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Safe Sleep: Bedding, Pillows, Safety and More

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Bare is Best! Poster

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CPSC staff estimates that between 1992 and 2010 there were nearly 700 deaths involving infants 12 months and younger related to pillows and cushions placed in or near a baby’s sleep environment. Nearly half of the infant crib deaths and two-thirds of bassinet deaths reported to CPSC each year are suffocations caused by pillows, thick quilts and/or overcrowding in the baby’s sleeping space.

The safest place for a baby to sleep is in a safe crib. A safe crib is one that meets CPSC’s strong federal safety standards and is clear of clutter. That means no pillows, no heavy quilts, no thick blankets, no pillow-like stuffed toys or other large stuffed toys and no child carrying devices, recliners or sleep positioners.

Many parents are aware of the Back-to-Sleep Campaign to reduce the risk of SIDS. Putting your baby to sleep on his or her back also helps prevent suffocation. Be sure to always place your baby on his/her back on a tight-fitting, firm, flat mattress or any surface that comes with the bassinet and play yard. Crib mattresses need to fit tightly, too.

I use a pillow, why shouldn’t my baby?

Re-creation of baby doll in crib filled with pillows. Baby is between the two pillows.

This medical examiner re-creation shows a hazardous situation. Babies should not be placed to sleep on anything pillow-like or in a crib filled with items. Bare is Best.

Babies and adults are different. A pillow can block a baby’s nose and mouth and can cause a baby to suffocate. On average, there are 32 infant deaths a year on pillows used as mattresses or to prop babies’ heads. The majority of these deaths involve infants in their first three months of life.

Parents can safely start using pillows for children who are 1½ years old, about the same age at which parents can safely move children out of the crib and either into a toddler bed or onto a mattress on the floor.

No thick blankets? My baby will be cold.

If you’re worried about the temperature in your baby’s room, dress your baby in warm clothes. You can also put a thin blanket on your baby. Do not use thick blankets or quilts. Young babies can and do get their faces stuck in thick blankets and suffocate.

Should I use a ‘sleep positioning’ device?

No. CPSC and the U.S. Food and Drug Administration began warning parents in September 2010 to stop using sleep positioners. There is currently no scientific evidence supporting medical claims that have been made regarding these products. CPSC and FDA are aware of 13 reports of infants between the ages of 1 and 4 months who died when they suffocated in these positioners or when they became trapped between a sleep positioner and the side of a crib or bassinet. CPSC has also received dozens of reports of infants who were placed on their backs or sides in sleep positioners, only to be found later in potentially hazardous positions within or next to the sleep positioners.

A major concern is the use of these products to keep a baby on its side, which is an unstable position. Infants placed on their sides are more likely to flip onto their stomachs because their backs are pressed against the side of the sleep positioning product. Because these products are designed to keep a baby from changing positions, infants who end up on their stomachs are then unable to free themselves. Young infants can suffocate because they don’t have the neck strength to move their heads.

Is it safe to put a car seat, carrier, infant recliner or other item inside the crib with my infant in it?

No. This is not a safe practice. Many of these items can tip over when placed on top of an uneven surface such as a mattress. Babies have also flipped over the side of these products and become wedged between them and other items in the crib. Since 2003, CPSC is aware of at least 9 deaths of infants in car seats, carriers, infant recliners and bouncy seats that were placed on a soft surface such as a bed, crib, play pen, air mattress or sofa.

Can I put toys in the crib/play yard/bassinet?

An uncluttered sleeping space is the safest sleeping space for a baby. Again, Bare is Best.

Toys attached to the sides of a crib should be securely attached to a single side. Make sure the toy does not contain any cords or straps that could wrap around a child’s neck. Avoid hanging crib toys with protruding parts that a child can use to pull themselves up and out of the crib or from which small parts might detach.

Don’t fill your baby’s crib, play yard or bassinet with large toys or decorative or nursing pillows, thick blankets or comforters. This is particularly important for children who are 4 months and younger.

Is there anything I need to know about my baby monitor?

All baby monitors with cords and other corded items need to be placed at least 3 feet away from a crib. CPSC knows of seven deaths and three near-strangulations since 2002 involving video and audio baby monitor cords. The monitors and cords were placed within a child’s reach.

I use a bassinet. What should I look for in my bassinet to make sure it’s safe?

