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Big Wireless Warns Shareholders:

Microwave Radiation Causes Health Harm and

Insurance Companies Will Not Cover Harms Caused By Smart Meters and 5G

The health effects of Smart Meters and all devices producing microwave radiation are well known.

See www.JamesRobertDeal.org/demand-that-seattle-ban-smart-meters-and-5g.

Insurance companies, including Lloyds of London, have a specific exclusion, and will not insure against radio frequency induced health effects. The standard business Some insurance companies will not cover fires, caused by radio frequency technologies, including Smart Meters. The standard business policy explicitly excludes coverage for damage caused by surges, and business owners must pay extra for an endorsement.

Big Wireless acknowledges that they can be sued and have no insurance coverage for health harms – which will come, because the damage is cumulative.

Also included is from Consumer Product Safety Commission, which is now looking into

specific and related issues with radio frequency technologies.

https://ehtrust.org/key-issues/electromagnetic-field-insurance-policy-exclusions/

https://ehtrust.org/key-issues/cell-phoneswireless/telecom-insurance-companies-warn-liability-risk-go-key-issues/

https://www.cpsc.gov/s3fs-public/Report%20on%20Emerging%20Consumer%20Products%20and%20Technologies_FINAL.pdf

Electromagnetic Field Insurance Policy Exclusions

https://ehtrust.org/key-issues/electromagnetic-field-insurance-policy-exclusions/

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Electromagnetic Field Insurance Policy Exclusion Are The Standard

Electromagnetic Fields Are Covered in “Pollutant” Policy Enhancements

Due to the high risk that electromagnetic (EMF) field exposure poses, most insurance companies do not cover electromagnetic fields and have very clear “electromagnetic field exclusions.” EMFs are classified as a “pollutant” alongside smoke, chemicals and asbestos. If you want insurance that will cover EMFs you have to purchase additional “Pollution Liability” or “Policy Enhancement” coverage.

“The Electromagnetic Fields Exclusion (Exclusion 32) is a General Insurance Exclusion and is applied across the market as standard. The purpose of the exclusion is to exclude cover for illnesses caused by continuous long-term non-ionising radiation exposure i.e. through mobile phone usage.” CFC Underwriting LTD in London, the UK agent for Lloyd’s

See examples of “electromagnetic field policy exclusions” and of “pollution liability” policies which do cover- at additional cost- electromagnetic fields. Please be sure to scroll down to the end to see videos and other insurance documents that discuss the risk of EMF exposure.


California State University Risk Management Authority (CSURMA) Self Insured Program

“We will not pay for loss or damage caused by or resulting from any of the following:

Artificially generated electrical, magnetic or electromagnetic energy that damages, disturbs, disrupts or otherwise interferes with any: (1) Electrical or electronic wire, device, appliance, system or network; or (2) Device, appliance, system or network utilizing cellular or satellite technology. But if fire results, we will pay for the loss or damage caused by that fire if the fire would be covered under this coverage form.

For the purpose of this exclusion, electrical, magnetic or electromagnetic energy includes but is not limited to: (1) Electrical current, including arcing; (2) Electrical charge produced or conducted by a magnetic or electromagnetic field; (3) Pulse of electromagnetic energy; or (4) Electromagnetic waves or microwaves. “

Portland Oregon Public School Insurance: GENESIS INSURANCE COMPANY

Pg 30.” Exclusions: This insurance does not apply to:

Bodily injury, personal injury, advertising injury, or property damage arising directly or indirectly out of, resulting from, caused or contributed to by electromagnetic radiation, provided that such loss, cost or expense results from or is contributed to by the hazardous properties of electromagnetic radiation. This includes any costs for the actual or threatened abatement, mitigation, or removal.”

Coverage Part B School Board Legal Liability: Various provisions in this Coverage Part restrict coverage. Read the entire Coverage Part carefully to determine rights, duties and what is and is not covered.

Pg 48 Exclusions: This insurance does not apply to any loss:

“8. Bodily injury, personal injury, advertising injury, or property damage arising directly or indirectly out of, resulting from, caused or contributed to by electromagnetic radiation, provided that such loss, cost or expense results from or is contributed to by the hazardous properties of electromagnetic radiation. This includes any costs for the actual or threatened abatement, mitigation, or removal.

