health
insurance.
[18] Michele Ver Ploeg and Edward Perrin, eds., Eliminating Health
Disparities: Measurement and Data Needs (Washington, D.C.: The National
Academies Press, 2004).
[19] A. Wilson-Stronks and E. Galvez, Exploring Cultural and Linguistic
Services in the Nation's Hospitals: A Report of Findings. (Oakbrook
Terrace, Ill.: Joint Commission, 2007).
[20] E. Arias, W. Schauman, K. Eschbach, P. Sorlie, and E. Backlund,
"The Validity of Race and Hispanic Origin Reporting on Death
Certificates in the United States," Centers for Disease Control and
Prevention, National Center for Health Statistics, Vital and Health
Statistics (2008), 2(148).
[21] According to CPSC officials, CPSC's language bank is a working
list of CPSC staff members who have proficiency in other languages.
[22] GAO, Program Evaluation: Strategies for Assessing How Information
Dissemination Contributes to Agency Goals, [hyperlink,
http://www.gao.gov/products/GAO-02-923] (Washington, D.C.: Sept. 30,
2002).
[23] The Injury or Potential Injury Incidents and In-Depth
Investigations files include information about related consumer
products, but not race and ethnicity information.
[End of section]
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