CPSC is working on a new bassinet safety rule. Before buying or borrowing a bassinet, check this bassinet recall list to make sure the product has not been recalled. Make sure to follow the bassinet’s setup instructions and be sure that all fasteners are secure, including all snaps and Velcro. Use only the mattress supplied by the manufacturer for your specific bassinet and make sure that you assemble the bassinet properly. Improper assembly can lead to baggy or collapsed sides, gaps and openings that are dangerous areas in which babies can get trapped.

Those play yard mattresses are so thin. Won’t my baby be uncomfortable on it?

Play yard mattresses are thin for a reason. The play yard is a flexible structure. Adding extra padding, foam or mattresses to the play yard can cause babies to suffocate in one of two ways:

  1. The baby can get his or her face stuck in the added mattress or other soft items or
  2. Because of the extra additions, the flexible sides of the play yard can be pressed out. This creates dangerous and deadly gaps between the side and the added material in which a baby can get trapped.

Use only the mattress that came with the play yard. Before buying or borrowing a play yard, check this playpen/play yard recall list to make sure that the product you are using has not been recalled.

Play yard with baby sleeping on back correctly; play yard with extra mattress that creates a gap.

A baby should be placed to sleep flat on the thin play yard mattress that came with a play yard, as at left. Gaps such as the one at right can be dangerous and deadly, leading to suffocation.

I don’t want my child to get out of the crib or play yard. Can I put a tent on it?

Once a child is able to stand, do not use a tent with the crib or play yard. Crib tents are not made for, nor intended to, keep children in cribs and play yards. Children have become tangled and trapped in tents that were used to try to keep them in cribs and play yards. CPSC has received at least 27 reports of incidents involving tents used on cribs and play yards, including one death and one near death. CPSC recalled crib tents in May 2012. Do not use the recalled tents.

I need to lift my baby’s head while he’s sleeping. Can I add extra bedding underneath the mattress to raise it?

Seek advice from your pediatrician or health care provider before placing your baby to sleep in a more vertical position. If your doctor advises you to raise a mattress, make sure that no gaps are formed anywhere around the perimeter of the mattress. Also, keep the angle low enough that your baby doesn’t roll or slide down the mattress.

Should I use a bumper pad?

Bare is best when placing a baby to sleep in a crib. By creating the toughest crib safety standards in the world and urging parents to keep pillows, quilts, heavy blankets, and sleep positioners out of the crib, CPSC has made great strides to ensure that babies and toddlers have a safe sleep. Agency staff has previously stated that overstuffed bumper pads can be hazardous and staff is currently re-examining the safety of all crib bumpers, in an effort to provide parents with our best advice. We respect the attention that a number of cities and states have given to the safety of bumpers, and we will continue to use the best science and data available to provide parents with advice that they can trust.

If I use a bumper, is there an age or developmental milestone when I should remove it?

As soon as your child can stand, remove the bumper pads and lower the crib mattressto its lowest position. Toddlers will use anything available to climb out of the crib. Children can fall out of the crib and/or get entangled in the bumper.

What else should I be aware of when setting up my nursery?

Beware of cords. Never put a crib, bed or furniture close to windows with corded window coverings, because children can climb on them, gain access to the cords, and strangle. CPSC recommends the use of cordless window coverings in all homes where children live or visit. In addition, keep baby monitor cords, lamp cords, telephone cords, and night light cords at least 3 feet away from the crib. Children can wrap the cords around their necks and strangle.

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This address for this post is: http://www.cpsc.gov/onsafety/2012/09/safe-sleep-bedding-pillows-safety-and-more/

A Letter to Dr. Montgomery on “Private Practice”

Dear Dr. Addison Montgomery,

On last week’s episode of “Private Practice,” we saw that you have a new baby. Congratulations on becoming Henry’s mom! As you’re learning, parenthood is life altering.

You’re clearly a mom who researches and finds the best for her baby, even supplying breast milk from a milk bank. As an obstetrician, however, we would expect you to have researched the latest information about crib safety as well.

