Danger to human health or safety assessment for decorative lighting strings

Last updated: July 4, 2023

Table 3 was first published in July 2020 to consolidate information for regulated parties in an effort to increase openness and transparency regarding Health Canada's evaluation of products that pose a danger to human health or safety. While this entry was added to Table 3 upon initial posting of the table in July 2020, the danger to human health or safety was previously communicated by Health Canada to regulated parties. This assessment does not present new decisions, and is being published for clarity on the decisions made previously.

This assessment was originally completed when the consensus-based safety standard applicable to decorative string lights in Canada was CSA-C22.2 NO. 37-17. In January 2020, this standard was replaced with CSA-C22.2 NO. 37-20. This assessment has been updated to reference the new standard; the criteria addressing electric shock, burn or fire hazards are comparable in both standards.

Legislative background

The purpose of the Canada Consumer Product Safety Act (CCPSA) is to protect the public by addressing or preventing dangers to human health or safety that are posed by consumer products in Canada, including those that circulate within Canada and those that are imported. Any person who manufactures, imports, advertises, sells or tests a consumer product must comply with all applicable requirements of the CCPSA and its regulations. Paragraphs 7(a) and 8(a) of the CCPSA prohibit the manufacture, importation, advertisement or sale of any consumer product that is a "danger to human health or safety". The CCPSA defines the term as follows:

Danger to human health or safety means any unreasonable hazard — existing or potential — that is posed by a consumer product during or as a result of its normal or foreseeable use and that may reasonably be expected to cause the death of an individual exposed to it or have an adverse effect on that individual's health — including an injury — whether or not the death or adverse effect occurs immediately after the exposure to the hazard, and includes any exposure to a consumer product that may reasonably be expected to have a chronic adverse effect on human health.

Definitions

Decorative lighting strings

Lighting strings used indoor or outdoor for general, temporary, seasonal, or holiday decoration. Also known as decorative string lights or seasonal lights.

Electrical outlet

A connection to the alternating current (AC) mains electricity supply. Also known as electrical plugs, sockets, or receptacles.

Strain Relief

A form of physical protection for a wire where it enters a rigid device such as a plug, receptacle or lampholder. Reduces the possibility of a wire's insulation being damaged during use and exposing the live electrical parts within.

Resistance

All electrical conductors offer some resistance to the electricity flowing through them. This resistance results in heating of the conductor, and the higher the resistance, the more heating may occur.

Scope of affected products

Decorative lighting strings

Includes:

• Series connected lighting strings (which may also include series-parallel)
• Exclusively parallel connected lighting strings
• Lighting strings that contain screw-in bulbs
• Lighting strings that contain push-in bulbs of any colour
• Lighting strings that plug-in to an electrical outlet (e.g., Christmas tree lights)
• Decorative items pre-lit with lighting strings (e.g., artificial trees, wreaths, deer)

Excludes:

• Battery-operated lighting strings
• Lighting strings with transformers
• Solar-powered lighting strings

Hazards of concern

Decorative lighting strings with insufficient strain relief may result in exposed live parts and pose an electric shock hazard. Decorative lighting strings with excessive resistance may overheat and ignite flammable wires or lampholders (also known as lamp sockets) and pose a burn or fire hazard.

Incidents^{Footnote 1}

Health Canada is aware of 126 reports of incidents that occurred between June 20, 2011, and December 31, 2022, involving decorative lighting strings in Canada. Of the 126 reports, nine reported electric shock injuries and nine reported minor burn injuries.

Health Canada is aware of 1570 reports of incidents that occurred between 1980 and 2015 involving decorative lighting strings in the United States. Of the 1570 reports, 134 incidents reported a combined total of 259 deaths. There was a downward trend in reports of deaths caused by decorative lighting strings in the United States from 1980 to 2015. The United States Consumer Product Safety Commission (CPSC) attributed the decline of deaths to a high level of conformance of products to the safety improvements made over time to the UL 588 Standard for Seasonal and Holiday Decorative Products. The US data is from the CPSC's publicly available database: https://www.saferproducts.gov/PublicSearch

Under reporting of incidents is suspected because Christmas tree fires are common, and the cause is often difficult to link to decorative light strings.

Danger to human health or safety assessment

Danger to human health or safety considerations

Considerations for a product to pose a potential danger to human health or safety are outlined in Health Canada's Industry Guidance - "Danger to Human Health or Safety" Posed by Consumer Products. The main considerations assessed are:

1. Unreasonable hazard
2. Existing or potential hazard
3. Normal or foreseeable use
4. May reasonably be expected to cause
   1. Death
   2. Adverse effect on health

1. Unreasonable hazard

The consideration of unreasonable hazard includes the following components.

a. Inherent hazard

AC mains electricity is required for the product to function as intended and electricity has an inherent electric shock hazard associated with its use. Decorative lighting strings with insufficient strain relief may expose live parts and pose an electric shock hazard. Decorative lighting strings with excessive resistance may overheat and ignite flammable wires or lampholders and pose a burn or fire hazard.

