Document 44n6kJ3pp8eBK8O5bpRK8kopG

FILE NAME: Asbestos in Hair Dryers (HD) DATE: : DOC#: HD0 OCUMENT DESCRIPTION: >Z'ZW^ZZZ ZZ/ZZZ^,DZ Ju..n..e 11. 1<J74 Jh- G;n.tt. Company .........1_ ......... ~ I' -1:~tr;1" Mr. Carl Blec~schmfdt D1:-ector. Dlvt~lon of Product Defect ldenti!lcation CoIl3Umer P:-:xiuct Safety Commlulon RoOm 202 .. S401 We~tbard AvemJe Waahingto~ D. C. 20207 i Re: CPSC ISP - 129 i CPSC lSP - 130 ! Dear Mr. BlecMchmidt: L This 'ener u In response to your above-referenced requests for lnformatlon . i regardlng The Gll1ette Company's Max hal!' dryer TI-lD-2 and Super Max hair dryer HD-7. A1J I noted to Mr. Klt:zes of your office in a telephone conv~sa tion on May 29, 191';. Glllette recently moved its Appliance Olviston Crom Chlc:.ago to Boston; your mailgram! were forwarded to us from Chicago and were receiYed on ~L1y 29, 1974. This letter wlll discus! the l~~e! you rai3ed with regard to J":e THD-2 and HD7 aod supply you with t!1e lnlormation you requested with respect thereto. In yout" m:1ilg:-ams you sug~st that the heating calls in the THD-2 and HD-1 might short ci:-::uit. In order to evaluate the risk. L! any. which such short dccu1tin; :::i;::: p:-ese:':t. it 15 necessOlry to cons1der the possible consequences thereof. 5':.;.-: ~_:c:;\t<; 1n t~e he:lting coils produce ~-!'!1inute. r:tomen~a~ ele':'rl:al C~~ . . Jr ,:<:5. .\rc~r.g 15 to be dis:ing-.!lshed i:-o~ so;!:;~lnc: the laner exlst~ on!! \'::-.. re i::canccsc::::t m.l!cer ls e:tpeiled. The J.r::i:.; caused =-:" heat~,; coil s~or~ c~:-c .a~s is :!;e S.lr..e so.~ of brief electrical dlsc~re;e one get~ when plu:;;::-:;::: a.::'_. ~:cnje~c:.1 .lri'li'::1ce. n.e c:-:-: :.:.- ::~:o ': ~;;:: .;.!:!-: :.:-ci::~ cc:.:!~ cc~.:e:\:l:-!Y !'?ld:5 the [;:-:~!ln; o~ nC;H~': !:~::-:- _:::e :..:~e:;; d ...... ::~ co~!c! o~:: ~.:;:pen it ,::c ~r;::1:1; occu:;red ou:side cr..: u::i: 7~.:rc is .1;;;..:.:,..::::::: :10 s::!nc:I!'c :cst to e\'J!::2:~ this sort of risk; CONFIDENTIAL G 00414 . .,. '. ... - . . _.. ". -- - - - .- . .. -- ~ - I- . ! II it Is our undcrstandlng that Underwrsittear.sn'daLra~btoersat.to'Wrieesa,tte[nmc:optIesd ctourlnilnlittleytwwoorhkligntg.Jy to devise such a test. flAmmable f~brics by In lleu of any means of the arcing from 14 HD-7 dryers wfW:h had exhlbtted coU .horu in a previous test. - -(In that same test. no THJj-2$ had exhLb1ted arciJlg outside the unit. which means that the llkel1hood oITgnitlon of flamuable materials 1.5 extremely low.) The materuls chosen were suraical C:lttOn and cheesecloth.. i These are among the most highly n:unmable of bbric:s ::m~ a.re or wlll be used by Underwriters' Laboratories in ordinary flammabUlty hazard tenfng. [n the te:n. baU ot the HD-7a were wrapped in surglcal cotton and half i.."'1 cheeseCloth. TIle - t c::tbaust grUle on each dryer was removed to allow as much arcing as possible to contact the material (most arcmg occurs inside the dryer - In only two out ot eighty lID-ia e:c.ambed in a previous test W3..! tl'.marCini out!lde the unit). A tow. of .coo oYer coU shom were then generated by fmpact1ng the an.lts. sense In no lIistance did the fia'mmable material Ignite. scorch or dl$c:olor. In ~ur opinion. tich arcing as is generated by Impact cannot Ignite highly 1lunmable materials. Is not capable of clluslng any other damage -and cannot be consid:ered ba.zardous. - You suggest in your mailgram relating to the .