AU TH ENTICATED ,
`U.S. G O V E R N M E N T^
`INFO RM ATIO N >
`
`Pt. 1205
`
`1205—SAFETY STANDARD
`PART
`FOR WALK-BEHIND POWER LAWN
`MOWERS
`Subpart A—The Standard
`
`S e c .
`1205.1 S c o p e o f t h e s ta n d a r d .
`1205.2 E f f e c t i v e d a te .
`1205.3 D e fin it io n s .
`1205.4 W a lk - b e h in d r o t a r y p o w e r m o w e r p r o ­
`t e c t i v e s h ie ld s .
`1205.5 W a lk - b e h in d
`c o n t r o ls . .
`1205.6 W a r n in g la b e ls f o r r e e l - t y p e a n d r o ­
`t a r y p o w e r m o w e r s .
`1205.7 P r o h i b i t e d s t o c k p ilin g .
`1205.8 F in d in g s .
`Subpart B—Certification
`
`r o t a r y p o w e r m o w e r
`
`1205.30 P u r p o s e , s c o p e , a n d a p p lic a t io n .
`1205.31 E f f e c t i v e . d a t e . .
`1205.32 D e f in it io n s . .
`1205.33 C e r t i f i c a t i o n t e s t in g .
`1205.34 R e c o r d k e e p in g r e q u ir e m e n t s .
`1205.35 P r o d u c t c e r t i f i c a t i o n a n d la b e lin g b y
`m a n u fa c t u r e r s .
`1205.36 P r o d u c t c e r t i f i c a t i o n a n d la b e lin g b y
`im p o r t e r s ..
`
`A uthority： S e c s . 2, 3, 7, 9, 14, 19, P u b . L .
`92-573, 86 S t a t . 1207, 1208, 1212-1217, 1220, 1224;
`15 U .S .C . 2051, 2052, 2056, 2058, 2063, 2068; sec .
`1212, P u b . L . 97-35, 95 S t a t . 357.
`
`S ource: 44 F R 10024, F e b . 15, 1979, u n le s s
`o t h e r w is e n o t e d .
`
`Subpart A—The Standard
`§ 1205.1 Scope of the standard.
`⑻ General. This subpart A of part
`1205
`is a consumer product safety
`standard which prescribes safety re­
`quirements
`for certain walk-behind
`power lawn mowers, including labeling
`and performance requirements. The
`performance requirements of the stand­
`ard apply to rotary mowers. The label­
`ing requirements apply to both rotary
`and reel-type mowers. The standard is
`intended to reduce the risk of injury to
`consumers caused by contact, pri­
`marily of the foot and hand, with the
`rotating blade of the mower. A detailed
`discussion of the risk of injury and of
`the anticipated costs, benefits, and
`other
`factors associated with
`the
`standard is contained in §1205.8 Find­
`ings.
`(b) Scope. (1) Except as provided in
`paragraph ⑻ of this section, all walk-
`behind rotary and reel-type power lawn
`
`16 CFR Ch. II (1-1-12 Edition)
`
`mowers manufactured or imported on
`or after the effective date of the stand­
`ard are subject to the requirements of
`this standard if they are “ consumer
`products” . “ Walk behind power lawn
`mower” is defined as a grass cutting
`machine with a minimum cutting
`width of 12 in (305 mm) that employs an
`engine or motor as a power source. Sec­
`tion 3(a)(1) of the Consumer Product
`Safety Act
`( “ CPSA”）， 15 U.S.C.
`2052(a)(1), defines the term consumer
`product as an “ article, or component
`part thereof, produced or distributed (i)
`for sale to a consumer for use in or
`around a permanent or temporary
`household or residence, a school, in
`recreation, or otherwise, or (ii) for the
`personal use, consumption or enjoy­
`ment of a consumer in or around a per­
`manent or temporary household or res­
`idence, a school, in recreation, or oth­
`erwise.” The term does not include
`products that are not customarily pro­
`duced or distributed for sale to, or for
`the use or consumption by, or enjoy­
`ment of, a consumer.
`(2)
`It is unlawful to manufacture for
`sale, offer for sale, distribute in com­
`merce, or
`import
`into the United
`States any product subject to this
`standard that is not in conformity with
`the standard. The Commission is not
`applying the standard to rental trans­
`actions or to the ultimate sale of used
`rental mowers by rental firms.
`(c) Exclusions—(1) General. Mowers
`that have all three of the following
`characteristics are not covered by the
`standard:
`(1) A cutting width of 30 in (762 mm)
`or greater,
`(ii) A weight of 200 lb (90.7 kg) or
`more, and
`(iii) For engine-powered mowers, an
`engine of 8 horsepower (6 kw) or more.
`(2) Reel-type mowers. Reel-type power
`lawn mowers need not meet the per­
`formance requirements of the standard
`but they must be labeled as required by
`§1205.6.
`§ 1205.2 Effective date.
`This standard applies to all rotary
`walk behind power lawn mowers manu­
`factured after June 30, 1982, except
`§1205.6 Warning labels, applies to rotary
`and reel-type walk-behind power lawn
`
`298
`
`TTI
`Exhibit 1008 - Page 1
`
`