Cost or expense arising directly or indirectly out of, resulting from, caused or contributed to by electromagnetic radiation, provided that such loss, cost or expense result from or are contributed to by the hazardous properties of electromagnetic radiation. This includes any costs for the actual or threatened abatement, mitigation, or removal.”

NATIONAL RIFLE ASSOCIATION OF AMERICA Carry Guard™ Declarations and Policy Illinois Union Insurance Company is a Chubb® Company

“This insurance shall not apply to…S. Pollution, and 1. any claim relating to the actual, alleged or threatened discharge, dispersal, release or escape of “pollutants” however caused or whenever or wherever happening;

or 2. any request, demand or liability to test for, monitor, clean up, remove, contain, treat, detoxify or neutralize “pollutants”, whether or not any of the NRA (SECTION 1m) 05 17 Page 5 of 10 foregoing are or should be performed by the “individual insured member” or by others.”

“Pollutants” means any electromagnetic transmission or fields, or any solid, liquid, gaseous or thermal irritant or contaminant, including smoke, vapor, soot, fumes, acids, alkalies, chemicals and wastes, including medical waste. Waste also includes materials to be recycled, reconditioned or reclaimed.

City of Ann Arbor Michigan Insurance Policy: Electromagnetic Radiation Exclusion

In this policy declaration, the electromagnetic radiation exclusion is part of several exclusions to exposures such as asbestos, lead, mold, and nuclear energy. The electromagnetic radiation exclusion not only excludes mitigation and harm from electromagnetic radiation but also excludes paying for the defense of “any supervision, instruction, recommendation, warning or advice given or which should have been given in connection with bodily injury, property damage, abatement and/or mitigation etc.

Canadian ProSurance Architects & Engineers Policy

In 2015 The General Exclusions section of their Canadian ProSurance Architects & Engineers Policy Document places EMF on the same footing as Asbestos: a total exclusion on liability for all EMF radiation.

“GENERAL INSURANCE EXCLUSIONS: Electromagnetic fields directly or indirectly arising out of, resulting from or contributed to by electromagnetic fields, electromagnetic radiation, electromagnetism, radio waves or noise.”

Updated Zurich Community Care Liability Insurance

“We will not pay anything under this policy, including claim expenses, in respect of: Electromagnetic fields any liability of whatsoever nature directly or indirectly caused by, in connection with or contributed to by or arising from electromagnetic fields (EMF) or electromagnetic interference (EMI)”

BIICL Product Liability Forum Insurance Perspectives on Product Liability

“Standard: Pollution, Asbestos, Electromagnetic fields

Due to potentially catastrophic losses and high clean up costs, product liability insurance contracts frequently exclude, whether partially or completely, the insured’s liability for asbestos, pollution and contamination, radiation and electromagnetic fields.

Most UK product liability insurance contracts implement the wording, either in its original or an adapted form, recommended by the Association of British Insurers to exclude liability for gradual pollution or contamination (such as long standing leaks from pipes or tanks).

This wording excludes all liability for pollution or contamination other than that caused by “a sudden identifiable unintended and unexpected incident which takes place in its entirety at a specific time and place during the period of insurance”.

South China Insurance Commercial General Liability Insurance Electrical/Electromagnetic Field/Radio Frequency Radiation (EFL/EMF/RFR) Exclusion Clause 101.07

“This exclusion applies, but is not limited, to any injury, damage, expense, cost, loss, liability or legal obligation to test for, monitor, abate, weaken, control or take any other remedial action with respect to EMF’s , EFL’s or RFR’s. “

ICW Group Exclusion Clause

“Electrical, magnetic or electromagnetic energy that damages, disturbs, disrupts or otherwise interferes with electrical or electronic wire, device, appliance, fixture, system or network. For the purposes of this exclusion, electrical, magnetic or electromagnetic energy includes, but is not limited to: a. Electrical current, including arcing; b. Electrical charge produced or conducted by a magnetic or electromagnetic field; c. Pulse of electromagnetic energy; or d. Electromagnetic waves or microwaves;”

REINS American Institute of Marine Underwriters LIABILITY EXCLUSION CLAUSE (2015)

“Health Hazard or Occupational Disease as defined in the original policy. In the absence of these terms being defined in the original policy, they shall be defined cumulatively as follows: C7.1. Any loss, damage, injury or expense directly or indirectly caused by or arising out of: asbestos; tobacco; coal dust; polychlorinated biphenyls; silica; silicosis; benzene; lead; talc; dioxin; mold; pesticides or herbicides; electromagnetic fields; pharmaceutical or medical drugs/products/substances/devices; or any substance containing such material or any derivative thereof.”

