NCHR Comment on CPSC Proposed Investigation of Smart Toys and Additional Toys Through Child Observations Response

NCHR submitted the only comment to CPSC about their proposed study of young children’s effective use of smart toys. CPSC responded to our previous comment and released a revised request for public comments, clarifying that the study was exploratory. We responded by again urging CPSC to study a larger number of children who are more representative of the U.S. population, to better guide future guidelines for these toys.

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NCHR’s Comments on the CPSC’s Proposed Guidelines on Safety Standard for Infant and Infant/Toddler Rockers

NCHR supports the CPSC’s new proposed guidelines for infant rockers that will help to strengthen safety standards for such products. We offered suggestions to the rule, including adding a minimum age of use of at least 4 months old, more strongly discouraging the use of rockers for sleeping, and making physical changes that minimize the use for sleeping and the risk of injury. We also urged the CPSC to strengthen warning/labeling requirements, prevent stockpiling of rockers that don’t meet the new requirements, and support future research into the safety of rockers and related products.

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NCHR Public Comment on Communications From Firms to Healthcare Providers Regarding Scientific Information on Unapproved Uses of Approved Medical Products

December 26, 2023: We responded to the FDA’s request for public comment about the scientific information (SIUU) that firms can provide to healthcare providers about the unapproved uses of approved medical products. Promotion for unapproved (off label) uses were prohibited years ago, but that has been loosened over the decades and the FDA’s new draft guidance is worrisome because it is not as specific as it should be about how to ensure that the information the companies provide is accurate and not misleading. We agree with some of the guidance but urge more careful wording to ban the use of poor quality data and misinterpretation.

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