Button battery safety - Assessment of regulatory options - Consultation paper - Australian Competition and Consumer Commission

Response 609956436

Introduction

3. What is your organisation or profession?

Organisation / profession

Victoria Poisons Information Centre

Consultation Paper Questions 1 - 7

1. The ACCC considers the status quo and proposes three options to improve the safety of button batteries. Which is your preferred option and why do you prefer it to the others?

Option 3 simply because it is the most likely to reduce the potential for harm.

2. What effect do you believe each of the proposed options will have in saving lives and reducing severe injuries caused by button batteries?

This is difficult to quantify, however restricting access to any potentially harmful product (whether it be a battery / drug / poison) is a proven effective method of reducing the likelihood of harm.

Warnings and information do are important, but will not necessarily be read or understood by all consumers.

3. Provide comment on the ACCC’s essential requirements for secure battery compartments, child-resistant packaging and warnings and information. Are there any additional requirements that should be included?

Secure, restricted access to the button battery within any product is likely to be most effective, combined with child-proof packaging of seperate button batteries.

Consistent warnings provided at point of sale may obviously be difficult to achieve.

4. In relation to the requirement for secure battery compartments in which button batteries are only accessible with the use of a tool, do you consider that the use of a ‘tool’ should include the use of a coin? Why/why not?

Accessing a button battery using a coin is easier than having a compartment that requires a dedicated screw driver. In addition coin-accessible compartments often require less than a single 360 movement to open. Ideally all compartments would be secured by a screw that required a tool and greater than one full rotation to open.

5. Do you supply products that currently meet the essential requirements for secure battery compartments, child-resistant packaging and warnings and information? If not, which requirements do your products not meet and why?

6. Provide comment on the ACCC’s proposed information standard for warnings and information to be made available at point of sale. Are there any additional requirements that should be included for products sold online, or for unpackaged products supplied to consumers?

The proposed information standard appears comprehensive.

Unpackaged consumer goods obviously pose a greater risk in terms of the ability to provide information. Another option would be to have a requirement for an adhesive warning label to be applied over the battery compartment, so that the battery could not be accessed or replaced without deliberate removal of the label.

Consultation Paper Questions 8 - 14

8. Do you agree with the proposed exemption for hearing aid devices and associated zinc air batteries? Please explain your reasons. (See section 5.2)

I agree, for the reasons already stated in the consultation document.

10 . What are the likely costs to implement each of the requirements (design changes, child resistant packaging, labelling), and what do you consider is the likely effect on prices for consumers?

This is beyond my area of expertise, but I would presume that consumer costs would increase.

12. Provide comment on the transition period for the proposed options. (See section 7)

Suggested duration of transition period seems appropriate.