SUN General Insurance

“This policy does not cover any liability, loss, cost or expense directly or indirectly arising out of, resulting from, caused or contributed to by exposure to magnetic electric or electromagnetic fields or radiation however caused or generated.”

Great American Insurance Group – A Special Environmental Liability Insurance Policy Is needed to cover electromagnetic radiation

“This insurance covers bodily injury, property damage, legal expenses and clean-up costs resulting from pollution conditions associated with a covered location on a claims-made basis.”

“The definition of pollutants includes mold, legionella, electromagnetic fields and methamphetamines.”

A&M Insurance for Medical Professionals – No Coverage for Electromagnetic Fields

“GENERAL INSURANCE EXCLUSIONS: Electromagnetic fields directly or indirectly arising out of, resulting from or contributed to by electromagnetic fields, electromagnetic radiation, electromagnetism, radio waves or noise.”

AT&T Mobile Insurance

AT&T Does Not Cover Damage Caused by Pollutants, Now Including Electromagnetic Fields

“Exclusions:

  1. Loss caused by or resulting from the discharge, dispersal, seepage, migration, release or escape of Pollutants
  2. “Pollutants” means: Any solid, liquid, gaseous, or thermal irritant or contaminant including smoke, vapor, soot, fumes, acid, alkalis, chemicals, artificially produced electric fields, magnetic field, electromagnetic field, sound waves, microwaves, and all artificially produced ionizing or non- ionizing radiation and waste. Waste includes materials to be recycled, reconditioned or reclaimed.” (pg. 4)

Penn National Insurance, “Commercial Liability Umbrella Coverage Form”

“Bodily injury” or “property damage” arising out of any liability loss, cost or expense directly or indirectly arising out of, or resulting as, a consequence of “electromagnetic radiation”.

Abu Dhabi National Insurance Company Workman’s Compensation Insurance Policy

“Other Exclusions: Any claim bringing of or attributed to electromagnetic fields…”

The Hartford, “EXCLUSION – ELECTROMAGNETIC HAZARD”

“The following exclusion is added: This insurance does not apply to: Electromagnetic Hazard….”

Mutual of Enumclaw Policy Changes, Edition 9-96 – Pollution Exclusions

“Pollutant or pollutants mean any solid, liquid, gaseous or thermal irritant or contaminant, including:

  1. smoke, vapor, -soot, fumes, acids, alkalis, chemicals;
  2. radioactive matter, including electromagnetic fields or electromagnetic radiation;
  3. petroleum, or petroleum products in any form;
  4. asbestos or substances containing asbestos;
  5. lead or substances containing lead;
  6. waste, including materials to be recycled, reconditioned or reclaimed.”

Verizon Insurance: Protects The Phone But Not the Person

“Coverage Excludes Pollution.”

Pollution is defined as “The discharge, dispersal, seepage, migration, escape or presence of pollutants. Pollutants means any solid, liquid, gaseous, or thermal irritant or contaminant including smoke, vapor, soot, fumes, acid, alkalis, chemicals, artificially produced electric fields, magnetic field, electromagnetic field, sounds waves, microwaves, all artificially produced ionizing or non-ionizing radiation and/or waste.”

Pollution Liability Policies

New Day Underwriting CCONTRACTOR’S POLLUTION LIABILITY

Contractor’s Pollution Liability (CPL) is intended to provide pollution liability coverage for any type of contracting operation. … Broadened definitions of pollution conditions to include mold, bacteria, viral matter, electromagnetic fields (EMF) and biological waste.

Vanner Specialty Risk, Vanner Insurance Agency, Pollution Liability Coverage Options

Additional Policy Enhancements

Pollutants broadly defined including:

  • Fungus & Legionnaire’s Disease, Electromagnetic Fields, Low Level Radioactive Material, Medical & Infectious Wastes

Delta Insurance Environmental & Pollution Liability Insurance for Service Industries

“Pollution incident means the discharge, emission, seepage, migration, dispersal, misdelivery, release or escape of: a. any solid, liquid, gaseous or thermal irritant or contaminant, including smoke, vapors, soot, fumes, acids, alkalis, chemicals, hazardous substances, petroleum hydrocarbons, medical, infectious and pathological waste; b. low level radioactive waste; c. microbial matter; d. legionellapneumophila; e. medical waste; and f. waste materials; and, g. electromagnetic fields;”

Federated Electromagnetic Field Liability

“Federated offers an Electromagnetic Field Liability policy to provide coverage for this exposure that is unique to rural electric utilities.