Henry's cluttered crib on the ABC TV Show "Private Practice"

This screen grab from "Private Practice" shows baby Henry in his crib

Those blankets and pillows in the crib have to go. Henry doesn’t need the cushioning. His baby needs are different than adult needs like yours. CPSC staff estimates that between 1992 and 2010 there were nearly 700 deaths involving children 12 months and younger related to pillows and cushions. Nearly half of the infant crib deaths and two-thirds of bassinet deaths reported to CPSC each year are suffocations from a baby being placed on top of pillows and thick quilts or because of overcrowding in the baby’s sleeping space.

We are disappointed with the lack of research that went into creating Henry’s nursery, so allow us to help. We have a great video here that can teach you about how to put Henry to sleep safely. While you rightly placed Henry on his back, we did a double take through the TV for all the loose blankets and clutter in Henry’s crib.

In Henry’s — or any baby’s crib — bare is best. As a respected obstetrician watched in millions of homes around the country, we expect better.

Henry needs a firm, flat surface and nothing else.

Even though the pillow in the back of Henry’s crib looks small, pillows are a big problem in cribs. Pillows can block babies’ noses and mouths and can cause them to suffocate. On average, there are 32 infant deaths each year on pillows used as a mattress or to prop babies’ heads. The majority of these deaths are to infants in their first three months of life, just like Henry.

We’re guessing that you covered Henry with all those blankets in a well-meaning way, worried about his temperature. If his room is cold, dress him in warm clothes like footie pajamas. Do not use thick blankets. Babies can and do get their faces stuck in thick blankets and suffocate.

Thanks for taking the time to read and learn about how to make Henry’s crib safer for him. We hope he starts sleeping through the night for you soon!

Sincerely,

The U.S. Consumer Product Safety Commission’s Children’s Safe Sleep Team

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This address for this post is: http://www.cpsc.gov/onsafety/2012/05/a-letter-to-dr-montgomery-on-private-practice/

Running for Safe Sleep

Runners start the Frederick County, MD, Crib Crawl 5K on April 7, 2012.

Runners start the Frederick County, MD, Crib Crawl 5K on April 7, 2012.

This isn’t just any 5K. It’s a 5K for Safe Sleep. And it’s something you can replicate in your own community.

The photo above is from a recent 5K run in Frederick County, Md. The organizers called it the Crib Crawl 5K. Their mission? Raise money to purchase safe cribs for families who can’t afford a crib or bassinet.

Jackie Whalen, of Frederick County Child Protective Services, tells us that about 10 children died in sleep-related fatalities in Frederick County from 2008 through 2011.

“All the children died sleeping with adults in beds or in places that had too much bedding,” Frederick County social services administrative assistant Melissa Myers told the Frederick News Post.

This is a problem nationwide. Of the hundreds of deaths associated with unsafe sleep environments during the past 20 years, many involved pillows and cushions. Nearly half of the infant crib deaths and two-thirds of bassinet deaths reported to CPSC each year are suffocations because of pillows, thick quilts and overcrowding in the baby’s sleeping space.

The Frederick County deaths sparked the child welfare department to embark on a safe sleep education campaign in the county. “I was inspired by our prevention efforts, the passion of our staff members about Safe Sleeping and have always wanted to have a 5K involving child welfare issues,” Jackie Whalen told us.

If you’d like to organize Safe Sleep efforts in your community and need free materials, you can get them from us. Here are some ideas:

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This address for this post is: http://www.cpsc.gov/onsafety/2012/04/running-for-safe-sleep/

Play Yards: What Parents Should Know

Because of deaths and injuries associated with play yards, CPSC has started drafting mandatory safety standards for them. In fact, earlier this month the commissioners at CPSC voted unanimously to move forward with proposed rulemaking aimed at making play yards safer than ever before.

Play yards have been involved in about 50 deaths and about 2,000 non-fatal incidents, including 165 incidents that resulted in injuries such as cuts and bruises since November 2007. The majority of the infant deaths were 1-year-old or younger. New standards are aimed at reducing the risk of injury and death.

To protect your baby, know the risks. Deaths associated with play yards included children who climbed out of the play yard and drowned in a nearby pool. Caregivers should remember that play yards are meant for children who are less than 35 inches tall and who cannot climb out of the play yard. 

Other play yard deaths include entrapment from a collapsed play yard, strangulation from a looped strap hanging in the play yard and a child found entrapped between an unfolded mattress pad and the play yard floor liner.

