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Monday March 13, 2023

CPSC Guidance Would Make Child VSL Double Adult VSL

A child's value of statistical life (VSL) would be twice that of an adult's in a draft CPSC guidance on such calculations. Commissioners were slated to vote by March 14 on starting a 60-day comment period on the guidance. The initial VSLs – in 2021 dollars – would be $23.2 million versus $11.6 million.


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Updates would account for both inflation and the real income method used by Health and Human Services in its Guidelines for Regulatory Impact Analysis.


In application:

  • "CPSC will include a sensitivity analysis in its regulatory analyses that use both high and low estimates for adult and child VSLs."

  • "When estimating VSL for future years, CPSC will discount the resulting benefit values to reflect the time value of money, consistent with its approach for all cost and benefits estimates."

Besides general feedback, CPSC wants to learn:

  • Reactions to the criteria and studies the authors used and information about new ones.
  • Suggestions for alternative methods for age adjustments.
  • Reactions to using the guidance to estimate VSLs.
  • Suggestions for adjustments to the guidance.

The draft guidance is at The draft Federal Register notice to seek comments is at


In 2018 (PSL, 3/5/18), a literature review by CPSC staff found support for the idea of differing VSLs, opening the way to this two-value approach.