Electromagnetic Field Liability coverage specifically insures the member utility for any bodily injury, property damage or devaluation of real estate that results from electromagnetic field lawsuits.

Standard Features provided by Federated’s Electromagnetic Field Liability policy include:

  • Claims-made coverage
  • Coverage for devaluation of real estate
  • No deductible for claims other than devaluation of real estate
  • Devaluation of real estate carries a $10,000 deductible”

MARSH: ELECTRONIC MAGNETIC FIELDS RISKS AND EXPOSURES AND POTENTIAL INSURANCE COVERAGE

“In Marsh’s experience the London markets are generally mixed in their approach to EMFs. Some will not provide any cover at all if a client has even a remote exposure but will remain silent i.e. providing insurance coverage by not excluding EMF risks from current insurance policies in all other instances. Others will only remain silent and never offer positive insurance cover or will provide positive cover ex US or remain silent across the board depending on the risk. This situation has not changed for several years. Although the insurance situation depends on the industry sector and details of the exposure, in general, cover is available in the London market on a claims-made, annual aggregate limit (with costs included in the limit) basis.”

Commercial property changes: The CSR Advisor October 2008 Edition

“Under the revised forms, the insurer will not pay for damage caused by artificially generated electrical, magnetic, or electromagnetic energy that damages, disturbs, disrupts, or otherwise interferes with any electrical or electronic wire, device, appliance, system, or network or any such device, etc., utilizing satellite or cellular technology.

“Electrical, magnetic, or electromagnetic energy” includes electrical current, including arcing; electrical charge produced or conducted by a magnetic or electromagnetic field; pulse of electromagnetic energy; or electromagnetic waves or microwaves. The insurer will continue to pay for any loss caused by fire that results from any of these. “

Insurance Materials on Mitigating Risk

Central Mutual Insurance Company

In the video below, Central Mutual Insurance Company reviews the risks of cell tower radiation.

The Radiofrequency (RF) Radiation Awareness Program for the Construction Industry
By The Center for Construction Research and Training

Aware of the risks of cell tower radiation and other safety issues related to loose safety regulations, The Center for Construction Research and Training together with the Roofing r2p Partnership and the RF Radiation Work Group, have developed the Radiofrequency (RF) Radiation Awareness Program for the Construction Industry, intended to raise construction contractors’ and workers’ awareness of the potential risk, how to identify the hazard, and steps to work safely.

Powerpoint Presentation: Radiofrequency (RF) Radiation Awareness Program for the Construction Industry Overview

Hazard Alert Card: RF Radiation – An invisible danger (available in Spanish)

Full details of the program are found at The Center for Construction Research and Training Website.

Read the Safety and Health Magazine article on the Program at Construction safety group aims to raise awareness of RF radiation exposure

Kaiser Permanente Insurance

Kaiser Permanente Insurance has funded research into the area and has posted research results on their website. See below some examples of information they post.

In-Utero Exposure to Magnetic Fields Associated with Increased Risk of Obesity in Childhood, Kaiser Permanente July 27, 2012

“Pregnancy is a critical developmental stage that is among the most vulnerable periods to environmental exposures,” said De-Kun Li, MD, PhD, a perinatal epidemiologist with the Kaiser Permanente Northern California Division of Research in Oakland, Calif., and the lead author of the study. “These findings indicate that electromagnetic fields, from microwave ovens to countless wireless devices, may be contributing to childhood obesity risk. This finding could have implications for possibly reducing childhood obesity and better understanding the obesity epidemic. Like any scientific discoveries, the results need to be replicated by other studies.”

Study Finds Exposure to Magnetic Fields in Pregnancy Increases Asthma Risk, Kaiser Permanente August 1, 2011

“In this study, we observed a dose-response relationship between mother’s MF level in pregnancy and the asthma risk in her offspring. In other words, a higher maternal MF exposure during pregnancy led to a higher asthma risk in offspring,” Dr. Li said.
In this new study, the researchers also found that two known risk factors for asthma, maternal history of asthma and being the first-born child, exacerbated the MF effect on the asthma risk. “This finding further supports the MF-asthma association,” said Dr. Li.