`

`Consumer Product Safety Commission
`
`§1205.3
`
`mowers manufactured after December
`31，1979.
`
`[44 F R 10024, F e b . 15, 1979, a s a m e n d e d 45 F R
`86417, D e c . 31，1980]
`§ 1205.3 Definitions.
`(а) As used in this part 1205:
`⑴ Blade means any rigid or semi­
`rigid device or means that is intended
`to cut grass during mowing operations
`and includes all blades of a multi-blad-
`ed mower.
`(2) Blade Up circle means the path de­
`scribed by the outermost point of the
`blade as it moves about its axis.
`(3) Crack means a visible external fis­
`sure in a solid body caused by tensile,
`compressive, or shear forces.
`(4) Cutting width means the blade tip
`circle diameter or, for a multi-bladed
`mower, the width, measured perpen­
`dicular to the forward direction, of a
`composite of all blade tip circles.
`(5) Deform means any visible alter­
`ation of shape or dimension of a body
`caused by stresses induced by external
`forces.
`(б) Gngine means a power producing
`device which converts thermal energy
`from a fuel into mechanical energy.
`(7) Oanual utarting means starting
`the mower engine with power obtained
`from the physical efforts of the oper­
`ator.
`
`srggf means
`(8)
`the maximum revolutions per minute
`(rpm) obtainable by the engine or
`motor under the conditions of the par­
`ticular test where the term is used. For
`an electrically powered mower, it is
`the speed attained when the mower is
`energized from a 60 Hz alternating cur­
`rent source that delivers a voltage no
`greater than 120 V and no less than 115
`V at the power input to the mower,
`with the mower running. For a battery-
`powered mower, it is the speed attained
`after
`the battery has been
`fully
`charged in accordance with the mower
`manufacturer’s instructions.
`(9) M oIot means a power producing
`device that converts electrical energy
`into mechanical energy.
`(10) Normal starting means is the pri­
`mary mechanism intended to be actu­
`ated by the operator to start a mower’s
`engine or motor (e.g., the cord mecha­
`nism of a manual start engine, the
`switch of an electric motor, or a power
`start mechanism).
`(11) Operating control zone means the
`space enclosed by a cylinder with a ra­
`dius of 15 in (381 mm) having a hori­
`zontal axis that is (1) perpendicular to
`the fore-aft centerline of the mower
`and (2) tangent to the rearmost part of
`the mower handle, extending 4 in (102
`mm) beyond the outermost portion of
`each side of the handle (See Fig. 1).
`
`299
`
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`Exhibit 1008 - Page 2
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`