Consumers should be especially careful about play yard attachments. Changing tables and bassinet attachments must be carefully installed. CPSC has received reports describing how the corner of bassinets detached from the frame of the play yard. Caregivers are reminded to review warning labels and instruction materials carefully when assembling play yards and play yard accessories, like bassinets. 

About 90% of incident reports describe the collapse of the play yard’s side rail. If the side rail collapses, a child can get their neck entrapped in the collapsed side rail, lose their footing and strangle. Side rail collapses also are dangerous because children can escape and may be injured outside the play yard.

Unfortunately, even a new federal standard can’t fully protect your baby from an unsafe sleep environment, so it’s up to you to keep the environment free of suffocation hazards.  The primary cause of play yard deaths is babies being placed in an unsafe sleep environment full of soft or extra bedding, such as pillows, quilts and comforters. Always remember a bare environment is best! 

Another leading cause of death is infants being placed face down. Babies should always be placed on their backs in a safe sleep environment such as a crib or play yard that meets current standards.

Caregivers also should ensure that play yards are placed away from window blind cords or computer cords that can fall into the play yard and strangle children inside.

To keep your baby safe check CPSC’s website for play yard and other nursery product recalls. Visit www.CPSC.gov/cribs for additional resources and safety information and sign up to get e-mail notification on recalls.

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This address for this post is: http://www.cpsc.gov/onsafety/2011/09/play-yards-what-parents-should-know/

The New Crib Standard: Questions and Answers

Earlier Version: March 4, 2011
Updated: July 15, 2011, Jan. 3, 2013

Since CPSC approved a new crib rule, your questions have been flowing into us. While most questions have revolved around the drop side, it’s important for you to know that the new standard affects far more than the drop side. A crib’s mattress support, slats, and hardware are now required to be more durable and manufacturers will have to test to new more stringent requirements to prove compliance.

Here are some of your questions along with answers:

General Questions | Consumers | Child Care Centers, Foster Homes, Churches, Hospitals | Manufacturers, Importers, Retailers | Retrofitting Cribs | Crib Warranties

GENERAL QUESTIONS

5 New Federal Requirements for Cribs

Click on the poster to print the 5 new federal requirements for cribs.

 

  • What is the new standard for cribs?Beginning June 28, 2011, all cribs manufactured and sold (including resale) must comply with new and improved federal safety standards. The new rules, which apply to full-size and non full-size cribs, prohibit the manufacture or sale of traditional drop-side rail cribs, strengthen crib slats and mattress supports, improve the quality of hardware and require more rigorous testing. The details of the rule are available on CPSC’s website at www.cpsc.gov/businfo/frnotices/fr11/cribfinal.pdf.

    The new rules also apply to cribs currently in use at child care centers and places of public accommodation. By December 28, 2012, these facilities must use only compliant cribs that meet the new federal safety standards.

  • What if I need to purchase a new crib prior to June 28, 2011?Some compliant cribs may be available before the required date. However, you will not be able tell if the crib is compliant by looking at the crib. So, you may want to ask the retail store or the manufacturer whether the crib complies with 16 CFR 1219, the new federal standard for full-size cribs or with 16 CFR 1220, the new federal standard for non-full-size cribs.
  • Is this new regulation simply a ban on all drop-side rail cribs?No, these are sweeping new safety rules that will bring a safer generation of cribs to the marketplace in 2011. CPSC’s new crib standards address many factors related to crib safety in addition to the drop-side rail. A crib’s mattress support, slats, and hardware are now required to be more durable and manufacturers will have to test to the new more stringent requirements to prove compliance.
  • Are all drop-side rail cribs “recalled” because of the new regulation?There has not been a specific “recall” of all drop-side cribs due to the new regulation. Instead, some manufacturers recently have recalled their cribs in cooperation with the CPSC because a specific defect or risk of harm has been discovered relating to a particular crib. Although these recalls are separate from CPSC’s new crib standards, traditional drop-side cribs will not meet the new crib standards that became effective on June 28, 2011, and cribs with traditional drop-sides cannot be sold after that date.
  • How do I know whether the specific crib that I own/use in my child care facility meets the new standards?You cannot tell from looking at a crib whether it meets the new standards. It is not likely that cribs in use before the Commission issued its crib rule in December 2010 will comply with the new standards. If you are considering purchasing new cribs that meet the standards, you may want to ask the manufacturer or retailer whether the crib complies with 16 CFR 1219 (the new standard for full-size cribs) or 16 CFR 1220 (the new standard for non-full-size cribs). Manufacturers are required to test samples of their cribs to the new standards and to certify that they comply with the new standards. They must provide this certification to the retailer.

