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CR comments to CPSC on nursing pillows NPRM 11-27-2023

Consumer Reports (CR), the independent, non-profit member organization,1 welcomes the opportunity to submit comments to the Consumer Product Safety Commission (CPSC) regarding the agency’s notice of proposed rulemaking (NPR) to promulgate a consumer product safety standard for nursing pillows.2 CR strongly supports the proposed rule, which addresses hazards associated with nursing pillows that put infants at an increased risk of injury or death.

The current marketplace offers a wide array of infant products that are intended, marketed, or designed to help parents and caregivers feed and care for their babies. Unlike some other infant products on the market, nursing pillows provide a clear utility and benefit during breastfeeding or bottle feeding. This includes additional support for nursing parents, including those who have undergone a cesarean section, and caregivers who may have a disability or limitation that makes feeding challenging. Nursing pillows undoubtedly have been an important tool for many parents and caregivers that can help reduce fatigue and promote bonding with the baby.

However, nursing pillows can pose serious safety risks to babies when used improperly for sleep or for lounging. The CPSC is aware of 242 incident reports between January 2010 and December 2022, including 154 incidents involving an infant death. Nearly all of the reported deaths involved babies six months old or younger; in addition, nearly all of the reported deaths involved the use of the nursing pillow for sleep. Upon becoming aware of infant deaths linked to nursing pillows, CR investigated the products’ safety hazards, warned consumers about the risks of using nursing pillows for infant sleep, and urged companies and the federal government to take strong action that would improve the safety of nursing pillows.3

Consumer Reports strongly supports the CPSC’s sensible proposal, which would require nursing pillows to meet performance requirements that are specially tailored to address known safety hazards. Contrary to what some might argue, it is clear that the CPSC’s proposal is not a ban on nursing pillows, but rather a reasonable and necessary step to make nursing pillows safer for parents and caregivers to use for breastfeeding and bottle feeding. As the CPSC works to finalize this safety standard, CR offers several more specific comments in this comment letter.