June 12, 2020
National Center for Health Research’s Comments on Consumer Product Safety Commission’s Proposed Safety Standard for Crib Bumpers/Liners
[Docket No. CPSC-2020-0010]
We are writing to express our views on the Consumer Product Safety Commission’s (CPSC) proposed rulemaking on safety standards for crib bumpers and mesh liners.
The National Center for Health Research is a nonprofit think tank that conducts, analyzes, and scrutinizes research, policies, and programs on a range of issues related to health and safety. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
We strongly urge the CPSC to ban the sale of crib bumpers and liners. The known risks of crib bumpers far outweigh any potential benefits. While these products have not demonstrated any clear benefits, there is evidence that they can cause serious injury, including death.1 We agree with a 2017 CPSC report, which states:
“The best evidence-based advice for creating a safe sleep environment for newborns recommends a bare crib or bassinet that is free from all cushioned or padded pillow-like objects—Bare is best.”2
We also support a ban on mesh liners in addition to a ban on padded crib bumpers, given that 13% of the non-fatal incidents (such as slat entrapments) and concerns reported to CPSC involved a mesh liner.
The proposed rule is aimed at reducing the risk of death and injury caused by crib bumpers by preventing the sale of crib bumpers that pose a three-fold or higher increase in the risk of Sudden Infant Death Syndrome (SIDS). Since crib bumpers offer no benefit to babies, any increase in the risk of SIDS, suffocation, entrapment, or entanglement is unacceptable. How would one justify a 2-fold increase in SIDS, or even a 50% increase in SIDS? When there is no benefit, why should any additional risk of a baby’s death be considered acceptable?
Although CPSC commissioners have previously strongly advised consumers to discontinue the use of padded crib bumpers,3 many consumers are unaware of these risks and falsely believe that crib bumpers could not be sold if they were not safe. In stores, consumers would be likely to be told by sales staff that the products comply with CPSC safety standards. Descriptions of crib bumpers for sale online are misleading about safety, and they would be likely to be even more misleading if CSPC initiated the proposed rule. For example, here are three current ads on Amazon.com that refer to the safety of crib bumpers:
- “Padded with high density microfiber filling (330 GSM), it will protect your baby’s head from crib rails and prevent arms, legs from getting caught. Meanwhile, it will stop baby from chewing on crib slats, which contain lead and other ingredients.” https://www.amazon.com/TILLYOU-Breathable-Standard-Microfiber-Polyester/dp/B077HQSWL7/ref=sr_1_5?dchild=1&keywords=crib+bumpers&qid=1591394675&sr=8-5
- “BREATHABLE MESH: Made of lightweight, breathe-through mesh without any padding to restrict airflow.” https://www.amazon.com/BreathableBaby-Classic-Breathable-Mesh-Liner/dp/B0013FGWD0/ref=sr_1_6?dchild=1&keywords=crib+bumpers&qid=1591394675&sr=8-6
- “Reasonable Thick and Soft: Baby bumper for cribs are combined with 100% microfiber cover and filling microfiber up to 330gsm. Crib liners padded will protect your baby’s head from the crib rails and prevent arms, legs from getting stuck.” https://www.amazon.com/Biloban-Almohadillas-protectoras-para-cuna/dp/B07P6236C3/ref=sr_1_8?dchild=1&keywords=crib+bumpers&qid=1591394675&sr=8-8
In fact, it seems likely that updated safety standards would be considered proof that the bumpers are safe; we think parents would be shocked to learn that it only means that the bumpers are less than 3 times more likely to cause SIDS. Inevitably, keeping crib bumpers on the market sends a very misleading message to parents and caregivers.
We acknowledge that CPSC is proposing a broad definition of crib bumper/liner to encompass both traditional padded crib bumpers as well as mesh liners, and given the known safety risks and lack of benefits we strongly urge a ban on all products that would be considered part of this category.
If the CPSC does not implement such a ban, the agency will be responsible for any deaths subsequently caused by bumpers or liners, and should at least include language in its rulemaking that explicitly protects bans put into effect by state or city governments.
National Center for Health Research can be reached at firstname.lastname@example.org or at (202) 223-4000.
- American Academy of Pediatrics. Choosing a Crib. Healthychildren.org. https://healthychildren.org/English/ages-stages/prenatal/decisions-to-make/Pages/Choosing-a-Crib.aspx. May 2014.
- Midgett JD. Cluttered Cribs and Infant Safety: Policy Implications of Selling and Using Padded Crib Bumpers and Messaging about Safe Sleep Environments for Babies. Bethesda, MD: U.S. Consumer Product Safety Commission; 2017:15. https://www.cpsc.gov/s3fs-public/CBStatement.pdf?dhFXWQNHUqQ2yV4xuY654JrJ3K0Towc
- Kaye EF, Adler RS, Robinson MS, and Mohorovic JP. Joint Statement of Chairman Elliot F. Kaye, Commissioner Robert S. Adler, Commissioner Marietta S. Robinson and Commissioner Joseph P. Mohorovic Recommending Parents and Caregivers Not Use Padded Crib Bumpers. Bethesda, MD: U.S. Consumer Product Safety Commission; 2016:1. https://www.cpsc.gov/s3fs-public/Joint%20Statement%20on%20Padded%20Crib%20Bumpers%20FINAL%2011.3.16.pdf