Vol. 149, No. 30 — July 25, 2015

Cribs, Cradles and Bassinets Regulations

Statutory authority

Canada Consumer Product Safety Act

Sponsoring department

Department of Health

REGULATORY IMPACT ANALYSIS STATEMENT

(This statement is not part of the Regulations.)

Executive summary

Issues: Cribs, cradles and bassinets are the only products intended to provide unsupervised sleeping accommodation for infants and young children. To protect this vulnerable population, it is important that these products and their accessories be constructed in a manner that protects against known hazards that may result in injuries and deaths, and provide a safe sleep environment. The current Cribs, Cradles and Bassinets Regulations (CCBR) have strict requirements for the construction and performance of these products. However, in collaboration with the ASTM International working groups for cribs, cradles and bassinets, Health Canada has identified further hazards not yet addressed by these Regulations, such as those associated with the deformation and breakage of hardware on traditional crib drop sides, and is proposing to introduce new Regulations to address these hazards. The new CCBR would also further align the Canadian requirements for cribs, cradles and bassinets with the requirements established by the United States Consumer Product Safety Commission (U.S. CPSC), which reference in law the ASTM standards for cribs, cradles and bassinets.

Description: It is proposed that the new CCBR, under the Canada Consumer Product Safety Act (CCPSA), be introduced to include a number of major modifications to address identified hazards, including a prohibition on the sale, importation, manufacture and advertisement of traditional drop-side cribs, and the introduction of performance requirements and test methods for accessories for cribs, cradles and bassinets and stands for cribs, cradles and bassinets. The new CCBR are intended to help improve the safety of these products to further safeguard against injuries and deaths, while bringing the majority of the Canadian regulatory requirements in line with those of the U.S. CPSC, which, in turn, will help provide clarity for industry.

Cost-benefit statement: The costs of the regulatory proposal have a present value of $12.19 million over 20 years, discounted at a rate of 7%. The benefits have a present value of $32.79 million over 20 years, discounted at a rate of 7%. Thus, this regulatory proposal would deliver net benefits to Canadians in excess of $20.60 million. The net benefits would have an annualized value of $1.94 million and a benefit/cost ratio of 2.69. Beyond this economic argument, some aspects of existing crib, cradle and bassinet designs are contributing to non-fatal and fatal incidents involving infants in Canada. Adopting the proposed CCBR would help to better protect infants and young children.

“One-for-One” Rule and small business lens: The “One-for-One” Rule does not apply to this regulatory proposal as it does not impose administrative burden. The small business lens applies to the regulatory proposal. The completed small business lens checklist follows the Regulatory Impact Analysis Statement (RIAS). There are not expected to be substantial, disproportionate direct impacts on small businesses.

Domestic and international coordination and cooperation: The proposed requirements involve aligning several aspects of the Canadian requirements with the U.S. requirements, where possible and appropriate. There are particular requirements in the U.S. specifications that were identified as adding further safety measures to the CCBR. Greater alignment of the CCBR with the requirements of the United States would facilitate industry compliance and trade between the two countries, as several manufacturers of these products sell in both Canada and the United States.

Background

Cribs, cradles and bassinets are intended to be used by infants and young children without adult supervision. Young children constitute a particularly vulnerable segment of the population because they cannot recognize potentially dangerous conditions and therefore require a higher degree of protection than adults. The proposed Cribs, Cradles and Bassinets Regulations (CCBR) would improve the safety of these products by specifying the minimum safety requirements that these products would need to meet in order to limit the risk of death and injury to users.

Canada’s requirements for cribs, cradles and bassinets are among the most stringent in the world. However, Health Canada has identified safety concerns associated with traditional crib drop-sides. In addition, crib, cradle and bassinet manufacturers have requested greater alignment of the Canadian CCBR with other recognized international standards, specifically those of ASTM International.

Since the existing CCBR were introduced in 2010, a number of substantial issues relating to crib, cradle and bassinet safety, including hazards associated with traditional crib drop sides, crib mattress supports, and entrapment hazards from openings in fabric-sided products, have resulted in reported incidents in Canada. Health Canada has responded to these issues by negotiating voluntary recalls with industry and identifying improvements to the regulatory requirements to address these issues.

Health Canada launched a public consultation on September 29, 2010, regarding the development of a new regulatory proposal to prohibit traditional drop sides on cribs, improve the general safety of cribs, cradles and bassinets and further align Canadian and U.S. requirements.