b. Severity of hazard

Electric shocks may range in severity from minor to electrocution (death). Decorative lighting strings may overheat and ignite flammable wires or lampholders and pose a burn or fire hazard. Burn injuries from overheating depend on contact duration and are limited to the contact points between the user and the affected product. Decorative lighting strings overheating could result in a home fire or smoke inhalation injuries if there are flammable materials nearby.

c. Intended and foreseeable users

The intended users of decorative lighting strings are adults. Reasonably foreseeable users of decorative lighting strings include children.

d. Obviousness of hazard

Adults are expected to be more likely than children to recognize that exposed live parts on an electrical product poses an electric shock hazard. Users may be able to feel overheating decorative lighting strings and see smoke or fire before exposure to the hazard. Users would not be able to see how flammable the wires or lampholders are prior to a fire incident.

e. Social utility

Decorative lighting strings are typically used as seasonal or holiday decorations and to provide additional indoor or outdoor lighting using electricity all year long. Known incidents primarily occurred during the month of December. Other lighting fixtures using electricity could provide lighting. Other items could provide decorative value and in some cases lighting as well without the inclusion of lighting strings. A significant portion of the public engages in the cultural practice of decorating for seasons, parties, or holidays using decorative lighting strings. Decorative lighting strings may therefore have moderate social utility.

f. Available alternatives

Battery-operated lighting strings, decorative lighting products not incorporating lighting strings, and coloured bulbs in light fixtures are light-producing decorative items that are some of the available alternatives to decorative lighting strings.

g. Consensus-based safety standards or government regulations

The consensus-based Canadian national safety standard applicable to decorative lighting strings is CSA C22.2 NO. 37-20 – Decorative lighting products. This standard sets out criteria that address the electric shock, burn, or fire hazard, including but not limited to:

• DC resistance – clause 5.2.5.1
• Flame test (FT1) – clause 5.2.5.1 (for Type TXF or TXFW wire)
• Vertical flame test (VW-1 or FV2) – clause 5.2.5.1 (for Type CXWT wire)
• Lampholder needle flame test – clauses 5.1.4.3.7 and 6.4.8
• Strain relief test for wiring devices – clause 5.11.2

There are decorative lighting strings available in the Canadian marketplace that appear to conform to the applicable criteria outlined above. All electrical products that plug into an electrical outlet, including decorative lighting strings, are already required to be certified to the applicable Canadian national safety standard from the Canadian Electrical Code to comply with provincial and territorial legislation. That certification must be from a certification body accredited by the Standards Council of Canada and the certified product must carry the recognized certification mark of that certification body.

2. Existing or potential hazard

Incident reports from Canada and the United States indicate the presence of an existing or potential electric shock, burn, or fire hazard.

3. Normal or foreseeable use (including foreseeable misuse)

Normal or foreseeable use of decorative lighting strings with insufficient strain relief may result in exposed live parts and pose an electric shock hazard. It is foreseeable for consumers to come into close contact with the plugs of decorative lighting strings when installing or removing the product and receive an electric shock from touching exposed live parts.

Normal or foreseeable use of decorative lighting strings with excessive resistance may result in overheating. Overheating combined with flammable wires or lampholders could pose a burn or fire hazard and foreseeably result in a home fire or smoke inhalation injuries if there are flammable materials nearby. It is foreseeable for consumers to wrap or place decorative lighting strings around a highly flammable dry natural Christmas tree, wood railing, wood window, or near textile curtains.

4. May reasonably be expected to cause

a. Death

Decorative lighting strings overheating could result in a home fire or smoke inhalation injuries if there are flammable materials nearby. Home fires and smoke inhalation may reasonably be expected to cause death by asphyxiation from carbon monoxide or other combustion products.

It is therefore reasonable to expect that decorative lighting strings that do not conform to the applicable criteria outlined above to address the electric shock, burn, or fire hazard may cause death.

Health Canada is not aware of any deaths caused by decorative lighting strings in Canada.

b. Adverse effect on health

Exposed live parts may pose an electric shock hazard. Electric shocks may range in severity from minor to electrocution (death). Recent reports of incidents included minor electric shock injuries. Decorative lighting strings may overheat and ignite flammable wires or lampholders and pose a burn or fire hazard. Burn injuries from overheating depend on contact duration and are limited to the contact points between the user and the affected product. Recent reports of incidents included minor burn injuries. Decorative lighting strings overheating could result in a home fire or smoke inhalation injuries if there are flammable materials nearby. Health Canada is aware of Canadian reports of adverse effects on health associated with decorative lighting strings.

It is therefore reasonable to expect that decorative lighting strings that do not conform to the applicable criteria outlined above to address the electric shock, burn, or fire hazard may cause an adverse effect on human health.

If you require additional information regarding this Danger to Human Health or Safety Assessment, please contact a Health Canada Consumer Product Safety Office via email (hc.ccpsa-lcspc.sc@canada.ca) or telephone at 1-866-662-0666 (toll-free within Canada and the United States).