Vol. 931 | 19 Oct 2016

As part of the rulemaking process required by Section 104(b) of the Consumer Product Safety Improvement Act of 2008 (CPSIA), the U.S. Consumer Product Safety Commission (CPSC) has proposed a new federal regulation: 16 CFR 1235 Safety Standard for Baby Changing Products. The rule proposes to adopt the existing ASTM standard F2388-16 Standard Consumer Safety Specification for Baby Changing Tables for Domestic Use, with a few modifications to the enhance the effectiveness of the standard based on gathered incident data.

A “baby changing product” according to the notice of proposed rulemaking (NPR), refers to changing tables and other changing products including contoured changing pads and add-on changing units. The ASTM F2388 defines a changing table as “an elevated, freestanding structure generally designed to support and retain a child with a body weight of up to 30 lb (13.6 kg) in a horizontal position for the purpose of allowing a caregiver to change the child’s diaper. Changing tables may convert from or to other items of furniture, such as, but not limited to, a dresser, desk, hutch, bookshelf, or play yard, may have pull-out or drop-down changing surfaces, and may provide storage for diapers and diaper products.”

The proposed 16 CFR 1235 modifies certain key requirements of the ASTM standard as follows:

  • Structural integrity testing has been revised to account for instances where consumers don’t use the secondary strap provided as well as instances of incorrect assembly of key structural elements using threaded fasteners.
  • Where provided, restraint systems need to comply with performance standards to ensure they don’t create hazardous conditions as a result of breakage or separation from initial installation.
  • Warning labels wording to emphasize the fall and suffocation hazards as well as requirements for warning label format and placement.

Certain significant features addressed by the ASTM F2388-16 standard include:

  • Stability of changing tables
  • Barriers and occupant retention
  • Entrapment in openings and shelves

The CPSC has proposed that the rule become effective 6 months after publication of the final rule in the Federal Register. Comments on the proposed rule can be submitted until December 13, 2016.

The proposed Rule can be viewed at: https://www.gpo.gov/fdsys/pkg/FR-2016-09-29/pdf/2016-22557.pdf


For questions, please contact Laxmi Ravikumar (laxmi.ravikumar@intertek.com, +1-630-209-9265).

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