April 5, 2023
We are writing to express our views on the Consumer Product Safety Commission’s (CPSC) proposed rulemaking on safety standards for non-full-size (NFS) baby cribs.
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 support the substantive revisions made to ASTM F406-22 to improve the safety of NFS cribs. The addition of a general requirement for cords and straps that can form a loop will reduce the risk of strangulation. We agree that this requirement should also apply to all parts of in-scope products. We also strongly support the expansion of the scope of the standards to include cribs for playing in addition to sleep, since this will reduce the number of potentially hazardous products that would be exempt from safety requirements.
However, we disagree with the statements that “a mattress is not required to be provided with a product if the product is designed exclusively for play and not for sleep and is intended to be used without a mattress. This change has no effect on safety.” According to Independent Safety Consulting, LLC, most suffocation deaths happen as a result of soft bedding being added to the play yard floor. Even when the crib is intended for play, it is likely that some adults will add a mattress or other soft bedding that will increase the risk of suffocation. That is why the statement, “This change has no effect on safety,” is inaccurate and is why NCHR encourages the CPSC to reconsider the proposal to exempt products from including a mattress or similar product with non-full-size cribs. It would be safer to require a mattress or other bedding that meets safety requirements but is not used, than to take the chance that an unsafe mattress or bedding will be added.