`

`§1205.4
`
`16 CFR Ch. II (1-1-12 Edition)
`
`(12) Power source means an engine or
`motor.
`(13) Reel-type mower means a lawn
`mower which cuts grass by rotating
`one or more helically formed blades
`about a horizontal axis to provide a
`shearing action with a stationary cut­
`ter bar or bed knife.
`(14) Rotary mower means a power lawn
`mower in which one or more cutting
`blades rotate in essentially a hori­
`zontal plane about at least one vertical
`axis.
`(15) Separate means to cause to have
`any apparent relative displacement in­
`duced by external forces.
`(16) Shield means a part or an assem­
`bly which restricts access to a haz­
`ardous area. For the purposes of this
`part 1205, the blade housing is consid­
`ered a shield.
`(17) Stress means a force acting across
`a unit area in a solid material in resist­
`ing separation, compacting, or sliding
`that tends to be induced by external
`forces.
`
`(18) Top of the mower,s handles means
`the uppermost portion⑻ of the handle
`that would be gripped by an operator in
`the normal operating position.
`(19) Walk-behind power lawn mower
`means a grass cutting machine either
`pushed or self-propelled, with a min­
`imum cutting width of 12 in (305 mm)
`that employs an engine or a motor as a
`power source and is normally con­
`trolled by an operator walking behind
`the mower.
`(b) Where applicable, the definitions
`in section 3 of the Consumer Product
`Safety Act (15 U.S.C. 2052) apply to this
`part 1205.
`[44 F R 10024, F e b . 15, 1979, as a m e n d e d a t 46
`F R 54934, N o v . 5, 1981]
`rotary power
`§ 1205.4 Walk-behind
`mower protective shields.
`(a) General requirements. Walk-behind
`rotary power mowers shall meet the
`following requirements:
`(1) When the foot probe of Fig. 2 is in­
`serted under any point within the areas
`
`300
`
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`Exhibit 1008 - Page 3
`
`

`

`Consumer Product Safety Commission
`
`§1205.4
`
`to be probed during the foot probe test
`of paragraph (b)(1) of this section, the
`shields shall prevent the foot probe
`
`from entering the path of the blade or
`causing any part of the mower to enter
`the path of the blade.
`
`(2) Any shield located totally or part­
`ly within the areas to be probed, as de­
`fined in paragraph (b)(1)(ii) of this sec­
`tion, shall not permanently separate,
`
`crack, or deform when the shield is
`subjected to a 50 lb (222 N) static ten­
`sile force, uniformly distributed over
`not less than half the length of the
`
`301
`
`TTI
`Exhibit 1008 - Page 4
`
`

`

`§1205.4
`
`16 CFR Ch. II (1-1-12 Edition)
`
`shield. The force shall be applied for at
`least 10 seconds in the direction which
`produces the maximum stress on the
`shield. While beinv tested, a shield
`shall be attached to the mower in the
`manner in which it is intended to be
`used. (This requirement does not apply
`to the housing.)
`(3) During the obstruction test of
`paragraph (b)(2) of this section, shields
`shall not:
`(i) Stop the mower as a result of con­
`tact with the raised obstacle,
`(ii) Enter the path of the blade, or
`(iii) Cause more than one wheel at a
`time to be lifted from the fixture sur­
`face.
`Shield tests—general—(1) Foot probe
`(b)
`test, (i) The following test conditions
`shall be observed:
`(A) The test shall be performed on a
`smooth level surface.
`(B) Pneumatic tires, when present,
`shall be inflated to the cold pressures
`recommended by the mower manufac­
`turer.
`(C) The mower housing shall be ad­
`justed to its highest setting relative to
`the ground.
`(D) The blade shall be adjusted to its
`lowest position relative to the blade
`housing.
`(E) The mower shall be secured so
`that the mower may not move hori­
`zontally but is free to move vertically.
`Areas to be probed. (A)(1) The min­
`(ii)
`imum area to be probed shall include
`an area both 60 degrees to the right and
`60 degrees to the left of the rear of the
`fore-aft centerline of the cutting width.
`For single-blade mowers, these angles
`shall be measured from a point on this
`fore-aft centerline which is at the cen­
`ter of the blade tip circle (see Fig. 3).
`For multi-blade mowers, these angles
`shall be measured from a point on the
`fore-aft centerline of the cutting width
`which is one half of the cutting width
`forward of the rearmost point of the
`composite of all the blade tip circles
`(bee Fig1. 4).
`
`(2) For a mower with a swing-over
`handle, the areas to be probed shall be
`determined
`as
`in
`paragraph
`(b)(1)(ii)(A)(1) of this section from both
`possible rear positions. (See Fig. 5.)
`
`302
`
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`Exhibit 1008 - Page 5
`
`

