Regulatory requirements for furniture, cribs, and toddler beds.

1. U.S. Consumer Product Safety
Commission
CPSC Requirements for furniture, cribs and
children’s beds
This presentation was prepared by CPSC staff, has not been reviewed or
approved by, and may not reflect the views of, the Commission.

2. Mission
Protecting the public against unreasonable
risks of injury from consumer products
through education, safety standards
activities, regulation and enforcement.

3. 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

4. Product Hazard Prevention Strategies
• Engaging in product safety
system processes by
supporting improvements
to voluntary
standards/codes
CPSC staff promotes • Creating and enforcing
consumer product safety
} technical regulations and
bans
through a multi-pronged • Identifying and removing
products with defects and
approach
hazards through
surveillance activities and
recalls
• Developing education
programs for consumers,
importers, U.S. and foreign
manufacturers, and retailers

5. CPSC Voluntary Standards
Monitoring
Participate in
committees
Propose Analyze
standards injury/death
development data for hazard
or revisions patterns
Conduct tests Review
and evaluations
standards for
to support
findings inadequacies
CPSC staff does not vote.

6. Voluntary Standard Development
Organizations for Consumer Products
ANSI (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

7. 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.

8. 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 there is not
standard does or substantial
not adequately compliance.
reduce the risk

9. Furniture Requirements
Cribs

10. Crib Hazards
• Strangulation and suffocation from
drop-side-related issues (hardware
failure, incorrect assembly)
• Limbs caught between slats
• Falls from cribs

11. Crib Hazards
• Inadequate wood strength
• Inadequate mattress support
• Incorrect mattress size
• Paint and coating-related issues

12. Deaths Due to
Crib Structural Failures

13. Deaths Due to
Crib Structural Failures

14. CPSC Crib Regulations
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.

15. CPSC Crib Regulations
• Specific dimensions
−Interior dimensions
−Rail height
• Spacing of crib components
−Distance between components with and
without an applied force

16. CPSC Crib Regulations
• Hardware
– Must prevent mechanical hazard
– Requires fastener/attachment hardware
locking devices
• Construction and finishing
– Wood components
– Prevention of fall hazards

17. CPSC Crib Regulations
• 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

18. Crib Testing
18

19. Furniture Requirements
Toddler Beds

20. Toddler Bed Hazards
• Entrapment
• Broken, loose, or detached components
• Product integrity issues
– Mattress support
• Mattress fit problems
• Paint-related issues

21. 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.

22. CPSC Toddler Bed Regulations
• 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

23. CPSC Toddler Beds 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.

24. CPSC Toddler Beds Regulations

25. CPSC Toddler Bed 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)

26. Furniture Requirements
Bunk Beds

27. CPSC Bunk Bed Regulations
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.

28. CPSC Bunk Bed Hazards
• Entrapment
• Falls
• Product integrity issues
– Mattress support

29. CPSC Bunk Bed Regulations
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

30. 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

31. 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

32. 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.

33. Bunk Bed Testing
33

34. Furniture Requirements
Upholstered Furniture

35. 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.

36. Upholstered Furniture
(proposed regulation)
• 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

37. 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/

38. 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.

39. Responsibility to Comply with Voluntary
Standards and Technical Regulations
All equally responsible
Manufacturers
Distributors Retailers
Importers
Importers, although reliant on foreign producers,
are directly responsible for the safety of products
they bring into the United States.

40. Importance of Using U.S. Technical Regulations
and Voluntary Standards
To avoid entry problems with the U.S.
government (Customs and CPSC), foreign
manufacturers SHOULD comply with BOTH:
– CPSC Regulations (mandatory)
– Private Sector Standards (consensus
voluntary standards)
Both play essential safety roles.

41. How the CPSC Works with
Manufacturers
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

42. 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.

43. 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”.

44. 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.

45. Best Manufacturing Practices

46. Contact Information
Dean W. Woodard, M.S.
Director, Office of Education, Global Outreach, and
Small Business Ombudsman
E-mail: Dwoodard@cpsc.gov
Phone: 301-504-7651
Tilven M. Bernal
Program Manager for the Western Hemisphere
International Programs
E-mail: Tbernal@cpsc.gov
Phone: 301-504-7309