    You can ask the manufacturer or retailer for a copy of the certificate of compliance that should indicate that the crib is certified to meet 16 CFR 1219 or 16 CFR 1220. Beginning June 28, 2011, all cribs manufactured or offered for sale, lease, or resale are required to meet the new crib standards.

  • Who will be enforcing the crib standards and what are the penalties for using cribs that do not meet the new standards?CPSC will be the main agency enforcing the new crib standards. The initial focus will be on manufacturers and retailers since they must comply with the new standards by June 28, 2011. Anyone who is covered by the new crib standards and does not comply commits a prohibited act under section 19(a)(1) of the Consumer Product Safety Act (CPSA). A person or company that knowingly commits a prohibited act is subject to possible civil penalties. States’ attorneys general also have authority to enforce the crib standards through injunctions.

 

CONSUMERS

 

  • As a consumer, what can I do if I have a drop-side crib?Some drop-side crib manufacturers have immobilizers that fit their cribs. Drop-side crib immobilizers are devices that are used to secure drop sides to prevent dangerous situations in which the drop-side either partially or fully separates from the crib. As part of a recall, CPSC staff works with companies to provide fixes, or remedies, for products. For drop-side cribs, that remedy has been immobilizers.

    Check the CPSC’s website for companies that have recalled their cribs and are providing immobilizers to secure the drop-side on the cribs. These immobilizers were evaluated and approved by CPSC staff for use with these particular drop-side cribs.

    If your drop-side crib has not been recalled, you can call the manufacturer and ask if they are making an immobilizer for your crib. Remember, though, that those particular immobilizers have not been tested or evaluated by CPSC staff for use with your specific crib.

    Note that a drop side crib, even with an immobilizer installed, will not meet the new CPSC crib standards.

  • Is a sturdy, non drop-side crib okay for a consumer to use?It is unlikely that your current crib will meet the new crib standards. The new standards require stronger hardware and rigorous testing to prove a crib’s durability. If you continue to use your current crib, you are encouraged to check the crib frequently to make sure that all hardware is secured tightly and that there are no loose, missing, or broken parts. Note that after December 28, 2012, child care facilities, family child care homes, and places of public accommodations, such as hotels and motels, must provide cribs that comply with the new and improved standards.
  • My drop-side crib has not been recalled, but I am worried about using it with my baby. Can I return it for a refund?Manufacturers and retailers are not required to accept returned drop-side cribs or to provide a refund if the crib has not been recalled.
  • Is it okay for me as a consumer to resell, donate or give away a crib that does not meet the new crib standards?A consumer should not resell, donate or give away a crib that does not meet the new crib standards, such as trying to resell the product through an online auction site or donating to a local thrift store. CPSC recommends disassembling the crib before discarding it.
  • Is the answer different if a piece (“immobilizer”) has been added to my drop-side crib to prevent the side from moving up and down?Consumers should not sell or give away a drop-side crib that has an added immobilizer because it still will not meet the new crib standards.
  • If I am unable to purchase a new crib, what can I do to keep my baby safe?If you continue to use your current crib, you are encouraged to:
        a. Check CPSC’s crib recall list to make sure that your crib has not been recalled.
        b. Check the crib frequently to make sure all of the hardware is secured tightly and that there are no loose, missing, or broken parts.
        c. If your crib has a drop-side rail, stop using that drop-side function. If the crib has been recalled, request a free immobilizer from the manufacturer or retailer (particular immobilizer will vary depending on the crib).
      d. Another option is to use a portable play yard, so long as it is not a model that has been recalled previously.

 

  • If a customer purchased a crib that was manufactured before June 28, 2011, but they return the crib for a warranty claim after June 28, 2011, must the replacement crib meet the new crib standards?

 

Yes. When a manufacturer (retailer or other supplier) provides a replacement crib for use beginning on the June 28, 2011, compliance date, the crib must meet the requirements of the CPSC’s new crib standards.

