The Consumer Product Safety Commission has been ineffective in reducing product-related injuries to consumers and may not be able to survive as an independent agency, according to an internal commission report.

The 170-page document, obtained by The Washington Post, is sharply critical of the commission's record since it was created by Congress five years ago. The document is presently being circulated among top CPSC staffers for comment.

Many officials who have seen the draft report said privately that they were amazed at some of the findings.

"Overall consumer product-related injuries requiring emergency medical treatment have increased by 44 percent in the CPSC'S five-year history," the report states. It adds, however, that at least some of the increase is due to a more sophisticated injury reporting system.

According to the report, injuries treated in hospital emergency rooms jumped from 6,284,954 in 1973 to 9,055,220 last year.

Although the report documents some achievements of the fledging and politically embatled agency, itbasically presents a scathing chronicle of failure to live up to its congressional mandate.

The report states that the agency was given four purposes by the Consumer Product Safety Act, under which it was created:

"Protect the public against unreasonable risks of injury from consumer products - and ultimately to prevent injuries, help consumers evaluate the comparative safety of products, minimize conflicting state and local safety regulations, and promote safety research."

"Up to now," the report states, "the CPSC has not pursued three of these four purposes very energetically." And, the report says, the agency doesn't have a very good record on the one it has pursued (protecting the public from injury.)

"In almost five years," the report states, "the CPSC has issued only three safety standards under its enabling legislation. Of these standards - swimming pool slides, matchbooks and architectural glass - the first two have often been criticized as poor product selections . . . anyone clase to the CPSC will acknowledge that it has had problems in those areas."

The report offers a variety of explanations for poor performance by the CPSC, including "political or leadership disagreements among the commissioners . . . tensions between staff and commissioner . . . staff performance . . . the effects of having no permanent Executive Director for so long."

But, the report adds, "It is not the purpose of this plant to evaluate these arguments.

The study points out that the National COmmission on Product Safety, in 1970, issued a report citing several consumer product hazards and calling for the creation of what was to become the CPSC. At that time, the report states, the NCPS listed 16 "unreasonable hazards" and 17 other "unfinished business" items which should have become the first objects of CPSC actions.

"Of the 33, only one (architectural glass) became a mandatory standard under the CPSA," the report states. It added, however, "Most of the rest have been or are now the objects of agency action."

Clearly, the report states, the commission has had some successes. According to CPSC figures, hundreds of deaths and thousands of injuries were prevented by CPSC-set safety standards for toys, packaging of aspirin and poisons to keep them out of the hands of children, flammability of sleepwear, and construction of cribs.

Still, the opinion of those "outside" the agency, according to the report, are not very positive. In addition to the obvious complaints from special interest groups like businessmen who want less regulation and consumer leaders who want more, the report found other recurring themes in statements on its performance from a number of sources:

Few people consider product safety to be a top priority among consumer issues; the CPSC should try to do fewer things, but do them better and safety responsibilities are best left to the individual.

Looking to the future, the report contains a section ominously named "The Sunset Question." Under federal "Sunset law" provisions, an agency not serving "an important purpose" should be dismantled, "residual functions should be transferred elsewhere, and the resource saved should be spent on other federal priorities."

The report suggests these alternatives for the future of the CPSC: "Consolidation with other health and safety agencies in a new, larger agency; absorption of the CPSC within another existing health and safety agency; and continuation of the CPSC as an independent agency."

While it makes no recommendations, the report lists some advantages to the first two alternatives.

Merging the commission with other agencies chould result in greater efficiently should all federal health and safety projects fall under one administrator. "Resources could be allocated to those which are the most cost-effective," it states.

But there are also problems with a consolidation including the risk of a deemphasizing product safety.

Should the CPSC want to remain independent, "it should be prepared to justify this conclusion by defining its goals and long-term strategies," the report states.