U.S. Consumer Product Safety Commission

This presentation was prepared by CPSC staff, has not been reviewed or approved by, and may not reflect the views of, the Commission.

CPSC Requirements for furniture, cribs and children’s beds

Mission

Protecting the public against unreasonable risks of injury from

consumer products through education, safety standards activities, regulation and

enforcement.

Four Types of Safety Concerns

• Product fails to comply with a mandatory safety standard or ban under the Acts

• Product fails to comply with voluntary standards relied upon by the Commission

• Product contains a defect which could create a “substantial product hazard”

• Product creates an “unreasonable risk” of serious injury or death

Product Hazard Prevention Strategies

CPSC staff promotes consumer product

safety through a multi-pronged approach

• Engaging in product safety system processes by supporting improvements to voluntary standards/codes

• Creating and enforcing technical regulations and bans

• Identifying and removing products with defects and hazards through surveillance activities and recalls

• Developing education programs for consumers, importers, U.S. and foreign manufacturers, and retailers

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CPSC Voluntary Standards Monitoring

Participate in

committees

Analyze injury/death

data for hazard

patterns

Review standards

for inadequacie

s

Conduct tests and

evaluations to support findings

Propose standards

development or

revisions

CPSC staff does not vote.

Voluntary Standard Development Organizations for Consumer

ProductsANSI (American National Standards Institute)– Motorized Equipment– Lawn & Garden Equipment– Household Products– Safety Labeling

ASTM International – Children’s Products• Recreational Products

Underwriters Laboratories (UL)– Electrical and other products

Voluntary Standards and Recalls

In some cases, failure to comply with a consensus voluntary standard indicates to the CPSC that a product contains a defect that presents a substantial product hazard.

Example: These lights do not meet the voluntary Underwriters Laboratory (UL) standard due to insufficient wire size. They can overheat and pose a fire and shock risk.

CPSC can seek a recall.

Technical Regulations

Regulatory process can be started by vote of the Commission or by a petition from an interested party

CPSC statutes specify that voluntary

standards should be relied upon. However, a regulation may be

issued if:

the current voluntary standard does not

adequately reduce the

risk

there is not substantial compliance.

or

Furniture Requirements

Cribs

Crib Hazards

• Strangulation and suffocation from drop-side-related issues (hardware failure, incorrect assembly)

• Limbs caught between slats

• Falls from cribs

Crib Hazards

• Inadequate wood strength

• Inadequate mattress support

• Incorrect mattress size

• Paint and coating-related issues

Deaths Due to Crib Structural Failures

Deaths Due to Crib Structural Failures

The CPSC issued new regulations for full-size and non-full-size baby cribs

and third party testing. The regulations

were effective on June 28, 2011, for manufacturers, importers, and

retailers.

CPSC Crib Regulations

CPSC Crib Regulations

• Specific dimensions−Interior dimensions −Rail height

• Spacing of crib components−Distance between components

with and without an applied force

CPSC Crib Regulations

• Hardware–Must prevent mechanical hazard–Requires fastener/attachment

hardware locking devices

• Construction and finishing–Wood components–Prevention of fall hazards

• Assembly instructions–Complete–Easy to understand

• Identifying marks, warning statement and compliance declaration– Identification of the manufacturer,

importer, distributor, and/or seller–Cautionary language–Recordkeeping

CPSC Crib Regulations

Crib Testing

18

Furniture Requirements

Toddler Beds

Toddler Bed Hazards

• Entrapment

• Broken, loose, or detached components

• Product integrity issues –Mattress support

• Mattress fit problems

• Paint-related issues

CPSC Toddler Bed Regulations

• The CPSC issued new regulations for toddler beds and procedures for third party testing.

• The toddler bed regulations were effective on October 20, 2011.

• References the ASTM standard F1821-09 Standard Consumer Safety Specification for Toddler Beds, with some changes:

- Height requirement for guardrails

- New performance test to address guardrail structural issues

CPSC Toddler Bed Regulations

• New performance requirements for spindle/slat strength of guardrails, side rails, and end structures.

• Changed warning labels to address entrapment and strangulation hazards separately.

CPSC Toddler Beds Regulations

CPSC Toddler Beds Regulations

Toddler beds that are converted from full-size cribs:

• Use spindle/slat testing in full-size crib standard (16 CFR § 1219)

• Use warning required in section 8 of ASTM F1169-10 (incorporated by reference at 16 CFR § 1219)

CPSC Toddler Bed Regulations

Bunk Beds

Furniture Requirements

The Commission regulates bunk beds to reduce the risk of death or injury to children from entrapment between an upper bunk and a wall, in openings below guardrails, or in openings in the ends of bunk beds.