CHILD CARE CENTERS, FOSTER HOMES, CHURCHES, HOSPITALS

 

  • My child care center still has drop-side cribs. Are they in violation of the regulation?No, child care facilities, family child care homes, and places of public accommodation, such as hotels and motels, have until December 28, 2012, to ensure that the cribs used in their facilities meet the requirements of the CPSC’s new crib standards.

    After this date, places of public accommodation may no longer use traditional drop-side cribs or noncompliant cribs and must use cribs meeting the new federal safety standards.

    Parents should talk with management about the new standards and the facility’s plan of action for replacing the cribs. Parents also should make sure their baby is not being placed in a recalled crib.

    Note: Child care facilities, family child care homes, and places of public accommodation should not resell, donate or give away a crib that does not meet the new crib standards, such as trying to resell the product through an online auction site or donating to a local thrift store. CPSC recommends disassembling the crib before discarding it.

  • Are portable cribs or play yards affected by the regulation?The crib standards cover portable cribs, but not play yards. CPSC’s crib rule includes a standard for full-size cribs (16 CFR part 1219) and a standard for non-full-size cribs (16 CFR part 1220). A non-full-size crib is a crib that is either larger or smaller (or otherwise shaped differently) from a full-size crib. The standard for non-full-size cribs covers portable cribs (a crib that “may be folded or collapsed, without disassembly, to occupy a volume substantially less than the volume it occupies when it is used”) as defined in that standard. The term “non-full-size crib” does not include products with mesh/net/screen or other non-rigid construction. Instead, enclosures with mesh or fabric sides are considered to be play yards and are not subject to the crib standards.

    CPSC is developing a separate mandatory federal standard for play yards.

  • Are hospitals required to provide cribs that comply with the CPSC’s new crib regulation?The CPSC crib rule requires only certain facilities to provide cribs that comply with CPSC requirements. Those places include child care facilities, family child care homes, and places of public accommodation such as hotels and motels. Hospital cribs are regulated by the U.S. Food and Drug Administration (Here’s the latest information from them), and thus, are considered to be medical devices. Cribs used in hospitals as medical devices are not required to comply with the new CPSC crib standards.

    However, the CPSC will treat a child care facility that is owned or operated by, or located in, a hospital the same way as any other child care facility. We will expect the facility’s cribs to meet the new crib standards by December 28, 2012, unless the facility provides documentation showing that the cribs are medical devices.

  • What types of child care arrangements are impacted by the new crib standards?The Consumer Product Safety Improvement Act of 2008 (CPSIA) directed the U.S. Consumer Product Safety Commission (CPSC) to issue the new crib standards and apply them to (among others) “any person that … based on the person’s occupation, holds itself out as having knowledge or skill peculiar to cribs, including child care facilities and family child care homes.” The law does not define “child care facility” or “family child care home.”

    Based on the CPSIA language and other federal programs related to child care, we consider a “child care facility” to mean a nonresidential setting that provides child care services (which could include early learning opportunities) for a fee. We consider “family child care home” to mean a location that provides child care services (which could include early learning opportunities) for a fee in a residential setting. The residential setting is usually in a home other than the one where the child resides, although the child or children of the caregiver may also attend.

    Licensing requirements vary widely from one state to another, and whether a child care provider is licensed does not determine the provider’s status as a child care facility or family child care home for purposes of CPSC’s crib standards.

    We do not consider “in-home care,” where a child is cared for in his/her own home or by a relative in the child’s home or the relative’s home, to be a “child care facility” or a “family child care home.”

    In turn, we do not consider such arrangements to be subject to the new crib standards.

  • Are churches/church nurseries subject to the new crib standards?The CPSIA does not provide any exclusion for churches. If a church operates a child care facility, the cribs it provides must comply with the CPSC’s crib standards. Given the language in the CPSIA, we consider a “child care facility” to be one that provides services for a fee or that pays a person (or persons) to take care of children. If volunteers take care of children without pay during a church service, we do not consider that arrangement to be a “child care facility”, and cribs used under such an arrangement would not be subject to the CPSC’s crib standards.
  • Are foster homes or residential facilities subject to the new crib standards?We consider a foster home to be a private residence where care is provided in the child’s own home. This arrangement is similar to in-home care and would not be subject to CPSC’s crib standards. However, in addition to child care facilities and family child care homes, CPSC’s crib standards apply to “places of public accommodation,” which means “any inn, hotel, or other establishment … that provides lodging to transient guests.”