Issues

Between 2010 and mid-September 2014, there were 35 recalls for cribs, cradles and bassinets, of which 14 were related to crib drop sides, 5 to crib slat strength, 2 to crib mattress supports and 2 to instructions for assembly and proper use. The U.S. CPSC has moved to address these issues in regulations.

Drop-side cribs generally have a tendency to be less structurally sound than cribs with fixed sides because of the additional stress caused by the repeated raising and lowering of the drop side. The hardware on these cribs has broken or deformed after routine use. When the drop side hardware breaks or deforms, the drop side can detach from the crib in one or more corners and create a space between the drop side and the crib mattress. The bodies of infants and toddlers have become entrapped in this space, which has led to suffocation. Complete detachment of the drop side from the crib has led to falls.

Between January 2000 and mid-September 2014, Health Canada received 104 complaints involving crib drop sides of all models sold in Canada, including those models that were ultimately recalled. The 104 reported drop-side complaints were associated with 94 non-injury-related incidents, 8 reports of bumps, scrapes and bruises, one report of a concussion, and one death. The death occurred in a crib where the original drop-side hardware had been replaced with parts that were not supplied by the manufacturer. The crib was also in a general state of disrepair.

The U.S. CPSC has adopted revised mandatory requirements for cribs. The new regulation requires that full-size cribs comply with the industry standard ASTM F1169-13. The United States CPSC has also adopted the industry standard for cradles and bassinets ASTM F2194-13a as law.

The ASTM F1169-13 standard for full-size cribs includes several new provisions, such as a restriction on crib sides that are not rigidly attached to the crib ends (the traditional style of crib drop-sides). Due to this new U.S. CPSC requirement, which is based on the voluntary industry standard, many industry members no longer manufacture or sell traditional drop-side cribs in the United States and Canada.

Objectives

The objective of the proposed CCBR is to improve the protection of the health and safety of young children with regard to the use of cribs, cradles and bassinets, including a specific focus on reducing injuries related to traditional drop-side cribs, and to further align Canada’s safety requirements with those of the United States.

Description

The proposed CCBR of the CCPSA would repeal and replace the existing CCBR, which were promulgated under the Hazardous Products Act. They would enhance safety and better align Canada’s safety requirements with those already adopted by the U.S. CPSC. This would be accomplished by strengthening construction and performance requirements through the following:

  1. Prohibiting the sale, importation, manufacture and advertisement of cribs, cradles and bassinets with sides that are not rigidly attached to the crib, cradle or bassinet ends (i.e. traditional “drop sides”);
  2. Updating the structural integrity test method for the mattress support vertical impacting of cribs and cradles such that it is more repeatable;
  3. Adding an additional performance requirement and test method for crib slat strength;
  4. Including a performance requirement to further safeguard against incorrect assembly of key structural components of cribs, cradles, bassinets and accessories;
  5. Including performance requirements and test methods for accessories, such as sleep or change table accessories, that attach to cribs, cradles or bassinets;
  6. Including performance requirements for the maximum rest angle and maximum flatness angle of cribs, cradles, bassinets, sleep accessories and stands;
  7. Updating the completely bounded openings performance requirement and test method to clearly include cribs, cradles, bassinets and sleep accessories with sides made out of textile or other pliable materials, including removable textile or pliable material covers, under their scope;
  8. Changing the performance requirement for the maximum height of corner posts from 3 mm to 1.5 mm;
  9. Including a performance requirement and test method for the stability of cradles, bassinets and stands;
  10. Introducing performance requirements and test methods for stands that are designed or advertised for use with cribs, cradles and bassinets;
  11. Adding a performance requirement prohibiting the use of occupant restraints on cribs, cradles, bassinets and sleep accessories, and performance requirements and test methods limiting the length of cords and size of loops attached to cribs, cradles, bassinets, accessories and stands;
  12. Including minor administrative revisions to other sections to improve clarity and readability; and
  13. Providing a six-month transition period for the replacement of non-compliant cribs, cradles and bassinets available in the marketplace.

A more detailed description of the proposed requirements can be found below.

1. Prohibition of the sale, import, manufacture and advertisement of traditional drop-side cribs, cradles, bassinets and sleep accessories

In light of the safety concerns and alignment with the new U.S. requirements for cribs, Health Canada is proposing to prohibit the sale, importation, manufacture and advertisement of traditional drop-side cribs. This involves introducing a requirement that stipulates cribs with access sides having movable components intended to aid in access to the occupant must have those sides rigidly attached to the crib ends and contain no movable section less than 510 mm above the top of the mattress support in the lowest position. This also ensures that the movable portion of the crib access side does not create a toehold that could be used by the occupant to aid in climbing out of the crib. As traditional style drop sides on cradles, bassinets and sleep accessories pose the same hazard, the proposal also limits the movement of sides on these products to the uppermost portion.