`

`Consumer Product Safety Commission
`
`§1205.4
`
`the bottom edge of the blade housing
`and shields. During each insertion, the
`“ sole” of the probe shall be kept in
`contact with the supporting surface.
`Insertion shall stop when the mower
`housing lifts or the horizontal force
`used to insert the probe reaches 4 lb
`(17.8 N), whichever occurs first. As the
`foot probe is withdrawn after each in­
`sertion, the “ toe” shall be pivoted up­
`ward around the “ heel” as much as
`possible without lifing the mower.
`(2) Obstruction test. (i) The following
`test conditions shall be observed:
`(A) Pneumatic tires, when present,
`shall be inflated to the cold pressure
`recommended by the mower manufac­
`turer.
`(B) The mower housing shall be at its
`highest setting relative to the ground.
`(ii) The test shall be performed on
`the fixture of Fig. 6, which consists of
`a level surface having (A) a 0.99 in (25
`mm) deep depression with a 5.90 in (150
`mm) radius of curvature and (B) a
`raised obstacle 0.60 in (15 mm) square,
`each extending the full width of the
`fixture. The depression shall be lined
`with a material having a surface equiv­
`alent to a 16- to 36-grit abrasive. The
`depression and the obstacle shall be lo­
`cated a sufficient distance apart so
`that the mower contacts only one at a
`time.
`
`shield is required by § 1205.5(a)(l)(iv)(B)
`or § 1205.5(c), the entire periphery of the
`mower shall be probed (including any
`discharge chute comprising part of the
`periphery).
`Procedure. Within the areas spec­
`(iii)
`ified in paragraph (b)(1)(ii), the foot
`probe of Fig. 2 shall be inserted under
`
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`Exhibit 1008 - Page 6
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`

`

`§1205.5
`
`(iii) The test fixture may be relieved,
`only to the extent necessary, to pre­
`vent interference with any blade re­
`taining device.
`(iv) The mower shall be pushed for­
`ward and pulled rearward perpen­
`dicular to and across the depression
`and the raised obstacle on the fixture.
`The mower shall be pulled and pushed,
`without lifting, with a horizontal force
`sufficient to transit the obstruction
`fixture at a speed not to exceed 2.2 ft/
`sec (0.7 m/sec).
`(c) Movable shields—(1) General. Mov­
`able shields must meet the general
`shield requirements of paragraph (a) of
`this section.
`In addition, movable
`shields which are in any of the areas to
`be probed defined in paragraph (b)(1)(ii)
`of this section and which are intended
`to be movable for the purpose of at­
`taching auxiliary equipment, when de­
`flected to their extreme open position
`in the manner intended by the manu­
`facturer and released, shall either:
`(1) Return automatically to a posi­
`tion that meets the requirements of
`subpart A of this part 1205 when the at­
`tached equipment is not present, or
`(ii) Prevent operation of the blade⑻
`unless
`the attached equipment
`is
`present or the movable shield is re­
`turned to a position that meets the re­
`quirements of subpart A of this part
`1205.
`(2) Tests. (i) Automatic return of a
`movable shield shall be determined by
`manually deflecting the shield to its
`extreme open position, then releasing
`the shield and visually observing that
`it immediately returns to the closed
`position.
`(ii) Prevention of operation of the
`blade⑻ shall be determined, first by
`manually deflecting the shield to its
`extreme open position, then, following
`the appropriate manufacturer’s
`in­
`structions, completing the procedures
`necessary to operate the blade. Ob­
`serve, using any safe method, that the
`blade⑻ has been prevented from oper­
`ating.
`
`[44 F R 10024, F e b . 15, 1979, a s a m e n d e d a t 45
`F R 86417, 86418, D e c . 31, 1980; 46 F R 54934,
`N o v . 5, 1981; 48 F R 6328, F e b . 11, 1983]
`
`16 CFR Ch. II (1-1-12 Edition)
`
`rotary power
`
`§ 1205.5 Walk-behind
`mower controls.
`(a) Blade control systems—(1) Require­
`ments for blade control. A walk-behind
`rotary power mower shall have a blade
`control system that will perform the
`following functions:
`(1) Prevent the blade from operating
`unless the operator actuates the con­
`trol.
`(ii) Require continuous contact with
`the control in order for the blade to
`continue to be driven.
`(iii) Cause the blade motion in the
`normal direction of travel to come to a
`complete stop within 3.0 seconds after
`release of the control.
`(iv) For a mower with an engine and
`with only manual starting controls,
`this blade control shall stop the blade
`without stopping the engine, unless:
`(A) The engine starting controls for
`the lawn mower are located within 24
`inches from the top of the mower’s
`handles, or
`(B) The mower has a protective foot
`shield which extends 360 degrees
`around the mower housing (see §1205.4
`(b)(1)(ii)(B)).i
`(2) All walk-behind rotary power
`mowers shall have, in addition to any
`blade control required by paragraph
`(a)(1) of this section, another means
`which must be manually actuated be­
`fore a stopped blade can be restarted.
`This additional means may be either a
`control which is separate from the con­
`trol required by paragraph (a)(1) of this
`section, or may be incorporated into
`the control required by paragraph (a)(1)
`of this section as a double-action de­
`vice requiring two distinct actions to
`restart the blade.
`(b) Blade stopping test—(1) General.
`Any test method that will determine
`the time between the release of the
`blade control and the complete stop of
`the blade motion in the normal direc­
`tion of travel may be used.
`(2) Conditions. (i) The mower shall be
`operated at maximum operating speed 1
`
`1 P a r a g r a p h s ( A ) a n d (B ) o f § 1 2 0 5 .5 (a )(1 )(iv ),
`p e r m i t t i n g m o w e r s t h a t s to p t h e b la d e b y
`s t o p p in g t h e e n g in e b u t t h a t d o n o t h a v e
`p o w e r r e s t a r t , w e r e a d d e d t o t h e s ta n d a r d as
`d ir e c t e d b y S e c . 1212 o f t h e O m n ib u s B u d g e t
`R e c o n c i l i a t i o n A c t o f 1981, P u b . L . 97-35, 95
`S t a t . 357.
`
`304
`
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`Exhibit 1008 - Page 7
`
`