- HD-7 that ~ plastic casing mf.gbt bum. All HD-7 cases are made of polycarboDate. a material with excelleIIt impact J- I reslsunce chanc:terlstics. Thls plasdc: 1. DOt flammable In the that paper is flammable. It will not trunaln combustion after being subjected to the flame from a match or a 30 second appllca.tion of the flame (rom a butane cigarette lighter. - Appllcitlon of hotter and/or more prolonged flames wil1 re:;ult in burning of the plastlc. rut even th{~ will gradually self-extinguish: the case material is classified as self-e:ctinguishing by Underwriters' Laboratories. Apart from these CM r:lcterlstics of the plude C1Sing all drye~ made for tbe Appliance Oh'ision conuin various strucrural safety fearure:s. There ls, for Instance, a thermo9t~t which pre\'ents rtihneg bpuroilcd:-!Uucptloonf.inFteunr-s.e.hhee::amt.oreO. ntehebupDodssreibdlpeesrocuerncte!o!f of these are inspected tv.'ice du 19n1tlon in the HO7are-Lnsulated from the plastic C2.sing by heatresisunt materials_ For-example. the he:lte~ box containing the coils is made-from high density. heat l."esist.:!::t phenolic_ T~e open ends of the heater box are shielded ~ a sc:-een and phenolic grii!~ on on:! end ace! an aluminum fan on the ocher. We condude that. althou~h the plastic C:1sLng of the H!)7 can be m:1de to burn. such an occurrc::ce is extremely unllkely L., ac cual use and In no case could be calJsed by he~t:ing coil .1rciq;_ elSe flamrr.:lbili:y accorrli:-:;:r presenrs :10 su!:Jst."lr:tiai ris<: of lnjury to users o( tt-.e H:J*7_ , We hayc prc--10usl\- b:-"I~::cc :I-:e Co:-:sumt!r P:-oc.::: S.!fe~ ~c;":"!rr::ssk;:1 cer.~ir. ::0:1- sumcr cor._;':.lin~ C:l::l [or 19,3 rC;J :-cln; the ennre line of lund-held h.:. l.lr dryers so:d G 00415 J . . .. ' " N - - ~aFl nIech3chmidt . June 12, 197-1 Page 3 - A .. _ I'~ e -~~' _~~. .._..'~.~: . - ':'-s~"-.r~~~~~~. ~'.'.-Z-,,!~_.,~.:- by the Appliance Division of The Glllette Company. In the present letter we would Illee to particularize thb information for the THD-2 and HO-7t update to Include anUable 1914 data and offer further 1n!cmDation. w.1! classiIy certa in ol our consumer correspondence as "non- routine". complabt:s. These Include lnstance~ 'lJ.ilere the con5Utner complained of personal1njury (bJ.:rned or singed hair. other hafr damage, shock. burn~ skin) or property damage, or where our tests confirmed a serious product defect (thermostat !allure, !allure of dlt!lectrlc test. acrual sIgns of intense heat). It should bt! emphasized that. since almost all consumers are sat~fi.ed with repair or replacement of thl'!ir dryerI complalnts oC personal injury or PI"?perty damage are not in fact'Vertfled. In 1973 the Appliance Division received a total of ten non-rootiM complaints On the TIm-2. T1W! represents. 0006% ot the number of THD-2 dryen estimated to be In the hands ol consumen in 1973. One of tilt! ten units was not returned, two were DOt examined (replacement of unlta under warranty), and three files have been misp1.l.ced !clIc\1,"ini the Division', move ta BaS-LOn. Three of the r~1n1ng four "A"ere found to haTe component de!ecta or ma1!u::nctfona unrelated to the pocslble heating con defect referred ~ in your mailgram. The remalnlngunit exhibited a shan circuit which may han been caused by beating coU .bon1ng. Couumer complaiIlts oa the THD- 2 lor 1973 c:.an be summar!%ed as follow.: four per50a3 compla1ned of barned 01" singed hair. t~ee of shock. two of fire; name or smoke; and one of property damage. In 1973. three aon-routine complaints were received on the HO-7. which represents .0003% oC the number ot units estimated to be in the hands ot cOlUUmers in 1973. In two cases no apparent maltunction v.as discovered; one unit was not rerurned. Two persons complained at burned skin and one of shoclC. Por the first lour months of 1974. the Appliance Dlvtslon received 14 non-routine compblnts on the THD-2; this represents 0008~ oLthe number of dryers estimated to be in the hands of consumers as of April 30, 19;4. E!even of the unit' involved were rerurr.ed and examined; of these, eight were found to contain component defects I 01" malfunctions unrelated to coil shortin~. TIlree of the remainin5 units had unspeci- fied hC!ltL1g coil malf.mctions (not :1ecessarlly short drcultir.o; due to the mountl=tg o( the colls). Early 1974 com?laints on the THO-2 can be summarized as follows: eight COrT:p!.:!:r.:s oC burned 0:' .ln~ed hair. one a! other h:1lr damage, one of pro?e:'t? damage. rw~ o( sh~c\:. and cwo of ~ire. flame or smoke. The THD-2 Is 00 longer in procJct!on c:.!