2. Mattress support vertical impact test method for cribs and cradles

The current U.S. crib requirements feature a modified version of Health Canada’s mattress support vertical impact test for cribs. In order to best align requirements, Health Canada and the U.S. CPSC have agreed upon a common set of test requirements for both countries. These testing specifications closely resemble the existing Canadian method, but involve changing certain parameters, such as the cycle frequency (to one impact for every four seconds from one impact per second) and the test mattress, to allow for greater repeatability of the test. The equipment and the test parameters will also be aligned with the modified ASTM F1169-13 version of the mattress support vertical impact test.

3. Crib slat strength performance requirement and test method

In Canada, the CCBR currently contain strict requirements relating to slats, where the slats must not turn, dislodge, deform or become damaged when tested. Despite these strict requirements, Health Canada continues to receive reports of crib slats breaking or disengaging. Cribs are intended to accommodate babies of an older age group than cradles and bassinets, and crib slats are subjected to greater wear and tear. As a result, Health Canada is proposing to also align its requirements with the more stringent performance requirements and testing parameters of the ASTM F1169-13 crib slat strength test, which would involve applying a 356 N pull force to 25% of the crib’s slats.

4. Performance requirement for correct assembly of key structural components

Health Canada has received reports of incidents associated with the incorrect assembly of cribs. The incorrect assembly of cribs, cradles or bassinets has the potential to result in serious injury or death. Consequently, Health Canada proposes aligning its requirements with the new requirement in ASTM F1169-13 that stipulates crib designs must only allow for correct assembly of key structural components, such as side assemblies, end assemblies, mattress supports and stabilizing bars, or have permanent markings that indicate how to assemble the component. The proposed CCBR would require that these markings on cribs, cradles, bassinets, accessories and stands must be conspicuous in any misassembled state.

5. Accessory performance requirements and test methods

Accessories, such as sleep and change table accessories, are products that are designed or advertised for use with a crib, cradle or bassinet. They are designed to support the weight of a child and they can be placed on or fixed to the product with which they are used. Due to its structure, location, movement or failure, a crib, cradle or bassinet accessory may expose a product’s occupant to hazards, including openings that could lead to entrapment. Health Canada is proposing to align its requirements with the performance requirements and test parameters for openings, detachment and cord/strap length that assess entrapment in crib accessories from ASTM F1169-13. Additionally, ASTM F1169-13 requires that accessories meet other applicable ASTM standards, such as those for bassinets and change tables. The proposed structural integrity tests for sleep accessories and change table accessories are from the ASTM bassinet and change table standards respectively.

6. Rest angle and mattress flatness performance requirements

The potential for serious injury or death is present when infants and young children are not placed to sleep on a firm and flat sleeping surface. To limit the potential for suffocation or entrapment, a maximum mattress flatness and maximum rest angle is proposed. Revised ASTM F2194-13a includes a maximum rest angle (for rocking or swinging bassinets and cradles of 7° from the horizontal and, through a change to the standard’s scope, a 10° from the horizontal maximum allowable mattress flatness angle for all bassinets and cradles). To align its requirements with the U.S. CPSC’s new requirements, Health Canada is proposing a maximum rest angle of 7° from the horizontal, which, according to current science, should provide an adequate level of protection, for rocking or swinging cribs, cradles, bassinets, sleep accessories and stands. Based on the current science and a Health Canada risk assessment, Health Canada is proposing a maximum mattress flatness angle of 7° from the horizontal. The rationale for this proposed angle, which is stricter than the U.S. requirement, is that 10° from the horizontal is an angle at which infants might not be able to keep their airways clear. Health Canada’s proposal would still allow for some flexibility in manufacturing.