`

`Consumer Product Safety Commission
`
`§1205.7
`
`for at least 6 minutes immediately
`§ 1205.6 Warning label for reel-type
`and rotary power mowers.
`prior to the test.
`(ii) The blade must be at maximum
`(a) General. Walk-behind power lawn
`operating speed when the blade control
`mowers shall be labeled on the blade
`is released.
`housing or, in the absence of a blade
`Starting controls location. Walk-be-
`(c)
`housing, on other blade shielding or on
`hind mowers with blades that begin op­
`an adjacent supporting structure or as­
`eration when the power source starts
`sembly, with the warning label shown
`shall have their normal starting means
`in Fig. 7. The label shall be at least 3.25
`located within the operating control
`in (82.5 mm) WigW and 4 in (102 mm)
`zone unless the requirements of para­
`wide, and the lettering and symbol
`graphs (a)(l)(iv) (A) or (B) of this sec­
`shall retain the same size relation to
`tion apply to the mowers.
`each other and to the label as shown in
`[44 F R 10024, F e b . 15, 1979, as a m e n d e d a t 46
`Fig. 7.
`F R 54934, N o v . 5, 1978]
`
`(b) Rotary mowers. Walk-beWxnd ro­
`tary mowers shall have one label as
`shown in Fig. 7, on the blade housing.
`The label shall be located as close as
`possible to any discharge opening, or, if
`there is no discharge opening, in a posi­
`tion that is conspicuous to an operator
`in the normal operating position.
`(c) Reel-type mowers. Walk-beWind
`power reel-type mowers shall have one
`label as shown in Fig. 7, located as
`close to the center of the cutting width
`
`of the blade as possible. However, in
`the absence of a suitable mounting sur­
`face near the center of the cutting
`width, the label shall be placed on the
`nearest suitable mounting surface to
`the center of the cutting width.
`[44 F R 10024, F e b . 15, 1979, as a m e n d e d a t 45
`F R 86417, D e c . 31, 1980]
`§ 1205.7 Prohibited stockpiling.
`Stockpiling. Stockpiling means
`(a)
`manufacturing or importing a product
`
`305
`
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`Exhibit 1008 - Page 8
`
`

