Consumer Reports, the independent, non-profit member organization, welcomes the opportunity to submit comments to the Consumer Product Safety Commission (CPSC) regarding the agency’s supplemental notice of proposed rulemaking to establish a safety standard for infant sleep products. We commend the CPSC for proposing a rule that would strengthen safety standards for infant sleep products nationwide and align with medical experts’ safe sleep recommendations, all based on a robust and growing body of evidence for how to keep infants safe.
Parents and caregivers should be able to trust that all products for infant sleep must meet strong standards to keep babies safe, and right now, this simply is not the case. Accordingly, Consumer Reports strongly supports the proposed standard, with minor modifications, and urges the CPSC to finalize it expeditiously.
As a part of CR’s ongoing work to improve infant sleep safety, and working together side by side with consumers across the country, Consumer Reports received approximately 22,650 signatures from people who wished to petition the CPSC in support of the proposed safety standard for infant sleep products. Attached to these comments, please find the names of these people, who collectively send the Commission the following message:
We urge the Consumer Product Safety Commission to finalize its strong proposed rules on infant sleep products. These rules would effectively stop the manufacture and sale of all infant inclined sleepers with inclined angles greater than 10 degrees. Not one more child or parent should suffer from this dangerous type of product.
Indeed, in the supplemental notice of proposed rulemaking, the Commission proposes promulgating a mandatory safety standard under section 104 of the Consumer Product Safety Improvement Act (CPSIA) for infant sleep products that would expand, build on, and substantially strengthen the current ASTM International voluntary standard for infant inclined sleep products (ASTM F3118-17). The proposed standard would apply to infant sleep products not governed by current mandatory standards—specifically, those pertaining to bassinets/cradles, cribs, play yards, and bedside sleepers—and would limit infant sleep products to a back incline angle of 10 degrees or less. The proposed rule generally aligns with American Academy of Pediatrics (AAP) safe sleep recommendations and clear evidence establishing the dangers of infant sleep at an incline.
Consumer Reports recommends minor modifications to the proposed rule to help ensure that the new infant sleep products safety standard would apply to all infant products that are for sleep. This includes infant products intended, marketed, or otherwise indicated for sleep, including products described using substitute language for sleep, such as “napping” or “snoozing.” The final rule should ensure that every infant sleep product entering commerce aligns with safe sleep recommendations by medical experts, particularly the AAP, in order to keep babies safe and minimize confusion for parents and caregivers.
For the full comments, click here.