7. Completely bounded openings performance requirement and test method

Some cradles and bassinets are sold with textile or pliable material sides or a textile or pliable material cover that fits over the product’s frame. These covers may include snaps or zippers that can be undone for ease of removal. Between January 2000 and mid-August 2010, Health Canada received one report of an infant becoming entrapped between the bars of a bassinet’s metal frame and one report of an infant falling through the bars of a bassinet’s frame. Both of these incidents occurred when the frame was exposed as a result of the cover becoming unfastened. Although the current CCBR include a requirement intended to ensure that the product does not have any hazardous openings in which a child could become entrapped or fall through, the U.S. CPSC has adopted additional requirements that specify cradles and bassinets are to be tested with the textile or pliable material on the product, but without the snaps, zippers, etc., fastened. However, the U.S. CPSC does not address cribs with removable covers. In the future, it is possible that cribs with covers may arrive on the market. Therefore, Health Canada is proposing a clarification to the Regulations with respect to the requirements for completely bounded openings for cribs, cradles and bassinets with sides made of a textile or other pliable material. This proposal includes a requirement specifying that cribs, cradles, bassinets and sleep accessories with removable covers that can be taken off without the use of tools should be assessed for completely bounded openings without the snaps, zippers, etc., fastened. This testing would assess the foreseeable situation in which all of the removable cover’s fasteners have not been engaged after it has been removed for cleaning or replacement. This approach would improve safety should this situation be encountered in real life by minimizing the potential for hazardous openings being present in the product’s frame. While the existing Canadian test method for completely bounded openings assesses the same hazard related to completely bounded openings as the U.S. requirement, it differs in the manner in which the test is performed. Health Canada has simplified its approach by using the same test block currently specified in the Regulations to assess completely bounded openings in cribs, cradles, bassinets and sleep accessories rather than introducing an additional block.

8. Maximum height of corner posts

Corner posts on cribs, cradles and bassinets may pose a strangulation hazard because a baby’s clothing could catch on the post. To improve safety and better align its requirements with those of the United States, Health Canada is proposing to limit the height of corner posts on cribs, cradles, bassinets and sleep accessories from 3 mm to 1.5 mm. Bassinets and sleep accessories typically do not have corner posts. Bassinets and cradles sold in the United States have to meet the corner post requirement under the U.S. CPSC’s new rulemaking. Based on this situation with respect to cradles and bassinets and Health Canada’s recent cyclical enforcement testing of cribs, it is expected that the majority of cribs, cradles and bassinets on the Canadian market will already be compliant with this proposed requirement.

9. Cradle and bassinet stability performance requirement and test method

Health Canada is proposing to align its performance requirement and test method for cradle and bassinet stability with those the U.S. CPSC has recently adopted as law. This requirement is intended to make sure that the product does not tip over under a load of 10 kg, which represents the mean pull strength of a two- year-old male child. The inclusion of this requirement would further safeguard the stability of cradles and bassinets and further align Canadian and U.S. requirements.

10. Stands

In recent years, stands, in particular for bassinets, have become more popular on the Canadian market. Many sleep products are marketed for use both on and off a stand. Stands are supplied with the product, or sold separately and marketed for use with a specific product. Some stands are designed to accommodate a product that rests on it and others have latching or locking mechanisms that attach the product to the stand. Health Canada is aware of a death that resulted from a bassinet which was not attached to the stand on one side when the infant was put down for a nap. Health Canada is proposing a mandatory warning for stands that would alert caregivers to the hazards associated with using a product when it is not appropriately secured to the stand. This warning, in addition to the proposed stability requirement and test method to which stands will be subjected, would address the hazards related to stands. The overall safety of stands would also be improved by the introduction of general safety provisions for stands.

Heath Canada staff have reviewed the U.S. CPSC’s removable bassinet bed attachment requirement and have concerns regarding its suitability. There are a number of options for compliance with the requirement. Two of these options (the stand shall not support the bassinet bed and the sleep surface of the bassinet bed shall be at least 20° off from the horizontal plane when the bassinet bed is in the unlocked position) involve designing the product in such a way to alert the caregiver that the bassinet bed is not appropriately attached to the stand (i.e. the product would appear unsafe when fasteners on the stand are unlatched or unlocked). Many removable bassinet beds incorporate handles such that they can be moved from room to room with the child in the product. It is reasonably foreseeable that some caregivers may attempt to attach the bassinet bed to its stand while the child is in the product. Product designs that cause the bassinet bed to collapse or tilt to a severe angle when unlatched or unlocked from the base may expose children to unnecessary hazardous conditions. Health Canada staff submitted a formal comment to this effect to the U.S. CPSC during its public consultation preceding the adoption of these new requirements. The U.S. CPSC has not expressed opposition to the Canadian approach. Due to these concerns, Health Canada is not proposing to align its requirements with this aspect of the U.S. CPSC requirements for cradles and bassinets.