CPSC Bunk Bed Regulations

• Entrapment

• Falls

• Product integrity issues –Mattress support

CPSC Bunk Bed Hazards

Guardrails

• Must have at least two upper bunk guardrails no less than 5 inches above top of mattress

• Guardrail on side next to wall must run full length to within 0.22 inches of end structure, if not attached to end structure

CPSC Bunk Bed Regulations

Guardrails

• Guardrail on side away from wall cannot have an opening greater than 15 inches between it and end structures

• Wedge block must not pass through any spaces in or below guardrail

CPSC Bunk Bed Regulations

End Structures

• Top of each end must be at least 5 inches above top of mattress for at least half distance

• Wedge block must not pass through any opening in upper bunk

CPSC Bunk Bed Regulations

End Structures

• Wedge block must not pass through any opening in lower bunk unless the opening also permits passage of a 9-inch diameter sphere.

• Openings that permit passage of sphere must be tested for neck entrapment.

CPSC Bunk Bed Regulations

Bunk Bed Testing

33

Upholstered Furniture

Furniture Requirements

Upholstered Furniture (proposed regulation)

• The Commission proposed a rule addressing the risk of residential fires associated with cigarette and small open-flame ignitions of upholstered furniture.

• Currently, CPSC staff is conducting research to validate or revise performance test methods and to respond to public comments.

• The proposed regulation primarily targets the risk of fire associated with smoldering ignitions of upholstered furniture.–Proposal would require that

manufacturers & importers use either: • Smolder-resistant upholstery

coverings

• Smolder-resistant and flame-resistant interior fire barriers

Upholstered Furniture (proposed regulation)

Furniture and OSHA

• The furniture used in a workplace is regulated by the U.S. Occupational Safety and Health Administration (OSHA), even if it is the same product used in a home. 

• Certain types of furniture may need to be tested and certified by an OSHA-recognized laboratory (NRTL) to meet the applicable safety test standard.  For more information, go to: www.osha.gov/dts/otpca/nrtl/

State Regulatory Authorities and Technical Regulations

• In the United States, some states have laws and regulations that are more strict than federal requirements. These laws include regulations for products, labeling, packaging, and chemical restrictions (e.g., flame retardant chemicals).

• Your customer (importer) should know these requirements.

Importers, although reliant on foreign producers, are directly responsible for the safety of products they bring into the United States.

Responsibility to Comply with Voluntary Standards and Technical Regulations

All equally responsible

ManufacturersImporters

Distributors Retailers

Importance of Using U.S. Technical

Regulations and Voluntary Standards

To avoid entry problems with the U.S.government (Customs and CPSC), foreignmanufacturers SHOULD comply with BOTH:

–CPSC Regulations (mandatory)

–Private Sector Standards (consensus voluntary standards)

Both play essential safety roles.

Develop guidance and help firms comply with the law through:

• International program outreach

• Domestic manufacturer seminars

• Participation at ICPHSO symposiums

• Advice and guidance to trade associations and consultants

How the CPSC Works with Manufacturers

Best Manufacturing Practices

Manufacturers and importers should use best practices to ensure safe products enter into the chain of commerce.

– Importers/suppliers must work as a team.–Know where and how your product will be

used. –Know and understand all requirements and

standards.–Comply with consensus standards and

technical regulations.

Best Manufacturing Practices

–Design safety into product. It is your responsibility to work with the designer.–Control your supply chain (supply

chain integrity).–Preventive action is better than

corrective action.–Avoid long-term repercussions:

Damage to Brand Name and “Made in My Country”.

Best Manufacturing Practices

–To avoid problems, samples should be tested randomly, early and often.–The cost of testing is a tiny fraction of the

costs associated with recalls and violations.–Seek products with third party

certification.–Unauthorized component substitutions can

easily lead to a recall.–Conduct spot inspections.

Best Manufacturing Practices

Dean W. Woodard, M.S.Director, Office of Education, Global Outreach, and

Small Business OmbudsmanE-mail: Dwoodard@cpsc.gov

Phone: 301-504-7651

Tilven M. BernalProgram Manager for the Western Hemisphere

International ProgramsE-mail: Tbernal@cpsc.gov

Phone: 301-504-7309

Contact Information