~ [0 t.'1e l11trod:.I;:~ion of new models. For the S.l:-::e f0Jr l"!":o:-:I':; i;, ! q:-~. L'1e :\pp!iance Divisior. recicved 69 ::on- routbe cnmp!.l:-' .~ ::-::! : :::--. -. :-~.:-:- . .:~:.' ::': '::;:- - of :~:::: ::'..:=::xr !;':;=:=:::l=L'd :0 be.: ir. :~.c hands C: '_:::::::-5':'5";; :.;i:-ll ~~_'. 1":-';. f"~~-o::c:: t;;..: !.J:.trs L~:ol\cd wc.re returr:c..! ..!.~": ":X.l;-::l::et!; Q[ \.::(!S~ .;5 were fOll.'ld to !-,.J:c comror.C:1[ defects or mJI- G 00416 .c;:arl IDe1:hschmldt June 12, 1974 Page " e': functions unrelated to loose heating calls: the rema1ning three conu1ned unspecifled beating coLI malfunctions. The 69 cOmplaints br~1c down as follows: 30 complaints of bJrned or singed haIr. two of other hair c11.nuge. one of property damage. ten of shock, 18 of burned skin. and eight of fire. name or smoke con In enlu.attng these sUttJJt1cs, it must be emphasized that the conditions complained of. If In tact they occurred, cannot be attributed to shorting fo,r the reasons discussed aoove: coil arcing cannot cause 5 hock or ignition of flammable materials. In the great majority of cases, varloU!l Isolated component de!ecu unrelated to loose heating colI n:ounting can be found which may have caulSed tile conditions complaned of; In some cases we simply do DOt Icnow ~t. If a.nyt.h!ng. went wrong with the unit in the field- Arcing due to colI shorting lenes no traces on the un.lt. In addition to the letters described above, we aI.o recelTe letters complalnlng of Incidents which are not borne out by the condldon of the retUnled dryer (e.g "fire" or "flame' Is complained of, but the dryer shows DO sign of beat; "e:cplosion" f..5 complained or rut the dryer is retu::rned intact) or lnc1deIWI which we do DOt believe 'represent !I.uety haUl.r~ (e. g... "bloWn bouse tuses", where of course other appUances may have contributed to the occ:urrence). We tD DOt beUeve that these are sufficiently !leriou::: to be tre.ated 10 the same fashion as the c:omplalots described prevtou!lly; nonetheless the IIIlmbcr thereat 1s,&s follows: for the THD-2 for 1973 and the !1rr-r fO'.lI" months 01 19i4, a total of 21 (repre!lenting :tpproxim:1tely .OO12~ of the numr..... Ln the hands oC consumers on April 30); for the HD-i since its IntTOduction in .....ug'.l!lt or 1973 through April 30, 1974, a total of 101 (representing approximately. 0069% ot the number in the hands of COMUmer3 on A.prll 30). Corrective Action In order to estl.rr.ate the incidence of heating coil short circuiting due to loose mounting of the coils, the Appll:mce Dlvision subjected both the n'iD-2 and HD-7 to an energ-lzed Lmpact test. Eighty units (~O new and 40 used) of e~ch model were dropped one meter onto a hudwood block In all possible orientation!l. The incidence of coll short1~g was determlned by visual observation and by mr-altoring current draw. The incidence of coli support cord brea\:a~ ~\as determined by visual obscrvat!on. The used units are estim:w~d to have bee~ L'l the hands of consurr.ers from 313 months (THO2) or "-10 mon:hs (l-iD-7). A total of sb: Incidents of coU shorting were observed on t.':e 11102. and n on the HD-i. There was DO correlation ~rwee:l coil sho~in; and unit age O~ Imp:lc:t surf:lce. There W3S no evidence oC he:lce:' s:':;lport .::ord ~re.l;"'.:l';-c. whl~h r.e.l:1S r~:1t t~C ihor:~::; ",':as temporary o~::: :~e d~:~,s tes:ed could cont~:::;::! to be u,c I .l:-:cr i:-:-::_1::. 