11. Restraint system, attached cord length and loops

The presence of cords and loops in an infant’s sleeping environment has the potential to lead to serious injury or death. Health Canada is aware of incidents and deaths that have occurred when a child in a crib has gained access to a cord or loop. Therefore, Health Canada is proposing to include requirements related to attached cord length and loops in the infant’s sleep environment. The U.S. CPSC has regulated against restraint systems in the cradles and bassinets because restraints are unnecessary in cradles and bassinets and are, therefore, more likely to be unused. The U.S. CPSC is aware of incidents involving other products with restraints, such as swings, infant carriers and bouncers. (see footnote 1) Health Canada is proposing to align its requirements with those adopted by the U.S. CPSC for cribs, cradles and bassinets with respect to restraint systems in cradles and bassinets, attached cord length on cribs, and loops on accessories, and broadening the scope of these requirements to address restraint systems in cribs, attached cord length on cradles, bassinets, accessories and stands, and loops attached to cribs, cradles, bassinets and stands, in addition to accessories.

12. Minor revisions to improve clarity

Minor adjustments to language and format have been made in order to increase the clarity, organization and readability of the proposed CCBR. For example, the current CCBR require that all cribs display the following warning, “Ensure that the sides of this crib are properly latched or locked in the appropriate position when a child is left unattended in it.” However, not all crib sides have movable components and, therefore, do not have multiple adjustment positions. The proposed CCBR would make it clear that certain warnings are only required for products with particular design characteristics.

13. Transition period

The proposed CCBR would provide for a transition period of six months during which time the current CCBR would continue to apply to all cribs, cradles and bassinets sold, advertised, imported or manufactured in Canada. This provision would allow industry the opportunity to modify or redesign its products to meet regulatory requirements, and verify the regulatory compliance of its products through product testing.

Regulatory and non-regulatory options considered

Status quo

The option of maintaining the current CCBR was rejected because it was determined that regulatory changes would be required in order to provide an enhanced level of safety with respect to the use of cribs, cradles, bassinets and accessories. These proposed changes would address safety concerns, such as those specifically associated with traditional drop-side cribs that have been identified as causing serious injuries or deaths. If the proposed CCBR are not adopted, the supply of potentially unsafe cribs, cradles and bassinets to Canadian consumers would not be prohibited. Additionally, the CCBR would not be further aligned with the U.S. law.

Prohibition of the manufacturing, sale, advertisement and importation of all types of movable crib, cradle, bassinet or sleep accessory sides in Canada

This option was rejected because it was determined that the proposed CCBR could otherwise include a requirement to prohibit the supply of cribs, cradles, bassinets and sleep accessories with sides that are not rigidly attached to the crib, cradle, bassinet or sleep accessory ends, while allowing for the uppermost portion of the side to move. The safety issues, which have been identified with traditional drop sides, would be addressed by ensuring that the lower part of the crib, cradle, bassinet or sleep accessory side is rigidly attached to the product’s ends. This would eliminate the potential for the lower part of the side to separate from the ends, creating a gap between the side and the mattress in which a child could become entrapped. This would still allow the upper portion of the crib, cradle, bassinet or sleep accessory side to move in order to allow for easier access to the child. A prohibition of all types of movable sides would limit caregivers to the use of fixed-side cribs, cradles, bassinets and sleep accessories. This could create difficulties for some caregivers who are small in stature or who have back problems. Additionally, the CCBR would not be further aligned with the U.S. law.

Adoption of the proposed CCBR

Adopting the proposed CCBR was determined to be the preferred method of protecting the health and safety of young children using cribs, cradles, bassinets and accessories. The proposed CCBR are intended to clarify certain aspects of the previous CCBR, as well as put in place more stringent safety requirements concerning access sides, product assembly and crib slat strength. Additionally, this option would address requests from stakeholders to further align Canadian and U.S. requirements for cribs, cradles, bassinets, accessories and stands.

Benefits and costs

The following table provides the results of the cost-benefit analysis. The annual results for a 20-year period are reported as the present value (see footnote 2) (PV) of cash flows. Over a 20-year period after the proposed CCBR become law, it is estimated that the changes could provide a net present value (see footnote 3) (NPV) of approximately $20.60 million. When annualized (see footnote 4) over the study period, the net present value amounts to $1.94 million per year. (see footnote 5)