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Cell Phones Wireless Companies Warn Shareholders About Future Financial Risks From Electromagnetic Radiation

https://ehtrust.org/key-issues/cell-phoneswireless/telecom-insurance-companies-warn-liability-risk-go-key-issues/

Below we have a slide show of Telecom warnings followed by Insurance Companies who do not insure for electromagnetic fields. In fact, electromagnetic fields are considered “pollutants”. We hope you will download these slides and share them widely.

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Click here to download a PDF of this presentation

Most insurance companies exclude coverage of harm by electromagnetic fields

ARKANSAS INSURANCE ELECTROMAGNETIC FIELD

“This insurance does not apply to any liability, damages, loss, injury, demand, claim or “suit” that arises out of, or allegedly arises out of, exposure to or the presence of “electromagnetic fields and/or electromagnetic radiation” whether such “pollutant” is alone or combined with any other substances or factors, whether included in a product or otherwise. This exclusion applies regardless of whether such exposure occurs within or outside a building.”

Insurance Companies offer special coverage called an environmental insurance product for EMFs.

EMF’s are defined as a “pollutant” by many insurance companies requiring special risk coverage. Read the Willis insurance company article on EMF’s entitled, “Electromagnetic Fields: More than just an eyesore.”

“Owning, buying or selling a property with EMFs nearby can turn into a financial disaster – particularly as more science and studies further demonstrate rising health concerns in addition to potential diminution in value claims.”

“The warning in your smartphone” by Dr. Anna Young published by Ferris University of Sydney Business School

Dr. Anna Young‐Ferris published an article in The Responsible Investment Association of Australia:

“Contingent liabilities that arise from the threat of litigation for smartphone manufacturers and service providers are one of the major investment risks. So much so that telco companies could be the next wave of ‘sin stocks’.”

Read it here.

Geovital: A review of the UNSW Sydney ‘faculty of law’ program: Risks, regulations and liability around exposing other people to wireless technology EMF radiation

The educational program at the University of New South Wales (UNSW) was aimed at lawyers, school principals, union representatives and others with an interest in radiation exposure, its legal ramifications and liability. This seminar was the first of its kind to be held in Australia and attracted professionals from across the country. Presentations were made by the following experts on various subjects related to radiation exposure. Read it here

Lawyers give presentations which include the electromagnetic radiation exclusion.

See Powerpoint Slide #13 from “An Assessment of Current Products, Risks, Coverages and Claims in Cyber Coverage Mary-Pat Cormier Bowditch & Dewey, LLP

News Reports:

Business Insurance: Insurers exclude risks associated with electromagnetic radiation

Examiner.com: Lloyds of London and the smart meter exclusion

Risk Management:The Broadening Scope of Pollution Legal Liability Insurance

Ask Jon Eakes: Lloyds of London bails out of the cell phone health debate

CONSUMER PRODUCTS SAFETY COMMISSION

https://www.cpsc.gov/s3fs-public/Report%20on%20Emerging%20Consumer%20Products%20and%20Technologies_FINAL.pdf

2.1 Smart Technology and the Internet of Things Smart-enabled devices are changing the ways consumers use everyday products and what they expect from them. Smart home devices, such as thermostats, light fixtures, and security systems (including smoke and carbon monoxide (CO) alarms) anticipate needs and send alerts. Smart technologies are finding their way into an array of consumer products, such as toothbrushes, tennis rackets, refrigerators, garage doors, and gas grills. When consumer products–from doors and windows, to home appliances–have sensors and an Internet capability that make them uniquely identifiable and accessible to the consumer from anywhere, and when these products can exchange messages with other products, irrespective of the manufacturer, you have the Internet of Things (IoT). Smart technology offers both product safety opportunities (e.g., automatic product registration, increased recall effectiveness) and challenges (e.g., hacking susceptibility, failed software updates that affect performance).

