The U.S. Consumer Product Safety Commission has proposedthat the implementation of performance standards is necessary to decrease theexisting, unreasonable risk associated with table saws.

This memo begins bysummarizing the proposed standards and data indicating the risks table sawspose. The next part explains how entities will be affected by the proposedstandards. The last section describes the significance of implementing newstandards. Backgroundand Proposed Safety Standards On April15, 2003, SawStop petitioners requested that the Commission establish newsafety performance standards for table saws to prevent and reduce unreasonableinjury risk. In 2015, table saws caused an estimated 33,400 emergency relatedinjuries leading to 4,700 amputations alone. Table saws are consumer productsthus they are subject to regulation by the U.S. Consumer Product SafetyCommission.

 Afteranalysis of finger injury data, the CPSC concluded that injuries fromblade-contact would be greatly decreased if all table saw manufacturers had to meetperformance requirements that limit saw cuts to 3.5 mm or less while thespinning blade approaches at 1 millimeter per second. The new requirementswould require table saws to be manufactured to contain Active Injury Mitigation(AIM) technology. AIM technology serves to move and stop the function of theblade if human contact is detected. This proposed rule would require that tablesaws are tested during manufacturing with a probe acting as a human finger toensure that cutting depth and speeds meet specified requirements.

Through dataanalysis, the Commission will ensure that the rule is necessary to reduceunreasonable risk and that it serves the public interest.   IndustryAdjustments The proposedrule would affect manufacturers, importers, private companies and consumers.The proposed rule does not establish a set structure for companies to meet newstandards; rather, firms of all sizes are tasked with determining theappropriate technology to do so on their own. The new standards would vastlyincrease the cost of producing saws. Companies would need to finance theacquisition of AIM technology and the redesign of table saws to support the newtechnology. Today,there are only two AIM technology systems, SawStop and Bosh REAXX tm thatare able to sufficiently decrease risks associated with saw injuries. Of the 22firms that provide table saws to the United States, 8 to 10 of these firms aresmall businesses.

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These small companies would need to invest thousands todevelop their own technology or pay an estimated $30-35 million in royalties toutilize existing AIM technology. There is no evidence or assurance thatindicates whether these two systems would eventually agree to license their technologyto small businesses in the future. Newtechnology will also affect the weight and utility of table saws. By adding AIMtechnology to the lightest saws, bench saws, stability bases would need to beredesigned to sustain kick-back and shock. Bench saws are responsible for 75% of all saw sales today. Theyare preferred by customers because they are intended to be portable and lightweight. An estimated increase of almost 18 poundswill decrease the utility of the bench saws. Implementation It is hardto estimate how effective AIM technology will be.

The benefits will only bevisible in the reduction of injuries reported and medically treated. TheCommission estimates that injuries will decrease by 70-90%. The Commissionbelieves that even without perfect implementation, AIM technology will stillserve to significantly reduce the number of medically treated injuries fromtable saws. Based on CPSC analysis, the proposed rule would target 54,800medically treated injuries and result in an aggregate $4.

06 billion benefit tosociety. There will always be circumstances where the benefits from AIMtechnology are mitigated by human operational behavior. Consequently,operational behavior creates an overstatement of the estimated benefits of theproposed performance requirements. TheCommission regulated by the CPSC is acting cautiously when working to finalizethe proposed rule because of the threat of a possible monopoly. AIM technologyis only available from two companies today.

These companies combined holdmultiple patents on the technology. The proposed rule will have the ability togrant these companies a legal monopoly that could ultimately serve to decreasecompetition, push companies out of the market and largely decrease table sawoptions for consumers.