Cost-benefit statement
Quantified impacts (in CAN$, in millions, Dec. 2012 price level / constant dollars)
  Total PV Annualized Cost
Benefits By stakeholder  
Avoided injuries (see footnote 6) Young children $17.05 $1.61
Avoided fatalities (see footnote 7) Young children $15.74 $1.49
Total benefits $32.79 $3.09
Costs By stakeholder  
Higher product prices Consumer $3.42 $0.32
Lost resale income Consumer $4.03 $0.38
Government costs Health Canada $1.50 $0.14
Compliance costs Small business $2.70 $0.26
Compliance costs Medium–Large business $0.54 $0.05
Total costs $12.19 $1.15
Net benefits $20.60 $1.94
Benefit-cost ratio 2.69  
Qualitative impacts
Consumer (positive)
  • Consumers are expected to benefit from avoided injuries and fatalities relating to the regulatory proposal for cradle vertical impacting, and for accessories to cribs, cradles and bassinets, but estimates of avoided cradle injuries and fatalities were not projected due to insufficient data.
  • Consumers are expected to experience reduced health care costs and enhanced quality of life.
Industry (positive)
  • Industry may experience higher sales in export markets as Canadian products become increasingly recognized by foreign consumers for high standards of safety.
  • Industry may face reduced claims for liability as a result of incidents involving their products.
  • Industry may experience lower compliance costs due to improved alignment of U.S. and Canadian regulatory requirements.
Child care centres (negative)
  • Seven provinces and one territory (Manitoba, Ontario, Quebec, New Brunswick, Newfoundland and Labrador, Nova Scotia, Prince Edward Island and Yukon) have legislation that requires licensed child care operations to use cribs that meet federal requirements. Depending on the enforcement approach taken by the provincial and territorial governments, child care centres in affected regions may face costs associated with the replacement of equipment.
  • There may be a rise in health care costs of child care workers due to increased back problems relating to repeated lifting and lowering of children into non-drop-side cribs.
Results

The cost-benefit analysis of the proposed CCBR indicates that Health Canada has a strong economic basis for adopting the regulatory proposal as it would deliver net benefits to Canadians in excess of $20 million.

Costs would initially be borne by laboratories testing cribs, cradles and bassinets to determine whether the products meet the proposed regulatory requirements. These costs would be passed through to manufacturers having their products tested. Manufacturers would also face costs if their products do not meet the proposed requirements, thus needing modifications or redesigns. These costs would be passed through to product wholesalers, retailers and, ultimately, to Canadian consumers. In addition, the Government of Canada would experience economic costs through regulatory compliance promotion, monitoring, product testing and enforcement. These are opportunity costs involving the reallocation of existing resources; additional funding would not be requested and additional people would not be hired.

Some child care operations may be impacted by provincial or territorial legislation that requires them to use cribs in their facilities that meet the federal requirements for cribs. It is important to note that it is these provincial and territorial requirements that directly impose the requirement on child care facilities to use a crib that is compliant with the federal regulations, and not the federal regulations themselves. The CCBR and the supporting CCPSA cover the manufacture, import, advertisement or sale of cribs, cradles and bassinets, but do not apply to the use of these products. Therefore, any costs to this group imposed by provincial and territorial legislation cannot be influenced by Health Canada. Health Canada intends to work with and support its provincial and territorial counterparts during the implementation of the proposed CCBR.

The cost-benefit analysis estimated the costs to Canadians that would be associated with higher prices for cribs, cradles and bassinets, and the inability to resell products that do not meet the requirements. The impact on Canadians of higher crib, cradle and bassinet prices of $1.00, $0.45 and $0.60, respectively, was estimated.

The proposed CCBR are intended to deliver benefits to Canadians in terms of avoided non-fatal and fatal injuries related to the use of cribs, cradles and bassinets.

The proposed CCBR would also increase the extent to which product requirements are aligned between Canada and the United States. For industry, alignment provides broader access to international markets by making it easier and more economically viable to market and compete in a global marketplace. Internationally aligned legislation is also more readily accepted by industry, which leads to higher compliance rates.

Consumers
Costs

Canadian consumers may face costs as a result of the proposed CCBR. These costs would be related to higher product prices and prohibitions on the resale of non-compliant cribs, cradles and bassinets. With respect to higher product prices, the cost-benefit analysis indicated that the price of a typical crib, cradle or bassinet may increase on average by a maximum of $1.00 for cribs, $0.45 for cradles and $0.60 for bassinets. These price increases are expected to be maximum averages resulting from pass-through product testing, modification or redesign costs. The regulatory proposal would also result in an adjustment to the scope of which cribs, cradles and bassinets are prohibited from the sale, advertisement, manufacture or importation in Canada. Canadians holding used cribs, cradles and bassinets not meeting the proposed requirements would therefore not be able to advertise or sell (including giving away or donating) their used cribs, cradles and bassinets.

