Commercial Information Circulars

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Ref : EIC 111/2/21

21 April 2011

Dear Sirs,

Commercial Information Circular No. 240/2011

US : CPSC's Final Rule on Safety Standard for Toddler Beds and the Requirements for Accreditation of Third Party Conformity Assessment Bodies related to Testing of Toddler Beds

The US Consumer Product Safety Commission (CPSC) issued in the Federal Register (FR) of 20 April 2011 a final rule on the safety standard for toddler beds, which will become effective on 20 October 2011 and apply to products manufactured or imported on or after that date. Also published in the FR of the same day is a notice of requirements that provides the criteria and process for CPSC’s acceptance of accreditation of third party conformity assessment bodies for testing pursuant to specific CPSC regulations relating to toddler beds, which is effective on 20 April 2011.

DETAILS

Safety Standard for Toddler Beds

2.The trade was informed via Commercial Information Circular No. 185/2010 of CPSC's proposed rule on the safety standard for toddler beds. The final rule is very similar to the proposed rule and would establish a new section in Title 16 of the Code of Federal Regulations, i.e. 16 CFR part 1217, Safety Standard for Toddler Beds. 
 

3.The safety standard for toddler beds is substantially the same as a voluntary standard developed by ASTM International, ASTM F 1821-09, "Standard Consumer Safety Specification for Toddler Beds", with some modifications to make it more stringent in order to further reduce the risk of injury. The major modifications include:

1. strengthening the guardrail provisions by -
   1. requiring the upper edge of the guardrail be at least 5 inches above the manufacturer's recommended sleeping surface and if the manufacturer does not specify a mattress thickness, the guardrail height must be based on a mattress thickness of 6 inches; and
   2. modifying the test methodology;
2. adding requirements for testing the spindles/slats on guardrails, side rails, and end rails;
3. removing mattress retention provisions as other changes in the standard can better address entrapment protection; and
4. improving the warning label requirements by separating the warning label into two: one to address entrapment, and one to address strangulation. A specified warning concerning mattress size to address potential entrapment in gaps surrounding the mattress is also required. The final rule also requires toddler beds that convert from cribs to meet the warning requirements specified in the full-size crib standard, ASTM F 1169-10, instead of using the warnings specified in the toddler bed standard.

Other details of the safety standard and the testing requirements are set out in the FR notice which is available at http://edocket.access.gpo.gov/2011/pdf/2011-9421.pdf.

Third Party Testing for Toddler Beds: Requirements for Accreditation of Third Party Conformity Assessment Bodies

4.Pursuant to the US Consumer Product Safety Improvement Act of 2008 (CPSIA) and the issue of final rule on safety standard for toddler beds mentioned above, each manufacturer (including the importer) or private labeler of toddler beds must have such products manufactured on or after 20 October 2011, tested by a third party conformity assessment body accredited to do so and must issue a certificate of compliance with 16 CFR part 1217 based on that testing.

5.Third party conformity assessment bodies, that wish to be accredited to test the toddler beds for conformity with the applicable test methods as codified in the new safety standard mentioned above, must be accredited by an accrediting body that is a signatory to the International Laboratory Accreditation Cooperation-Mutual Recognition Arrangement (ILAC-MRA) and the accreditation must be registered with, and accepted by the CPSC. The CPSC has established an electronic accreditation registration and listing system that can be accessed via its website at http://www.cpsc.gov/about/cpsia/labaccred.html. Details of the requirements for accreditation are set out in the FR notice which is available at http://edocket.access.gpo.gov/2011/pdf/2011-9422.pdf.

ENQUIRIES

6.For enquiries concerning this circular, please contact the undersigned at telephone number 2398 5682.

Yours faithfully,

(Miss Carmen CHAN)

for Director-General of Trade and Industry