Vol. 1003 | 06 Dec 2017

As part of the rulemaking process under the Consumer Product Safety Act, the U.S. Consumer Product Safety Commission (CPSC) issued an advance notice of proposed rulemaking (ANPR) to initiate the rulemaking process and address the risks of death and injury associated with clothing storage units tipping over. The ANPR discusses the products, incident data, injury patterns, existing standards, and regulatory options being considered by the CPSC.

Clothing Storage Units or CSUs, as identified in the ANPR, are freestanding furniture intended for storing clothing. Although typically bedroom furniture, they may be used in other locations of the home. Examples of CSUs, as identified by the CPSC, include chests of drawers, bureaus, dressers, armoires, wardrobes, portable closets, and clothing storage lockers. CSUs do not include products that are permanently attached to or built into a structure or products that are not typically intended to store clothing, such as bookcases, shelves, cabinets, entertainment furniture, office furniture, or jewelry armoires.

The primary hazard patterns identified in the ANPR include:

  • Televisions tipping over along with the CSUs
  • CSUs tipping over when one or more drawers were open
  • Children climbing into or on the CSUs leading to tip-overs
  • Greater tip overs of CSUs in bedrooms and carpeted areas

Over the last several years, the CPSC along with CSU manufacturers have conducted several voluntary recalls of CSUs in addition to launching the Anchor It! educational campaign in June 2015.

The ANPR reviewed all international standards currently applicable to such clothing storage units and concluded that the two ASTM standards are the closest in addressing these issues but even those do not adequately address the hazards associated with CSUs.

The options listed by the CPSC for consideration in addressing the clothing storage units tipping over are:

  • A mandatory standard issued by the commission to address the hazards identified with CSUs
  • Relying on voluntary standards such as the ASTM F2057 and ASTM F3096 to address CSU tip-overs, if the industry compliance with these standards is substantial
  • Lastly, taking no regulatory action but continuing to rely on product recalls and educational campaigns such as Anchor It! to reduce the number of injuries and fatalities

The CPSC in the ANPR is seeking comments on various topics, including following key areas:

  • Data about risk of injury associated with CSUs
  • Appropriate scope of a mandatory standard and definition of a CSU
  • Effectiveness of the stability warning and tip-over restraint devices (TRD) requirements being considered
  • Information or studies about how characteristics of the flooring surface under a CSU may impact the stability and effectiveness of a stability standard
  • Effectiveness of voluntary or international standards at reducing the risk of injury associated with CSU tip-overs
  • Expected impact of technologies or design changes that address tip-over injuries on manufacturing costs or wholesale prices
  • Potential impact of design changes to address CSU stability on consumer utility

Comments on the ANPR can be submitted until January 29, 2018.

The ANPR can be viewed at: https://www.gpo.gov/fdsys/pkg/FR-2017-11-30/pdf/2017-25779.pdf  

For questions, please contact Laxmi Ravikumar (laxmi.ravikumar@intertek.com, 630-209-9265) or Dr. Pratik Ichhaporia (pratik.ichhaporia@intertek.com, 847-212-8273)


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