A model of future product sales was made, based on estimates that about 225 000 cribs, 20 000 cradles and 100 000 bassinets are sold annually in Canada. These sales were estimated in the future based on birth projections by Statistics Canada. It was projected that a total of approximately 7.73 million cribs, cradles and bassinets would be sold over the 20-year period of analysis. In total, the 20-year present value of costs, discounted at a rate of 7%, is approximately $3.42 million.

Estimates were made of the costs to Canadians for lost income from the resale of cribs, cradles and bassinets not meeting the proposed federal requirements. These lost incomes represent the receipts that Canadians would otherwise receive from the resale of products. The regulatory proposal would prohibit the sale of products held that do not meet the proposed requirements. These estimates are made by combining estimates of the number of cribs, cradles and bassinets owned, expectations regarding the number of these products that would not meet the proposed requirements, resale rates and resale revenues. In total, the costs of lost product resale revenues were estimated at approximately $4.03 million over 20 years when discounted at a rate of 7%.

Benefits

Some aspects of existing crib, cradle and bassinet designs are contributing to non-fatal and fatal incidents involving infants in Canada. Adopting the regulatory proposal would reduce the societal inequities by helping to protect children who otherwise do not have an option for avoiding consumer products that may pose health and safety hazards. Canadians would benefit from reduced numbers of non-fatal and fatal injuries resulting from the use of cribs, cradles and bassinets.

The approach for valuing these benefits involved reviewing Canadian and U.S. data to develop estimates of the number of non-fatal and fatal incidents that would be avoided in Canada as a result of the regulatory proposals. These data sources included Health Canada’s Product Safety Information System, the Public Health Agency of Canada’s Canadian Hospitals Injury Reporting and Prevention Program, and a number of databases and reports from the United States, including the U.S. CPSC’s In-Depth Investigation File and National Electronic Injury Surveillance System.

A profile of non-fatal and fatal injuries avoided was projected into the future. These estimates were coupled with values per avoided non-fatal and fatal incident. Minor injuries were monetized at a value of $10,000, major injuries at $500,000, and fatalities (see footnote 8) at $6.8 million (all in 2010 dollars), considering the value of a statistical life. In total, $32.79 million in discounted benefits are anticipated over the 20-year time frame as a result of the forecasted reduction in injuries and fatalities.

Child care centres

Legislation in seven provinces and one territory (Manitoba, Ontario, Quebec, New Brunswick, Newfoundland and Labrador, Nova Scotia, Prince Edward Island and Yukon) requires that licensed child care operations use cribs that meet federal requirements. Therefore, if changes were introduced into federal regulations to meet provincial and territorial legislation, licensed child care operations in these jurisdictions may assume costs, resulting from the provincial and territorial legislation, to replace their inventory of cribs with models that are compliant with the proposed federal requirements. These costs are dependent upon the enforcement plans of the provincial and territorial governments.

Enforcement activities with respect to the replacement of cribs used in child care facilities fall under the jurisdiction of the provincial and territorial governments. Should the proposed prohibition on the manufacture, sale, importation or advertisement of traditional drop-side cribs come into force, the onus would be on the provincial and territorial governments to determine an appropriate period of time for the replacement of cribs with traditional drop sides used in child care facilities in provinces and territories with legislation requiring the use of cribs that are compliant with federal requirements. Health Canada would continue to provide guidance and support to its provincial and territorial counterparts in interpreting federal requirements to help ease any indirect regulatory burden.

Industry

Some costs may be assumed by product testing laboratories, product manufacturers, and product wholesalers and retailers. Information from these groups provided evidence that while costs may occur, they would be passed through the supply chain and would ultimately be borne by Canadian consumers.

A survey of product testing laboratories concluded that the incremental costs associated with the proposed CCBR would be relatively small, are not expected to have any impacts on product testing laboratories, and would be passed through to product manufacturers. It is assumed that the maximum typical price increase would be 20% of existing costs (higher than indicated by the test facilities), or an average of $0.10 per crib.

The results of a survey of North American product manufacturers indicated that the majority of manufacturers supplied products to Canadian and U.S. markets, and the models supplied to each country tended to be the same. Manufacturers also indicated that the proposed CCBR would not result in significant cost impacts on crib, cradle and bassinet manufacturers and would not result in significant increases in product prices. To assess the net benefits of the regulatory proposals, a maximum average cost increase per product was assumed and modelled. The maximum average cost increases modelled were $1.00 per crib, $0.45 per cradle and $0.60 per bassinet (including the effects of potential test cost increases and product modification cost increases). These increases represent less than 1% of product prices. Note that these increases are much higher than indicated in the survey and are used only in a precautionary assessment of the potential costs of the regulatory proposal.

