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CR comments to the CPSC on the proposed safety standard for clothing storage units (CSUs)

Consumer Reports (CR), the independent, non-profit member organization, welcomes the opportunity to submit comments to the Consumer Product Safety Commission (CPSC) regarding the agency’s notice of proposed rulemaking to establish a mandatory safety standard for clothing storage units (CSUs). Addressing furniture tip-over hazards has been a priority for CR for more than a decade. We know first-hand how critical it is to implement a strong mandatory standard, based on the results of our independent testing, the findings of our investigations, and our experience advocating for change. We also know through our comparative stability testing of CSUs that it is indeed feasible to make a safer product, and the CPSC’s proposed rule would go a long way toward achieving this goal. In the following comments, we outline the serious tip-over risks associated with CSUs and provide input and recommendations on the proposed rule.

As a persistent hidden hazard, furniture tip-overs take a severe toll on families across the country. Existing harm mitigation efforts, including those tied to the voluntary standards process, the promotion and use of anti-tip restraints, and safety messaging to the public, are valuable—but they, alone, have done far too little to reduce tip-over deaths and injuries. It is clear that a strong mandatory rule, accounting for real-world conditions and foreseeable child interactions with CSUs, is urgently needed.

Although tip-over incidents have affected people of various ages, the vast majority of furniture tip-over fatalities involve young children. Since 2000, hundreds of children have died in furniture tip-over incidents, and every year, thousands are treated for injuries at the emergency department. We were pleased to see in the CPSC’s most recent report on tip-over incident data that staff has identified a statistically significant decline in tip-over injuries from 2011-2020. According to agency staff, this is due in large part to a reduction in tip-overs related to a television, though we suspect that recent declines in injuries also may be attributable to the enduring work of Parents Against Tip-Overs and others who have increased public awareness about the danger of furniture tip-overs. Despite this apparent decline, tip-over injuries and deaths still occur with alarming regularity. According to the latest CPSC data, an estimated 22,500 people suffer a medically-treated injury related to a tip-over every year. An average of six children are rushed to the emergency department every day after a chest, bureau, or dresser tips over onto them. Not all of these children survive. A strong and timely federal safety rule can help protect children against these preventable deaths and injuries.

For CR’s full comments to the CPSC on the proposed safety standard for CSUs, click here.