July 29, 2005
Ms. Sayde Dunn, Secretary
United States Consumer Product Safety Commission
Washington, DC 20207-0001
Dear Ms. Dunn,
I am writing in regard to the petition filed by Consumer Federation of America, the Drowning Prevention Foundation, et. al., to ban infant bath seats. Consumers Union, publisher of Consumer Reports magazine, respectfully requests that we be added to the list of petitioners in this matter.
In 1936 Consumer Reports exposed the widespread use of lead in children’s toys. In the 64 years since that article was published, CU has been rating products, including products for children. Today we are best known for our test reports, product ratings, and buying guidance. Since 1936, our mission has been to test products, inform the public, and protect consumers. Our income is derived solely from the sale of Consumer Reports magazine and our other publications and services. CU is committed to educating consumers about potential product hazards and to advocating for the passage of laws and regulations to protect consumers from product hazards.
Consumer Reports’ Guide to Baby Products advises parents to avoid suctioned bath seats for babies. “Babies and toddlers can drown in only one inch of water. Bath seats do not protect–45 babies died while using them. Most had suction cups to hold them in place.” The number of babies who have drown while using bath seats has increased just since this book was published. The 66 incidents of drowning and 37 reports of near drowning identified by Consumer Product Safety Commission staff demonstrate that parents and caregivers have a false sense of security when they put babies in these bath seats. CU joins with the Consumer Federation of America and the eight other petitioners in asking that the Consumer Product Safety Commission reconsider its 1994 decision regarding bath seats.
Thank you for your assistance. Please feel free to contact me if you have any questions or comments concerning this request.
Senior Product Safety Counsel