May 29, 2020

On January 31, the Consumer Product Safety Commission Published a Request for Comments on an Evaluation of the CPSC Safety Standards for Full-Size and Non-Full-Size Baby Cribs (16 CFR 1219 and 1220)

DATES: Written comments should be filed on or before March 31, 2020.

SUMMARY:  The CPSC is conducting this review as mandated by Section 610 of the Regulatory Flexibility Act which requires a review within 10 years of when a Standard is issued, if the Standard has a significant economic impact on small entitiesl

The CPSC is seeking comments on:

  1. Safety and Effectiveness
    1. Are there any technological developments that would improve the full-size or non-full-size crib standards?  If so, what would be the impact on large or small suppliers?
    2. Could the standards be improved?  If so, how would this impact suppliers?
  2. Costs and Impacts—Suppliers
    1.  Are there any requirements of the current standards that are unduly burdensome?
    2.  How does the cost of compliance affect crib production?
    3.  What kinds of modifications did manufacturers have to make to comply with the standards?
    4.  Have new entrants come into the market since the standards were issued?  Did the standards presented any difficulties for new entrants?
    5.  Have any manufacturers dropped crib models or crib lines because of the standards?
    6. Was the impact of the standards reduced due to the longer effective date of childcare facilities?
    7.  Are any other small entities affected by these standards?
  3. Recordkeeping and Third Party Testing
    1.  Questions regarding the cost and time required to certify to the standards.
    2.  Are the recordkeeping requirements of the standards adequate, inadequate, or unduly burdensome?
    3.  How frequently do suppliers submit samples to third party testing organization to test conformity of their products?
    4. To what extent has third party testing replaced in-house testing, and therefore not substantially increased the costs to manufacturers?
    5.  Could changes be made in third party testing procedures that would reduce the burden to crib manufacturers while still assuring compliance with the standards?
  4. Clarity and Duplication
    1.  Are there any aspects of the standards that are unclear?
    2.  Do any parts of the standards duplicate or conflict with other federal, state, or local government rules?
  5. Outreach and Advocacy
    1.  Are any suppliers of cribs unaware of the CPSC standards?  How can the CPSC more effectively communicate the standards to those suppliers?
    2.  Are there any cribs as small child care facilities or public accommodation facilities that do not meet the standards?  What can the CPSC do the increase awareness of the standards?