Consumer Federation of America, Consumer Reports, Kids In Danger, National Center for Health Research, Public Citizen, and U.S. Public Interest Research Group welcome the opportunity to comment on the notice of proposed rulemaking (NPR) by the U.S. Consumer Product Safety Commission (CPSC or Agency) on the Safety Standard for Infant Support Cushions.
Our organizations strongly support the proposed rule, which addresses hazards associated with infant support cushions that put infants at an increased risk of injury or death. For years, infant support cushions have been marketed and sold for a wide array of uses, including lounging and infant propping. Some were also marketed “for use in a crib or other infant sleep product.” Putting babies to sleep for any duration in products that do not meet the requirements of the CPSC’s Infant Sleep Product Rule or another mandatory CPSC standard for infant sleep, such as the bassinet standard, runs directly counter to evidence-based safe sleeping practices established by the American Academy of Pediatrics (AAP). These expert safe sleep guidelines recommend placing a baby alone, on their back, on a firm, non-inclined surface in a safe sleep environment without soft objects or loose bedding.4 Despite these established safe sleep guidelines and warnings, incident data confirms that some caregivers use infant support cushions for sleep.
To read full comments, click here.