Alan H. Schoem
Office of Compliance
email: email@example.com March 18, 2003
Re: 500-Watt Tubular Halogen Bulbs
The U.S. Consumer Product Safety Commission (CPSC) is an independent federal regulatory agency established by Congress in the Consumer Product Safety Act, 15 U.S.C. §§ 2051-2084. The Commission is responsible for protecting the public from unreasonable risks of injury associated with consumer products. We are asking that you take steps to assure that the packaging of any tubular 500-watt double ended halogen lamps (bulbs) you manufacture or import for consumer use through typical retail channels bears the appropriate ANSI warning label and that the label is displayed prominently on the front panel of the bulb packaging.
During 1997 and 1998, the National Electrical Manufacturers Association (NEMA) worked with CPSC to develop a warning label to be placed on the front panel of packaging of tubular 500-watt double-ended halogen lamps (i.e. bulbs). In October 1998, the labeling was approved as an American National Standard (ANSI C78.260c-1998 - Supplement to ANSI C78.260-1998). CPSC recently became aware that there are several new manufacturers of these 500-watt halogen bulbs that may not be aware of the required ANSI labeling. In cooperation with Cooper Industries, we recently issued the enclosed press release warning about 500-watt halogen bulbs that can be used in torchiere floor lamps or other indoor residential fixtures.
CPSC is aware of at least 291 fires and 27 deaths involving halogen torchiere floor lamps. Although the current Underwriters Laboratories standard requires halogen torchiere floor lamps to be equipped with a protective glass or wire guard, consumers may not be aware that the lamps should only be used with a bulb that is 300 watts or less. Since there still are older torchiere floor lamps in service that do not meet the current UL standard, it is especially important that consumers not inadvertently use 500-watt bulbs in those fixtures.
Your firm may manufacture, import, or distribute tubular 500-watt double ended bulbs that fit halogen torchiere floor lamps intended for indoor use. Since these 500-watt bulbs are often sold at retail in displays next to lower wattage bulbs, consumers may not understand that they should not use the 500-watt bulbs for their torchiere floor lamps.
We are asking for your cooperation to help prevent future fires and injuries associated with halogen torchiere floor lamps and other indoor residential fixtures that may be capable of using a 500-watt halogen bulb. We ask that all bulb manufacturers (and importers of bulbs) verify that their packaging complies with the ANSI requirements. If you are not already doing so, we request that your firm immediately begin placing the required ANSI labeling on the front panel packaging of your tubular 500-watt double ended halogen bulbs. For an example of an acceptable warning label, refer to press release 03-077 or to the ANSI standard cited above.
If you have any questions or require assistance in this effort, please call Renae Rauchschwalbe of my staff on 301-504-7664 or you can email her at firstname.lastname@example.org. CPSC investigators will be checking for the appropriate labeling within the next several months. We would like to work cooperatively with you in assuring that your products are used safely and appropriately.
Alan H. Schoem