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Safety Standards Proposed for Children’s Folding Chairs and Stools, Infant Bouncer Seats

Monday, October 19, 2015
Sandler, Travis & Rosenberg Trade Report

The Consumer Product Safety Commission is proposing separate safety standards for children’s folding chairs and stools and infant bouncer seats. If these standards are finalized they will be children's product safety rules that require the issuance of a notice of requirements to explain how laboratories can become accredited as third-party conformity assessment bodies to test products to the new standards. Comments on these proposed rules are due no later than Jan. 4, 2016. The CPSC is proposing to make the final rules effective six months after publication in the Federal Register for products manufactured or imported on or after that date.

Folding Chairs and Stools. Current voluntary standard ASTM F2613-14 defines a “children’s chair” as “seating furniture with a rigid frame that is intended to be used as a support for the body, limbs, or feet of a child when sitting or resting in an upright or reclining position.” A “children’s stool” is defined as a “children’s chair without back, or armrest.” ASTM further defines “folding chair” and “folding stool” as “a children’s chair or stool which can be folded for transport or storage.” This standard covers a chair or stool intended to be used by a single child who can get in and out of the product unassisted and with a seat height 15 inches or less, with or without a rocking base.

The CPSC proposes to base the mandatory standard on ASTM F2613-14 with several modifications. First, the scope of the mandatory standard would be limited to folding chairs and folding stools because the hazards presented by these items are different from non-folding chairs and stools. There are two primary designs associated with children’s folding chairs and folding stools: (1) straight tube versions that contact the surface in three or more capped-tube legs, and (2) bent tube versions that contact the ground along a substantial portion of the tubular frame. Although there are a variety of other designs used, the primary characteristic that applies to all is the folding mechanism of the chair and stool that is used for transport or storage of the product.

Second, the CPSC is proposing revisions with respect to marking and labeling. Specifically, each folding chair and folding stool would require warning statements. Provisions would be added to make warnings easier to read and more conspicuous; e.g., putting the warnings in English, using highly contrasting colors in non-condensed sans serif type, and placing the label separate and distinct from any other graphic or written material on the product.

Infant Bouncer Seats. Current voluntary standard ASTM F2167-15 defines an “infant bouncer seat” as “a freestanding product intended to support an occupant in a reclined position to facilitate bouncing by the occupant, with the aid of a caregiver or by other means.” These items are intended for infants who have not developed the ability to sit up unassisted (approximately 0 to 6 months of age).

Bouncer seats vary widely in style and complexity but typically consist of a cloth cover stretched over a wire or tubular frame. Wire frame bouncers have two designs: the forward bend design is constructed with the seating area supported from the front side, while the rear bend design has the seat supported from the rear side.

All bouncer seats support the child in an inclined position and some have adjustable seat backs. Various models include a unit that vibrates or bounces the chair and may play music or other sounds. Most bouncer seats also feature an accessory bar with attached toys that are, or at some point will be, within the child’s reach. Most models examined by Commission staff provide a three-point restraint system consisting of wide cloth crotch restraints and short adjustable waist straps with plastic buckles.

The CPSC is proposing specific modifications to ASTM F2167-15 to strengthen and improve the requirements for on-product warnings and instructional materials provided with bouncer seats. Two components would be added to the warning statements: (1) the statement “adjust to fit snugly” would be revised by adding the phrase “even if baby is sleeping;” and (2) developmental guidance would advise caregivers to stop using the product when children start trying to sit up. In addition, the fall hazard warning label would have to be on the front of the product near the infant’s head and comply with specific formatting requirements.

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