21 Oct 2016
Mandatory Safety Standards for Baby Changing Products under Consideration
The Consumer Product Safety Commission is accepting input from interested parties by 13 December on a proposed rule that would establish a mandatory safety standard for baby changing products. The proposed rule would incorporate by reference into the CPSC regulations ASTM F2388-16, Standard Consumer Safety Specification for Baby Changing Tables for Domestic Use, and impose more stringent requirements for structural integrity, restraint system integrity, and warnings on labels and in instructional literature.
ASTM F2388-16 applies to baby changing tables and other changing products. The standard defines “changing tables” as “elevated, freestanding structures” designed “to support and retain a child” with a body weight up to 30 pounds (13.6 kilogrammes) for the purpose of a diaper change. Changing tables may convert to other furniture pieces, such as dressers or play yards, and they may have storage or other pull-out or drop-down features. ASTM F2388-16 also applies to other changing products, such as contoured changing pads and add-on changing units that are sold separately for use on furniture products other than changing tables. Contoured changing pads have barriers designed to keep children up to 30 pounds on the pad for diaper changes on elevated surfaces, while add-on changing units are used with pieces of furniture to provide changing surfaces and/or barriers to keep children on the products during diaper changes. The majority of changing tables and add-on changing units are made of wood, while contoured changing pads are generally made of a combination of synthetic-covered foam. Changing tables come in various designs, some of which include drawers, cabinets or retractable stairs.
The CPSC believes that ASTM F2388-16 requirements, particularly regarding barriers, adequately address the risks that restraint systems are designed to mitigate. Accordingly, the agency is not proposing a more stringent requirement to mandate the presence of restraint systems on baby changing products. However, the incident data suggest that when a restraint system is present caregivers expect it to be effective and are likely to rely on it, which means that any such restraint systems must function effectively when included on a product. Accordingly, the CPSC is proposing to require any restraint systems provided with a baby changing product to be secured on a CAMI dummy and pulled in four directions anticipated during normal use with a 30-pound force. To pass this performance standard, straps and buckles must not break or separate from baby changing products more than one inch from their initial adjustment positions.
Based on the incident data, the CPSC also believes that a more stringent standard for structural integrity than what is currently in ASTM F2388-16 would further reduce the risk of injury from collapses and falls from baby changing products. To identify requirements that would address these hazards, Commission staff reviewed incident data, evaluated design features common in baby changing products involved in incidents and tested various baby changing products. Based on this information, Commission staff developed in co-operation with ASTM two provisions regarding threaded fasteners and secondary support straps to improve the structural integrity of baby changing products. Additionally, CPSC staff developed requirements for warnings in labels and instructional literature to address these issues.
Specifically, the proposed standard would (i) prohibit the use of threaded fasteners on key structural elements assembled by consumers; (ii) require a means of preventing manufacturer-installed metal threaded fasteners used in key structural elements from loosening (such as with lock washers); and (iii) require a means of preventing manufacturer-installed metal inserts in key structural elements from loosening (such as by gluing). The CPSC is proposing these limits for key structural elements such as primary changing surface supports and side, end, base and leg assemblies to address the stability of components that support the weight of occupants.
Moreover, the CPSC is proposing to adopt the structural integrity testing required in ASTM F2388-16 but modify the test to specify that consumer-installed secondary support straps not be installed for the test. The Commission notes that given that consumers often do not install secondary support straps or install them incorrectly, products should be tested without consumer-installed secondary support straps attached. The CPSC would also establish additional content and form provisions for on-product warning labels and parallel requirements for instructional literature as well as various miscellaneous requirements, such as a ban on components attached by screws from separating more than 0.04 inches (1 mm) after structural integrity testing.
Section 104 of the Consumer Product Safety Improvement Act of 2008 requires the CPSC to promulgate consumer product safety standards for a range of durable infant or toddler products. These standards must be substantially the same as applicable voluntary standards or more stringent than the voluntary standard if the Commission determines that more stringent requirements would further reduce the risk of injury associated with the product. As of 12 October, the CPSC had issued standards for bassinets and cradles, bath seats, bed rails (portable), bedside sleepers, full-size cribs, non-full-size cribs, infant swings, infant walkers, play yards, strollers and carriages, toddler beds, hand-held infant carriers, frame child carriers, portable hook-on chairs, and soft infant and toddler carriers. As of that date standards had not yet been adopted for infant sling carriers, infant bath tubs, infant bouncer seats, baby changing products, children’s folding chairs, stationary activity centres, gates and other enclosures for confining a child, high chairs and booster seats, although the Commission had issued proposed standards for some of these products (i.e., infant bath tubs, infant bouncer seats, high chairs, baby changing products, and children’s folding chairs and stools).