I write in support of this petition. I am a child psychologist based in Birmingham, Alabama. I have conducted extensive research on preventing unintentional injuries, including poisoning, to children. I have published about 100 peer-reviewed scientific articles and am recognized internationally as an expert in psychological aspects of child safety and injury prevention. One line of my research has examined kerosene poisoning among children in South Africa, where children frequently ingest kerosene stored in transparent bottles and suffer serious injuries or death. Although injury rates in the United States are somewhat lower than in developing nations like South Africa where kerosene is used widely in homes without electricity, there is evidence that many American children and adults suffer injuries and death after ingesting dangerous torch fuels and lamp oils. Any initiative to reduce those injuries is clearly of public health benefit.
To state the obvious, young children who cannot yet read rely heavily on product labeling and appearance to determine its safety for consumption. If a product looks like juice, and smells pleasant, a young child will drink it. We know that child resistant caps reduce the likelihood that a child will open a bottle but are not foolproof. Placing dangerous torch fuels and lamp oils into opaque containers will substantially reduce the likelihood that a child may see the liquid, believe it to be juice or some other appealing beverage, and consume it. We can save lives with this change, and we should act.
Comment from David Schwebel
This is comment on Proposed Rule
Petition Requesting Non-See-Through Packaging for Torch Fuel and Lamp Oil
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