3.2 Internet Home-Based Smart Appliances and Security Systems Homeowners are increasingly investing in intelligent or smart technologies. Various homebased smart technologies offer streamlined processes, intended to reduce time, costs, manual efforts, and energy inefficiencies with suites of automated devices. One of the first smart technology offerings, and a top reason for continued growth in home technology, was based in household security solutions to protect family health and property from fire and CO hazards, and intrusion. A smart home security system’s advantage over a standard standalone device includes alerting the home occupant to a burglary, high CO levels, or a fire event, even if the occupant is not within the sounding alarm’s range. In the last several decades,

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the expansion of home security began to include the connectivity of devices into a system for monitoring and communication for fire suppression, alerting first responders, and the remote accessibility of home via video surveillance. Newer home security technology continues to add functionality to smart security systems. Home monitoring and automation technology has expanded to meet the monitoring needs of the home’s vulnerable older, disabled, and younger occupants. The advanced technologies enable remote monitoring of home occupants to ensure their safety in arrivals, departures, and activities.10 Occupant activities can be sensed and recorded into Internet data logging and analysis systems that can provide a distress signal to first responders and keep homeowners aware of the activities going on in their homes at all hours. Specifically targeted smart technologies for older adults are available as passive or active sensors, monitoring systems, environmental control systems, and electronic aids to daily living. These technologies assist older adults in living independently longer and with less reliance on family members or paid caregivers. Examples of such systems’ features include monitoring or alerts prompting the resident to take daily medicine, turn off the stove, close the blinds, or attend to visitors at the door. A remote family member can also track the routines and activities of older adults. Critical vital signs can be monitored through devices like a smart shirt, which can provide data (e.g., heart rate, electrocardiogram, respiration, temperature) to a remote family member or physician.11 New home-based networks can interconnect many products (e.g., security sensors, cameras, thermostats, smart plugs, lights, entertainment systems, locks, appliances). The independent design of each component represents a potential problem for homeowners. The connection and control of each smart and connected product is individual, without regard to a centralized network. In this product-centered paradigm, each Internet-ready household appliance has a separate control scheme, often with very little internal security. These appliances’ logic controllers enable data connections and communications, but are not necessarily designed to be secure.12 Each smart device represents an opening to hackers or software failures that can interfere with the device’s basic operation. One potential hazard is that a homeowner may believe that an alarm is seemingly functional, yet through software bugs or intentional interference, the safety device is not responsive to conditions like rising CO levels, and does not alert the household. Beyond the software and data security, electronic disturbances in the home environment also may prevent proper product operation. With more home appliances and devices using interconnected wireless communications, the possibility of electromagnetic interference (EMI) increases. Current surges, voltage spikes, or an increase in the EMI noise level may interfere with the functionality of the appliance or alarm system. Electromagnetic signaling has two interference modes to consider. The incoming signal may be distorted by another electronic device, or the output signal amplitude may distort another device’s incoming data signal. CPSC could work through the products’ associated voluntary standards to ensure that, not only do the products operate safely, but the products also do not adversely affect the operation of other devices.

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3.3 Software as a Component Part (Softwarization) Smart watches, smart phones, smart appliances, smart fabrics, smart cars, robots, drones, the “things” with the potential for interconnection appear unbounded, and the associated embedded data communications and processing are seemingly ubiquitous. One common theme that runs through these modern devices and applications is software. This “software-enabled concept,” according to Antonio Manzalini, Chair of the Institute of Electrical and Electronics Engineers (IEEE), is being called “softwarization.”13 Softwarization attempts to make consumers’ lives easier by automating routine tasks, anticipating consumer wants, and enabling new capabilities. For example, smart watches and phones help consumers stay connected to the Internet and to each other. Smart appliances allow consumers to check the status of their appliances, and even turn them on and off remotely. Smart fabrics can enhance athletic performance, monitor vital signs, or light up and change color for aesthetic reasons. Over the past 40 years, CPSC has worked with stakeholders to develop mandatory and voluntary standards for consumer products, and frequently, their component parts. However, beyond the tangible materials, an essential part of all smart products is software. Along with the softwarization of consumer products comes an increasing risk of hazard to consumers related to software. These hazards could manifest in software that operates incorrectly (e.g., a bug creates an abnormal operating condition, malware changes the software function, an unforeseen input leads to an abnormal operating condition), or fails to operate when a response is required (e.g., a safety monitoring system does not respond when a hazardous condition is detected). A challenge currently facing the CPSC is that there is no standard for the testing and certification of software as a component part of consumer products. With the increasing role software plays in an ever-expanding list of products, we can expect the potential consumer hazards associated with software to increase. CPSC currently does not have expertise on staff to evaluate software as a component part in consumer products. The agency may wish to consider securing software engineering and evaluation skills as an added means of protecting consumers.

Sincerely,

James Robert Deal , Attorney & Broker
James
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