Bunk Beds Business Guidance

CPSC business guidance for manufacturers and importers regarding compliance with the full-size crib standard and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).

Federal law requires that bunk beds comply with the bunk bed standard and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).

Manufacturers and importers of children's bunk beds must certify in a Children's Product Certificate (CPC) that the bunk beds comply with the standard and the additional requirements after the bunk beds have been tested for compliance at a CPSC-accepted, third party laboratory.

 

Manufacturers and importers of adult bunk beds must certify in a General Certificate of Conformity (GCC) that the bunk beds comply with the standard after the bunk beds have been subjected to testing or a reasonable testing program to ensure compliance. All of these requirements are reviewed in greater detail atwww.cpsc.gov/cpsia.

 

What is a bunk bed?

A bunk bed is a bed with the bottom of its mattress foundation more than 30 inches above the floor. The mattress foundation is the base or support on which you place the mattress. The ends of a bunk bed are the upright parts at the head and foot of the bed to which you attach the side rails.

 

What is the purpose of the bunk bed rule?

This rule seeks to prevent the risk of deaths and injuries of children from being trapped between an upper bunk and a wall, in openings below the guardrails, or in openings in the ends of bunk beds.

 

Where can I find the requirements for bunk beds?

The requirements for adult bunk beds can be found at 16 CFR Part 1213, and the requirements for children's bunk beds can be found at 16 CFR Part 1513.

 

What does the bunk bed rule require?

Guardrails:

  1. Bunk beds must have at least two upper bunk guardrails, with at least one rail on each side. Lower bunks with mattress foundations that are 30 inches or less from the floor do not have to have guardrails.
  2. The guardrail on the side of the bed next to a wall or on the side opposite to a ladder must run continuously from one end of the bed to the other. If the guardrail does not attach to an end of the bed, the gap between the end of the guardrail and the nearest end of the bunk bed cannot be greater than 0.22 inches.
  3. A guardrail on the side of the bed away from the wall does not have to run continuously from end to end of the bed, BUT the distance between either end of the guardrail and the end of the bed nearest to it cannot be greater than 15 inches.
  4. Guardrails must be attached to the bunk bed with fasteners that must be released before the rails can be removed, OR the rail or fastener must be designed to move in two or more different directions, one after the other, to release them.
  5. The tops of the guardrails must be no less than 5 inches above the top of the mattress.
  6. With no mattress on the upper bunk, any space between the bottom of the guardrail and the top of the mattress foundation must not let the wedge block pass through freely. See the illustration of the wedge block below.


Bunk Bed Ends:

  1. No opening in either end of the upper bunk that is above the mattress foundation can let the wedge block pass through freely.
  2. When the thickest mattress and mattress foundation recommended by the manufacturer are used, the top of each end of the upper bunk must extend at least 5 inches above the top of the mattress, and that 5-inch margin of safety must extend at least half of the distance between the corner posts of each end.
  3. No opening in the headboard or footboard of the lower bunk below the mattress foundation of the upper bunk and above the mattress foundation of the lower bunk shall permit the wedge block to pass through freely - UNLESS the opening also allows a rigid 9-inch sphere to pass through it freely.
  4. Any opening in the headboard or footboard of the lower bunk below the mattress foundation of the upper bunk tested with the wedge block must also be tested for the risk of neck entrapment if the opening lets the 9-inch sphere pass though freely.

 

How do you test a bunk bed for entrapment hazards?

For detailed information on testing bunk beds, see 16 CFR §§ 1213.4 and 1513.4.

With no mattress on the bed, use the wedge block to probe spaces between the guardrail and upper bunk mattress foundation and openings in the upper and lower bunk ends. Place the wedge in the position in which it is most likely to pass through the space or opening, and then use the hook to pull the nose of the wedge into the space or opening. When testing spaces between the guardrail and upper mattress foundation, pull the wedge gradually, and sustain a force of 33 foot-pounds for 1 minute.

If the wedge block passes through any opening in the lower bunk end freely, try to pass a 9-inch diameter rigid sphere through that opening. If the sphere passes through freely, test the opening for neck entrapment.

The test is repeated after positioning the thickest mattress and mattress foundation

 

How do you test for neck entrapment?

The test for neck entrapment uses a specially designed probe that simulates a child's head and is inserted into each opening according to a precise procedure. Because of the detail involved in performing the test, the test procedure is not summarized here. For more detailed information, please refer to 16 CFR §1213.4(c)(3) or §1513.4(c)(3), or contact the Office of Compliance.

 

Are there any standards that apply to bunk beds?

ASTM F1427-96, a voluntary standard titled, "Standard Consumer Safety Specification for Bunk Beds," contains other requirements for the design and performance of bunk beds.

 

Are there any additional requirements for bunk beds?

Yes. Bunk beds for children may not have sharp points or edges. (See 16 CFR §1500.48 and 16 CFR §1500.49. Third party testing is not required for these requirements.)

 

What are the additional requirements for bunk beds required by the Consumer Product Safety Improvement Act of 2008?

Bunk beds that are designed or intended for children 12 years of age or younger are subject to surface coating requirements, lead and phthalate content limits, testing and certification, and tracking label requirements. These requirements are discussed below:

  • Surface Coating Limit: Children's bunk beds may not be painted with paint that contains more than 0.009 percent lead.
  • Lead Content Limit: Children's bunk beds cannot contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
  • Phthalate Content Limits: Given that the bottom bunk of a bunk bed can be intended to facilitate sleep by children three and younger, children's bunk beds cannot contain more than 0.1% of the following phthalates: di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl butyl phthalate (BBP). They also may not contain more than 0. 1 percent of (diisononyl phthalate (DINP), diisodecyl phthalate (DIDP), or di-n-octyl phthalate (DnOP) while an interim statutory ban of these phthalates remains in effect.
  • Testing and Certification: Children's bunk beds, like all products that are designed or intended primarily for children 12 years of age or younger, must be tested by an accredited and CPSC-accepted third party conformity assessment body for compliance with applicable children's product safety rules. Based on that testing, a domestic manufacturer (or importer) of children's bunk beds must issue a Children's Product Certificate (CPC) indicating that the product complies with those rules. Adult bunk beds require a General Certificate of Conformity (GCC). A GCC is a document that certifies, based on a test of each product or a reasonable testing program, that the product complies with all statutes, regulations, rules, bans, or standards under any law enforced by the Commission.
  • Tracking Labels: Bunk bed requirements call for a specific warning label AND a label or marking that provides the name and address of the manufacturer or importer, model number, and month and year of manufacture. Similarly, Section 14(a)(5) of the CPSA requires a children's product and its packaging to have a tracking label or other distinguishing permanent mark. The tracking label, to the extent practical, requires basic information, including the source of the product, date of manufacture, and cohort information, such as a batch or run number. Due to the similarities of the label requirements, a single label that meets all the combined criteria may be used. In addition, bunk beds must be marked or labeled with instructions giving the proper size and thickness of the mattress and containing the specific warnings for safe use.



Where can I find additional information?

For more information on the requirements for bunk beds, contact the U.S. Consumer Product Safety Commission:

  • Office of Education, Global Outreach, & Small Business Ombudsman (Assistance in Understanding and Complying with CPSC Regulations): e-mail: Business@cpsc.gov; telephone: (301) 504-7999.
  • Office of Compliance (Enforcement Inquires): e-mail: sect15@cpsc.gov; telephone: (301) 504-7520.

To obtain copies of ASTM F1427-96, contact ASTM International at: www.astm.org or via telephone: (610) 832-9585.