The U.S. Consumer Product Safety Commission (CPSC) is seeking information regarding the safety benefits of crib bumpers to determine if there are hazards associated with these products—which often contain nonwoven components—as well as whether safety standards currently in place are adequate. Additionally, CPSC is seeking information on potential performance requirements, testing, or other standards that may reduce the risk of injury, if any, associated with crib bumpers.

CPSC is seeking these data based on a petition filed by the Juvenile Products Manufacturers Association under the Consumer Product Safety Act (15 USC 2051-2089). In its petition, JPMA called for the creation of a performance standard for crib bumpers distinguishing“hazardous ‘soft’ pillow-like” crib bumpers from “traditional” crib bumpers (see Federal Register May 24, 2013).  

The Commission granted JPMA’s petition, but adopted a broader framework, directing staff to examine the safety benefits and risks associated with crib bumpers; evaluate existing standards; identify test methods and performance requirements that reduce any identified safety risks; and consider all regulatory options for addressing any identified risk of injury associated with crib bumpers.
In granting the petition, CPSC initiated a rulemaking to determine: 1) the need for, and appropriate scope of, new regulations; and 2) whether crib bumpers pose a safety hazard to infants. If safety risks are detected, the CPSC would evaluate what performance standards or requirements could mitigate that risk.  

Interestingly, it appears that the significance of these research priorities is reversed within the commission. Wouldn’t it be more appropriate to determine if crib bumpers actually pose any safety risks to infants and then—only then—consider the need/potential scope of new regulatory requirements?   

That said, as part of this effort CPSC staff has been reviewing incident data to identify crib bumper features or characteristics that create a safety hazard. Commission staff is also evaluating existing safety standards that apply to crib bumpers and similar products. In addition, CPSC is independently testing various types of crib bumpers to determine if safety issues exist.

At this point the commission is seeking input from the public to supplement the data it has already collected.  CPSC notes that data regarding safety risks and benefits associated with various types of crib bumpers would be particularly helpful at this stage of its review and would also like to review the empirical basis of those data. Data on the effectiveness of existing safety standards are especially helpful according to the commission.

For nonwovens producers, CPSC is currently most interested in data related to “mesh-like” or other “breathable” materials to determine whether these materials present a risk of suffocation to an infant if the infant’s face is pressed into the material.  
The commission also wants to know the specific characteristics that make a bumper “breathable;” and to what extent, if any, these types of crib bumpers address the risk of suffocation. CPSC finds data and research supporting any such conclusions helpful .  

Similarly, the commission is seeking data that describe potential hazards associated with mesh-like bumpers or liners as well as “vertical bumpers” which, according to CPSC, are essentially a series of small bumpers that individually cover each crib slat and other bumper alternatives.

CPSC is calling for answers to several specific questions related to the JPMA petition and the overall safety of crib bumpers:
What test data or other information are available to identify the specific features or characteristics of a crib bumper that might contribute to a risk of suffocation?

What objective, repeatable test methods, procedures or measures exist to assess the firmness of bedding, mattresses, and other possible sleep surfaces?

To what extent can such tests, procedures or measures assess whether these materials present a risk of suffocation by smothering?
To what extent does the test device specified in Australian/New Zealand Standard Number AS/NZS 8811.1:2013 (“Methods of Testing Infant Products, Method 1: Sleep Surfaces--Test for Firmness,” which can be found at www.standards.co.nz) accurately, assess the potential risk of suffocation associated with a sleep surface?  

To what extent would a test to accurately and reliably identify hazardous soft bedding or sleep surfaces be relevant to vertically-mounted surfaces such as crib bumpers?

What safety benefits do crib bumpers offer to consumers?

What data are available to demonstrate such benefits?

What evidence is there to indicate that “rebreathing” of carbon dioxide occurs with crib bumpers and presents a risk of suffocation?

According to CPSC, the current U.S. voluntary standard covering crib bumpers is ASTM F1917-12 (“Standard Consumer Safety Performance Specification for Infant Bedding and Related Accessories,” available at www.astm.org/cpsc.htm) and includes a requirement that essentially limits the compressed thickness of crib bumpers to two inches.  

In its most recent call for data, CPSC is also asking if other standards include performance requirements for crib bumpers, and whether evidence exists to support the ASTM F1917-2 requirements. CPSC also wants to know what, if any, association exists between ASTM F1917-2 requirements and risk of infant suffocation.

Comments are due April 18, 2016, and can be submitted electronically through www.regulations.gov by searching under Docket Number CPSC-2012-0034. Please note that all comments submitted with be posted, without change, to www.regulations.gov.
This includes any personal identifiers, contact information, or other personal information.  CPSC specifically requests that confidential business information, trade secret information or other sensitive material be left out of any submitted comment.
More information:  Timothy Smith, Project Manager, directorate for Engineering Sciences, U.S. Consumer Product Safety, 301-987-2557; TSmith@cpsc.gov.