Art Harris' treatment of hot tubs [Weekend, September 28] took a casual approach to a potentially serious consumer hazard . . . Mr. Harris . . . suggested that people should "never complain about the [hot tub] temperature," and that while water heated to only 105 degrees F. is friendly but not too friendly, "110 degrees is generally agreed to be therapeutic."

Our experts certainly do not agree with Mr. Harris' assessment. Specifically, we are convinced that water temperatures in hot tubs should never exceed 104 degrees F. Commission staff is informed of 11 deaths which have occured nationwide since hot tubs became widely popular; three of the deaths this year have involved drownings (alcohol-related) in water heated to approximately 110 degrees. In addition, even Mr. Harris' "friendly'" label for 105 degrees is dangerously misleading. Soaking in a hot tub with water heated to only a degree higher can raise human body temperature to the point of heat stroke (or impairment of the of the body's ability to regulate its internal temperature); both conditions can be fatal even to fully healthy adults.

CPSC staff has prepared some of its own rules for hot tub use, and we feel it would be appropriate for you to help us set the record straight . . . SAFETY RULES FOR HOT TUBS: 1. Hot tub temperature should never exceed 104 degrees F. A temperature of 100 degrees is considered safe for a healthy adult. 2. Children under five should not be exposed to water temperatures above 98 degrees F. 3. Like drinking and driving, excessive drinking and hot-tubbing don't mix well. Excessive drinking during hot tub use can cause sleepinees, possibly resulting in drowning. 4. Pregnant women beware! Soaking in water above 102 degrees F. can cause fetal damage during the first three months of pregnancy (resulting in the birth of a brain-damaged or deformed child). Pregnant women should stick to the 100 degrees-maximum rule. 5. Before entering the hot tub, consumers should check the water temperature with an accurate thermometer; hot tub thermostats may err in regulating water temperatures by as much as four degrees. 6. Persons with a medical history of heart disease, circulatory problems, diabetes or blood pressure problems should obtain their physician's approval before using hot tubs. 7. Persons taking medications which induce drowsiness, such as tranquilizers, antihistamines or anticoagulants, should not use hot tubs. 8. To be on the safe side, no one should use a hot tub while alone.

The staff of the U.S. Consumer Product Safety Commission currently is working with staff from the National Swimming Pool Institute and the International Spa and Hot Tub Institute as they develop voluntary standards for the manufacture, installation and use of hot tubs. These standards, which are expected to reflect many of the above safety warnings, may take effect as soon as April 1980.