|Received:||10/28/2009 8:55:40 AM|
|Agency:||Federal Trade Commission|
|Rule:||16 CFR Part 305: Proposed Amendments to the Appliance Labeling Rule That Would Change the Existing Labeling Requirements for Lamp Products (Light Bulbs)|
Comments:Data about watts or wattage of a bulb are important to consumers at the point of purchase and at the point at which the bulbs are put in to a fixture because lighting fixtures (both fixtures built into buildings, such as recessed ceiling lighting) and table lamps are labeled stating that use of bulbs with a wattage greater than (whatever the amount) may cause a fire hazard. Making the watts / wattage of a bulb secondary to lummens will make it harder for people to make safe/accurate judgements about which wattage of bulb is safe to use in which fixture. Instead of putting the lumens at the top of the label, and wattage at the bottom, why not put them on consective lines so that the information relevant to safety is not made secondary to the info about cost of using the bulb over a period of time.