committee believes that the agency's capacity to carry out this strategy needs to be strengthened by increasing its resources for injury surveillance, hazard analysis, and applied research. The key to successful regulation is better information.
Surveillance of product-related injuries is the foundation of CPSC's regulatory activities, including hazard identification, hazard analysis, and priority setting. The backbone of the CPSC surveillance system is NEISS. A recent GAO report questioned the adequacy of NEISS on the grounds that it is incomplete (omitting injuries treated outside emergency rooms) and lacks detail about the injury incidents (GAO, 1997). However, the committee agrees with CPSC that NEISS is adequate to serve the purposes for which it is used by CPSC. The real question raised by the GAO criticism is whether expansion of NEISS to cover other types of injuries would assist the injury field as a whole. From this perspective, the committee believes that the feasibility of expanding NEISS to cover all injury-related emergency department visits should be explored (see Chapter 3).
Additionally, the committee agrees with the GAO suggestion that CPSC's capacity to conduct more internal analysis, in order to identify product hazards, should be strengthened. Data needs identified by the GAO include exposure data and incident-based information bearing on consumer vulnerability. These suggestions should be considered in the context of a broader review of data needs bearing on residential and recreational injuries, conducted collaboratively by CPSC and NCIPC.
When it established CPSC, Congress recognized that research was an important component of the agency's mission. Section 5(b) of the Consumer Product Safety Act authorizes CPSC to "conduct research studies and investigations on the safety of consumer products and on improving the safety of such products." Despite the fact that CPSC is the only government agency that conducts in-depth product hazard research, the agency has limited capacity to carry out this important responsibility. As noted above, CPSC currently uses most of its limited technical resources to test and evaluate specific products and to support development of safety performance requirements. When the agency decides to take corrective action or to develop safety standards, it must present adequate evidence to demonstrate the existence of a safety hazard and the efficacy of proposed regulatory actions. Unfortunately, a few regulatory initiatives can fully deplete the agency's resources, especially if the products utilize newly developed technologies. As a result, the agency rarely has the resources to conduct applied research on generic safety problems that require more extensive study. If