To prevent infant suffocation, CPSC contributes to a public-private venture that encourages care givers to put infants to sleep on their backs or sides instead of on their stomachs. CPSC research, conducted in the wake of 35 infant deaths associated with bean bag cushions, found that rebreathing carbon dioxide trapped in bean bags and other soft bedding may contribute to approximately 30 percent of deaths previously determined to be, and probably misdiagnosed as, Sudden Infant Death Syndrome (SIDS) (CPSC, 1996b). Through safety alerts, press conferences, and public health campaigns with the American Academy of Pediatrics, the National Institute of Child Health and Human Development, and the SIDS Alliance, CPSC has sought to warn the public about soft bedding and the importance of placing infants on their backs or sides.

Assessment and Recommendation

In contrast to many other federal regulatory agencies, including OSHA, the CPSC has been criticized more for weakness than for overregulation (see, e.g., Viscusi [1984]; Christoffel and Christoffel [1989]). For the first decade of its existence, the prevailing view among economists was that the CPSC's regulatory actions had little or no effect in reducing product-related injuries, imposing costs on manufacturers and consumers without achieving any significant benefits (Viscusi, 1984). As a result, the agency faced the possibility of elimination. Since 1981, CPSC has suffered from chronic underfunding; its budget has decreased almost 50 percent in inflation-adjusted dollars, and the number of agency staff is less than half of what it was in 1980.

More recently, however, peer-reviewed scientific studies of specific regulatory actions by the CPSC have usually found that product-related injuries were substantially reduced at reasonable cost. Examples include child-resistant packaging of oral prescription drugs (Rodgers, 1996), bicycle safety standards (Magat and Moore, 1996), performance standards for walk-behind power lawnmowers (Moore and Magat, 1996), and the 1988 consent decree for all-terrain vehicles (Rodgers, 1993; Moore and Magat, 1997). Even one of the agency's most persistent critics has ranked CPSC regulation of unvented space heaters as one of the most cost-effective examples of risk regulation (Viscusi, 1992) and has found that behavioral adaptations do not offset the safety benefits of CPSC performance standards for child-resistant cigarette lighters (Viscusi and Cavallo, 1994).

Studies of regulatory success have begun to reshape the reputation of the CPSC. Once considered an ineffectual agency targeted for elimination, it now appears to represent a model of regulatory efficiency. This reputation has been reinforced over the past several years by the agency's efforts to leverage its resources through partnerships with manufacturers and consumer organizations. The committee believes that the CPSC is on the right course, relying heavily upon cooperative efforts with industry to raise prevailing standards of safety, all occurring in the shadow of the agency's regulatory authority. However, the



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