7!:cr(; were ~wo inci-:!~~:s of .lr::~:l; o!'!~;iiGe t.':c !.!nlt !or, :~c HD-7. Jnd no:-:e {or :!-,c TIID-Z. As we h.1 \"c C1':Jmcntcd in-ct:c ca rlier sections oC this lerter. colI shorting is not ha:z::1rc!o~s; t~::-c!ore, \':e \':o~id esrLnute the number oC product ',IntCS cor:caini."1; .1 G00417 I I ~ 1- . 'I . . . . . : . _ . . ' , . t;A r1 81ecfu5chmldt june 12. 19," '., e.. .~~ -, . .,-,.. Page 5 . -- wety haurd rue to such shorting u I?Ooe. We estimate tlut u of April 30. 197.. there were approximately Ip 716.000 THD-2. a.nd 1.463. ()(X) HD-7. In the hands oC con.umers. Based on the results ot the Impact test c5e~crlbed &boTe, we estimate that 130,000 THD2s (7.5%) an4 786,000 HIr7s (54%) could ah.Iblt temJX)rary con aborting: oC this number, based on the same test, no THD-2a and only 37.000 HD-7a (2.5%) could exhibit arcing olltside the dryer. - Although the shorting 1!1 not hazardous, the Appliance Division realized that such .. a condition could l:e oC concern to consumers who notice it and reflect on the qtallty ot our product. Accordingly. as a result ot a. meeting held on May 6, 1974 with engi.Deeno! the Consumer Product Safety Ccmmlsswn. the !ollowlni correctiYe actions were or 'are beini taken. with Teprd ~ the HD-7: .. ,-::!.. ~~...:: ..,..-' -~ 1. The manuhcturer hu been ~tt'ed'to add to bls pnunt ~V1! qual1ty control proceduies a c~reful examination of all"un1t! produced !or excessively loose heater coils; units which exhibit tbi4 condltion will be scrapped or reworked. This 1s now being oone. . 2. A pilot lot oC unit! Is now being produced with sevenl Improvement", among which la a repositioning of cOUs to maxtmize the dlstance between coils. It wbsequent evaluations show that these -cba.nges improve the quality and s.a!e~ of the product. the changes will be ma&: to prodlction unitS a.s soon as posslble. r support t 3. There 15 a mica in the center of the heater box which kee~ the coils trom hitting each other. Some protctypes are being made with two mica I support.! rather than one [0 provide more rigidity. Thi.! change will be made in production U!"'it3 as soon :IS Is possible if evaluation re!Ults indic.:lte an Improvement in procuct quality and ~tery: ?n:liminary lnve~t1gation.s m thls . I area have shown that the addltional mica support increases the loads required to cau.!e sr.ort circuIting trom about 60 G'" to about 200 G'". A very severe impact against a hand generates about 70 Gs. ... The mlc:l support mentioned above holds the coUs in a slot which allows ~ome movement between the coil and the support. Prototypes arc now beL"lg maCe with holes nther ~h:l~ slors. ThIs should !lolc! the coils r::ore secu!"e!~: and will become a parr of proc!:lction units as soon as possi!::lc aner evalu.:tion. If results show an L'lCreJ.se in product qmlit'l :lnd S.1!ery. No ch:l:tg:cs ~o t~e p!J.stlc case rr. terill are conrerr.?l:ncd sL-:ce \\"e feel ttut case I "nam-:.l~::::':" :s ::.::r ~Z'::-~~"..!5. I:: J<!~ir!on. t!-:e :::.lte:-i.a.l prese:1r!:-' used has excellc:-.: ::::;-lCt :CSI5~.l:-..:e ':':.JrJc:crl:;~ics. I. 1'0 corre'':~l'''C J:~ion is ::~~:c:::;:,I.l~l'd C'n the TIi!)-Z since it is no IO:l;cr ~inr pro- ~JCC~ t.!-.;~:o :::..:=~c~i::; C:'j0~:.:'-).:t:r.:c. I G 00418 . -, arl IDcchschmldt ]one12, 1974 Pqe6 a 4.... .1 .':'. .;. In closing, we wish to emphutze again th1t W~ do not belteve that either the TIro-2 or the HD-1 contairul a defect which would render it a subeta.nt!al hazard to consumers Ullng these products. If you have any que5tions or require a.ny further information, pIe.ase feel free to call at your conveo!ence. . Very trUly yours, I I I , I I JRL/dd l : I ,.. .~ ... .. ! \ . ,. , I , .. G 00419