Tuesday, June 28, 2011

Setting The Record Straight

The Consumer Product Safety Commission’s official pronouncements on the new mandatory safety standards for cribs have caused confusion among the press. This post is intended to correct the record.

The new standards ban drop-side cribs. But the standards also prohibit the sale, new or used, of all cribs – both drop-side and fixed-side – that are not tested to the new standards by a private laboratory. Because very few cribs that were not originally manufactured to the new standards will ever be tested, the new standards essentially ban all such cribs – drop-side and fixed side. As reported in today’s press, millions of drop-side cribs have been recalled. On the other hand, tens of millions of fixed side cribs manufactured to previous standards have never been recalled, never been found to be unsafe, and now also cannot be sold new or resold used.

Drop side cribs have been banned since 2009 by the voluntary standard followed by the vast majority of crib manufacturers offering cribs in the domestic United States market today. Therefore, although it is true that the new standards are the first “mandatory” federal crib standards in 30 years, very few new drop-side cribs have been available in the United States market for two years. That problem was largely solved already through recalls and a change to the industry voluntary standard.

1 comment:

Tim said...

The enforcement of this regulation could have perhaps been more bearable had it not been for CPSIA, which, among other things was a complete waste of the commissions efforts and business' revenue for ridiculous and unnecessary testing, re-engineering and material changes.

After the recalls for lead tainted paints & surface coatings in 2007, it seemed enforcement & surveillance should have perhaps been stepped up, but reducing the limits because a few companies violated the then safe and acceptable limit, which had been in place for 30 plus years? 600ppm apparently was considered "safe" for Generation X, but not Generation Y.

Then you have phthalates; where scientific evidence (not theoretical) suggests virtually zero harm to children, fetuses or pregnant women (except maybe in mice).

CPSIA was applied retroactively, costing not only for 3rd party testing, but a sudden spike in rising material costs by opportunistic suppliers and manufacturers and the retroactive application, which costs business hundreds of millions in lost inventory.

Which brings us back to the ban on drop-side cribs; where it may be in our best interest to be more proactive in significantly lowering the risks of injury or death to our children by pursuing this ban, but the continuing questions of intent and thoughtful consideration related to the CPSIA provisions keep manufacturers and perhaps retailers on guard when new bans or regulations are enacted. How can we truly trust the scope and application of the regulation?

It seems that common sense and the wide spread repercussions of these regulations are not carefully considered amongst the five commissioners (three of which have voting power); kind of like consumer watchdogs and true industry product safety professionals. We all have the same goal, but different methods of approaching and solving the same problem; one pie in the sky and one practical.