`

`§1205.8
`
`16 CFR Ch. II (1-1-12 Edition)
`
`blade contact injuries per year, or 77%
`which is the subject of a consumer
`product safety rule between the date of
`of all such injuries. The Commission
`issuance of the rule and its effective
`estimates that if all mowers had been
`date at a rate that is significantly
`in compliance with the standard in
`greater than the rate at which such
`1977, about 6,800 finger amputations,
`product was produced or imported dur­
`1,500 toe amputations, 11，000 fractures,
`ing a base period prescribed by the
`1，800 avulsions, 38,400 lacerations, and
`Consumer Product Safety Commission.
`several hundred contusions would not
`(b) Prohibited acts. Stockpiling of
`have occurred. Of the lacerations and
`power lawn mowers that do not comply
`avulsions, 28,300 were finger injuries
`with this subpart A of part 1205 at a
`and 9,400 were toe injuries.
`rate that exceeds by 20% the rate at
`(c) Consumer products subject to the
`which the product was produced or im­
`rule. The products subject to this
`ported during the base period described
`standard are walk-behind power mow­
`in paragraph (c) of this section is pro­
`ers. Power mowers with rigid or semi­
`hibited.
`rigid rotary blades are subject to all
`(c) Base period. The base period for
`the provisions of the standard while
`power lawn mowers is, at the option of
`reel-type and rotary mowers are sub­
`each manufacturer or importer, any pe­
`ject
`to
`the
`labeling requirements.
`riod of 365 consecutive days beginning
`Mowers that in combination have en­
`on or after September 1, 1971, and end­
`gines of 8 hp or greater, weigh 200 lb or
`ing on or before August 31, 1978.
`more, and have a cutting width of 30 in
`§ 1205.8 Findings.
`or more are excluded from the stand­
`⑻ General. In order to issue a rule
`ard. The Commission estimates that at
`such as part 1205, the Consumer Prod­
`least 98% of the total annual market
`uct Safety Act requires the Commis­
`(by unit volume) for walk-behind mow­
`sion to consider and make appropriate
`ers will be affected by the standard,
`findings with respect to a number of
`and the Commission estimates that in
`topics. These findings are discussed
`1978 this market was 5.4 million units.
`below.
`(S)
`Need of the public for the products
`(b) The degree and nature of the risk of
`subject to the rule. The Commission
`injury part 1205 is designed to eliminate or
`finds that the public need for walk-be-
`reduce. (1) The Commission estimates
`hind power mowers, which provide a
`that there are approximately 77,000 in­
`relatively quick and effective way to
`juries to consumers each year caused
`cut grass, is substantial. Riding mow­
`by contact with the blades of power
`ers, lawn and garden tractors, hand
`lawn mowers. From 1977 data, the Com­
`reel mowers, trimmers and edgers, and
`mission estimates that each year there
`sickle-bar mowers also provide grass­
`are approximately 7,300 finger amputa­
`cutting
`services, but walk-behind
`tions, 2,600
`toe amputations, 2,400
`power rotary mowers are by far the
`avulsions (the tearing of flesh or a
`most commonly used devices for main­
`body part), 11,450 fractures, 51,400 lac­
`taining household lawns. There are no
`erations, and 2,300 contusions. Among
`devices that can completely substitute
`the lacerations and avulsions, 35,800
`for walk-behind power mowers as a
`were to hands and fingers and 18,000
`were to toes and feet. The estimated
`group, since they have applications for
`costs caused by these injuries are 2253
`which other products are not as suit­
`million, not counting any monetary
`able. Each type of walk-behind power
`damages for pain and suffering. These
`mower has individual properties which
`injuries are caused when consumers ac­
`meet public needs, although one type
`cidentally contact the blade, either in­
`of walk-behind is often an acceptable
`advertently while in the vicinity of the
`substitute for another. The newly de­
`mower, or while
`intentionally per­
`veloped monofilament line mower is
`forming some task which they erro­
`not included within the scope of the
`neously believe will not bring their
`standard and could be a substitute for
`hand or foot into the path of the blade.
`mowers using rigid or semi-rigid blades
`(2)
`Part 1205 is expected to eliminate
`under some conditions.
`or reduce the severity of about 60,000
`
`306
`
`TTI
`Exhibit 1008 - Page 9
`
`

