Vol. 1032 | 05 Jul 2018

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 approved a new federal regulation: 16 CFR 1235 Safety Standard for Baby Changing Products. The rule adopts the existing ASTM standard F2388 - 18 Standard Consumer Safety Specification for Baby Changing Tables for Domestic Use, with no modifications.

According to the ASTM standard, a “baby changing product” refers to changing tables and other changing products including changing table accessories, contoured changing pads and add-on changing units. The ASTM F2388 defines each of these baby changing products as below:

  • A changing table is “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.”
  • Changing table accessory is “an accessory that attaches to a crib or play yard designed to convert the product into a changing table typically having a rigid frame with soft fabric or mesh sides or bottom surface, or both.”
  • Contoured changing pads are “changing pads designed for use on an elevated surface which incorporates barriers to prevent a child from rolling off the changing surface.”
  • And an add-on changing units is “a rigid addition to or separate product used in conjunction with an item of furniture that provides barriers to prevent the infant from rolling off the product when a diaper is being changed.”

The notice of proposed rulemaking issued in September 2016 recommended adopting the then-current version of the ASTM standard, F2388 - 15, with modifications to better evaluate structural integrity issues, restraint systems and enhance the warning effectiveness. The ASTM F2388 - 18 version of the standard incorporates these recommendations from the CPSC and further strengthens them by better defining terminology in the standard; adding scissoring, shearing and pinching requirements; clarifying the application of the structural integrity requirements; and aligning the warning and labeling language with the ad-hoc task group recommendations.

Significant features addressed by the ASTM F2388 - 18 standard include:

  • Stability of changing tables
  • Barriers and occupant retention
  • Entrapment in openings and shelves
  • Requirements for self-folding steps

The CPSC-approved rule becomes effective on June 26, 2019, which is 12 months after publication of the final rule in the Federal Register. Baby Changing Products manufactured on and after this date shall meet requirements of this rule and additionally will also require certification per 16 CFR 1110 based on testing at a CPSC-approved third-party accreditation body (third-party lab) for 16 CFR 1235.

The final rule can be viewed at: https://www.gpo.gov/fdsys/pkg/FR-2018-06-26/pdf/2018-13556.pdf

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


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