    We consider a public residential facility (as opposed to a private residence) to be a place of public accommodation and subject to CPSC’s crib standards.

  • Are “hospital cribs” located in child care facilities subject to the new crib standards? 

    This depends on whether the crib is a medical “device.” CPSC’s crib standards do not apply to medical devices. A crib that meets the definition of “device” in the Federal Food, Drug, and Cosmetic Act (21 U.S.C. § 201(h)) is subject to regulation by the Food and Drug Administration (FDA), not CPSC. You should contact FDA’s Center for Devices and Radiological Health to determine if a particular crib is a “device.”

 

A crib that is located in a child care facility and is not a “device” is subject to CPSC’s crib standards.

MANUFACTURERS, IMPORTERS, RETAILERS

Retrofitting Cribs

 

  • Is it possible to retrofit a crib that is currently in use (e.g., in a child care facility) to meet the new crib standards?CPSC staff does not believe that a crib currently in use can be retrofitted and tested to show compliance with the new crib standards. Typically, a crib is destroyed in the process of testing; therefore, retrofitting cribs currently in use cannot be done. As discussed in the preamble to the final rule, the crib standards include multiple, complex requirements for many parts of a crib, making it difficult to determine whether a retrofitted crib currently in use would meet the requirements without testing that specific crib. (Section E.9 of the preamble to the final crib rule, 75 Fed. Reg. at 81771-72.) Also, a retrofit, such as a side rail immobilizer, which previously might have been an acceptable remedy to address a defect in a recalled crib, may not necessarily make a crib compliant with the new crib standards because additional new compliance requirements now apply to that crib design.
  • Is it possible for a retailer, manufacturer, or lessor to retrofit unused crib inventory to meet the new crib standards?Under some circumstances, it may be possible to retrofit unused, noncompliant crib inventory to meet the new crib standards. To comply with the new standards, an existing crib model – with the retrofit in place – must be put through the complete test regimen. In other words, the crib model, as it exists in inventory, must be tested with the retrofit, and it must meet all the provisions of the relevant new standards and be certified to the applicable new standards prior to its sale. The manufacturer should provide a way to ensure that all the crib models in inventory have been retrofitted properly. For unused cribs in inventory, we assume that cribs of the same model are sufficiently similar, so that when a model that is identical to the crib(s) in inventory is tested to the standard with the retrofit, and the crib passes the test, then that retrofit can be applied to all other identical models currently in inventory to make them compliant. It is the manufacturer’s, retailer’s, or lessor’s responsibility to ensure that all cribs sold (or resold or leased) on and after June 28, 2011, are compliant with the new standards. If a retrofit is used, it is the manufacturer’s or importer’s responsibility to provide certification of the retrofitted crib, following testing by a CPSC-accepted certifying body, to ensure that the inventory is sold only with a retrofit that makes the crib compliant with the standard. The same retrofit methods developed for a non-compliant unused crib cannot be applied to a crib model that is used or that currently is in use because each crib is unique, due to its use patterns. Therefore, each used crib unit would have to be tested with the retrofit in place before the crib could be certified. The testing can be destructive; and likely would render the crib unusable.
  • If inventory is retrofitted, what testing is required?

 

The crib model must be tested to the relevant crib standard (16 CFR part 1219 or 16 CFR part 1220) with the retrofit in place. The testing must be conducted by a third party testing body that has been accredited and accepted by the CPSC to test cribsto the new crib standards.

  • Must crib manufacturers, retailers, and lessors get approval from the CPSC to retrofit crib inventory?

 

No. The CPSC does not approve crib retrofit methods. The CPSC relies on the manufacturer’s/importer’s certification of compliance of the retrofitted product that is supported by testing to the applicable standard by a CPSC accepted conformity assessment body.

  • If a company has an inventory of cribs that do not comply with the new crib standards, could the company export the noncompliant cribs to another country?
    Yes. However, beginning June 28, 2011, a company first must notify the CPSC and follow the procedures stated in 16 CFR part 1019, pertaining to Export of Noncomplying, Misbranded, or Banned Products.

 

If you have additional questions, please e-mail them to feedback@cpsc.gov.

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