`

`Consumer Product Safety Commission
`
`§1205.8
`
`Probable effect of the rule upon the
`ing mowers to be hard to push in grass
`(e)
`utility of the product. (1) The Commis­
`or to be unable to mow close to walls.
`sion finds that the probable overall ef­
`At the time of issuance of this rule,
`fect of the standard on the utility of
`mowers are available that will pass a
`mowers should be to increase their
`360° foot probe and others are available
`utility. In the first place, consumers
`that will pass rear and side foot prob­
`are likely to experience an increased
`ing without any significant loss of util­
`sense of security from having a safer
`ity caused by shielding. Therefore, the
`mower. A study of brake-clutch mow­
`Commission concludes that this re­
`ers conducted by the Federal Supply
`quirement will not adversely affect the
`Service (GSA) shows that almost all
`utility of mowers. Mowers with swing-
`users appreciated the safety features
`over handles, however, may be more
`on brake-clutch mowers. In addition,
`difficult to design in this regard, since
`by releasing the blade control and stop­
`120° at each end of the mower are sub­
`ping the blade, the operator can then
`ject to the foot probe requirement.
`travel over gravel or other surfaces
`However, since mowers meeting this
`without fear of thrown objects or of the
`requirement have already been built
`blade striking objects that might dam­
`without apparent loss of utility, the
`age
`the mower. Brake-clutch type
`Commission concludes that shielding
`mowers would also give an increase in
`can be designed so that there should be
`utility by virtue of enabling the oper­
`no loss of utility even for mowers with
`ator to use the clutch to prevent stall­
`swing-over handles.
`ing when the mower bogs down in
`(3) As required by section 9(b) of the
`heavy grass. On the other hand, there
`CPSA, the Commission, in considering
`may be some minor adverse effects on
`the issues involved in issuing a power
`utility caused by some aspects of com­
`lawn mower safety standard, has con­
`plying mowers. For example, in very
`sidered and taken into account the spe­
`heavy mowing conditions, there may
`cial needs of elderly and handicapped
`be some difficulty in engaging the
`persons to determine the extent to
`blade in a blade-clutch mower. (How­
`which such persons may be adversely
`ever, mowers that are currently on the
`affected by the rule. The Commission
`market that are not equipped with a
`has determined that there will be no
`blade clutch may have difficulty in
`significant adverse effect on such per­
`starting the engine in heavy grass.)
`sons as a result of this part 1205. In the
`Complying mowers may require slight­
`first place, the rule can affect only
`ly more time and a few additional ac­
`those persons who are physically capa­
`tions
`to operate. Since complying
`ble of using a power lawn mower. None
`mowers may have more electrical and
`of the rule’s provisions will make it
`mechanical parts than current mowers,
`more difficult to operate a mower that
`they may weigh more and require more
`complies with the standard. On the
`maintenance than current mowers. No
`contrary, complying mowers should be
`significant increase in mowing time is
`easier to use because the need for
`expected if a brake-clutch device is
`manually restarting the mower will be
`used to comply with the standard since
`less and because, if the mower uses a
`each engagement of the blade would re­
`brake-clutch to comply with the blade
`quire only a few seconds. The amount
`control requirement, use of the brake-
`of additional time and expense required
`clutch can reduce the tendency of the
`for maintenance, if any, will be depend­
`engine to stall in heavy grass. A l­
`ent on the design solution used. Such
`though a person’s ability to hold a de­
`disutilities are expected to be slight
`vice such as a blade control for a long
`and to be more than balanced by the
`period of time will decline with age,
`increased sense of security consumers
`the force required to hold the blade
`are likely to experience from having a
`control can be made low enough that it
`safer mower.
`will not be a problem during the length
`(2) During the development of the
`of time that it takes for consumers to
`rule, questions were raised about
`mow a lawn.
`whether changes in the shields neces­
`(4) After considering the possible ad­
`sitated by the foot probe requirements
`verse effects on mowers that could be
`would adversely affect utility by caus­
`caused by the standard and balancing
`
`307
`
`TTI
`Exhibit 1008 - Page 10
`
`

`

`§1205.8
`
`them against the increase in utility
`that is expected, the Commission con­
`cludes that, for p typical consumer, the
`increases in utility should more than
`offset any decreases.
`(f) Probable effect of the rule upon the
`cost of the product. The Commission es­
`timates that the retail price impact of
`the standard will be about $35 for the
`average walk-behind mower. Based on
`an average useful mower-life of about 8
`years, the additional annual cost to the
`purchaser is expected to average about
`$4.40. The probable effect of the stand­
`ard will differ on the various types of
`mowers within its scope. Percentage
`increases in price will vary from about
`a F percent increase for power-restart
`self-propelled mowers to about a 30 per­
`cent
`increase
`for gasoline-powered
`manual start push mowers. The costs
`attributable
`to
`individual
`require­
`ments of the standard are discussed in
`paragraph ⑴ of this section.
`(g) Probable effect of the rule upon the
`availability of the product. (1) The Com­
`mission finds that the standard is not
`expected to have a significant impact
`on the availability of walk-behind ro­
`tary mowers, since domestic produc­
`tion capacity appears to be sufficient
`to handle any increased demand for
`safety-related components or mate­
`rials. Although adapting some types of
`power mowers to the standard may be
`more costly than others, the effects of
`the standard on the price or utility of
`a particular category of power mowers
`are not expected to cause radical shifts
`in demand among types of mowers. The
`Commission finds that all types of
`power mowers subject to the standard
`will be available, although some, such
`as house-current-powered mowers, may
`increase their market shares becauses
`they can be brought into compliance
`with the standard at a lesser cost.
`⑵ Because some manufacturers may
`not revise their entire product line be­
`fore the effective date of the standard,
`individual mower manufacturers may
`initially have less varied lines than at
`present, but there should be no de­
`crease in the overall types and features
`of mowers available to consumers.
`(h) Alternative methods. (1) The Com­
`mission has considered other means of
`achieving the objective of the standard.
`For example, alternatives were consid­
`
`16 CFR Ch. II (1-1-12 Edition)
`
`ered such as hand probes, 44blade harm­
`less), tests, and blade control by engine
`kill but allowing manual restart. These
`alternatives have been rejected by the
`Commission as being either unfeasible
`or not as effective as the rule which is
`being issued.
`⑵ Similarly, the Commission has
`found no alternative means of achiev­
`ing the objective of the standard that
`it believes would have fewer adverse ef­
`fects on competition or that would
`cause less disruption or dislocation of
`manufacturing and other commercial
`practices, consistent with the public
`health and safety.
`(1) Unreasonable risk of injury. (1) The
`determination of whether a consumer
`product safety rule is reasonably nec­
`essary to reduce an unreasonable risk
`oi injury involves a balancing of the
`degree and nature of risk of injury ad­
`dressed by the rule against the prob­
`able effect of the rule on the utility,
`cost, or availability of the product. The
`factors of utility and availability of
`the products, adverse effects on com­
`petition, and disruption or dislocation
`of manufacturing and other commer­
`cial practices have been discussed
`above. The following discussion con­
`cerns the relationship of anticipated
`injury reduction and costs for various
`requirements of the standard. (See the
`report, Economic Impact of Blade Con­
`tact Requirements for Power Mowers,
`January 1979, for a detailed analysis of
`the possible effects of discounting and
`inflation on the computation of the
`quantifiable benefits associated with
`this regulation.)
`(2) The foot probe and related re­
`quirements are expected to reduce the
`number of blade contact injuries to the
`foot by 13,000 each year. It is not pos­
`sible to apportion this injury reduction
`among the respective requirements.
`The cost of these requirements is esti­
`mated to be about $4.00 per mower,
`mostly for redesign of the shields. The
`shield strength requirement is similar
`to a requirement in the existing vol­
`untary standard that is almost univer­
`sally complied with, and should com­
`prise only a small portion of the $4.00
`retail cost increase compared to pre­
`standard mow