A survey of product wholesalers and retailers indicated that any cost increases associated with the proposed changes to the Regulations would be passed through to the consumer. Canadian consumers would therefore be expected to assume the costs of product testing, product redesign and product modification. The companies also indicated that a minimum of six months would be required to sell existing inventories of cribs, cradles and bassinets.

Government

The annual costs associated with the promotion, monitoring, testing and enforcement of the proposed Regulations incurred by the Government of Canada were estimated at approximately $140,000. The total 20-year costs to the Government to conduct promotional, monitoring, testing and enforcement activities associated with the proposed Regulations were estimated at approximately $1.50 million. These 20-year costs were discounted at a rate of 7%. These are opportunity costs involving the reallocation of existing resources; additional funding would not be requested and additional staff would not be hired.

A copy of the complete cost-benefit analysis is available upon request.

“One-for-One” Rule

The “One-For-One” Rule does not apply to this regulatory proposal as it does not impose additional administrative costs.

Small business lens

The small business lens applies to this proposal. The completed checklist follows the RIAS. During the cost-benefit analysis consultations, both large and small businesses were consulted. In terms of manufacturers, smaller businesses were found to have slightly higher costs for testing cribs than larger companies, since test fees from testing laboratories are applied “per model,” and those costs per product are smaller for models with higher sales.

The number of firms (i.e. number of firms involved in the manufacture and/or importation of cribs, cradles and bassinets) that would be affected by these regulatory changes was estimated at about 30 (see footnote 9) companies, based on the information from the cost- benefit analysis study that was conducted. This estimate was based on available information from the Juvenile Products Manufacturers Association and on contact information provided by Health Canada that was analyzed.

Since traditional drop-side cribs have been effectively prohibited in the United States, the concentration of these products on the market has diminished greatly. A number of major industry members have indicated to Health Canada that they are no longer manufacturing, selling, importing or advertising traditional drop-side cribs in Canada. Therefore, the introduction of a Canadian prohibition on the sale, advertisement, import and manufacture of traditional drop-side cribs is projected to have a reduced impact on the costs faced by all businesses, regardless of their size. The majority of the proposed requirements align with specifications from U.S. legislation and voluntary standards with which the majority of North American cribs are already complying. A number of North American cradle and bassinet industry members indicate compliance, through the Juvenile Products Manufacturers Association certification program, with the voluntary industry standard that the U.S. CPSC has adopted into regulation.

  Initial Option Flexible Option
Short description An immediate coming into force of the proposed Regulations A coming-into-force period of six months
Maximum number of small businesses impacted 30 30
Annualized Average
($ 2012)
Present Value (see reference 1*)
($ 2012)
Annualized Average
($ 2012)
Present Value (see reference 2*)
($ 2012)
Total compliance costs $243,980 $1,713,640 $226,775 $1,592,775
Average cost per small business $8,130 $57,120 $7,560 $53,090

It is proposed that the Regulations come into force six months after the day on which they are published in the Canada Gazette, Part II. This would respond to stakeholder feedback, provide stakeholders with a flexible implementation option and respect the World Trade Organization Agreement on Technical Barriers to Trade requirement, which allows a reasonable interval between the publication of technical regulations and their entry into force in order to allow time for producers in exporting countries, particularly in developing countries, to adapt their products or methods of production to the requirements of the importing country. This is also consistent with the standard transition period of six months between versions of ASTM International standards.

Consultation

On September 29, 2010, Health Canada released a consultation document regarding the proposed changes to the CCBR. The following three options were proposed through the consultation:

  1. Maintain the status quo.
  2. Amend the Regulations to include several major changes that would align the Canadian requirements more directly with those that have been proposed in the United States. This would include prohibiting the sale, importation, manufacture and advertisement of cribs with sides that are not rigidly attached to the crib ends while allowing for the uppermost portion of the crib side to fold, pivot or move with respect to the frame. (This option is reflected in the proposed Cribs, Cradles and Bassinets Regulations.)
  3. Prohibit the sale, importation, manufacture and advertisement of all types of movable crib sides in Canada.

In the consultation document, Health Canada indicated that the second option would be preferred because it would align with the requirements that the U.S. CPSC had proposed (and has subsequently adopted) relating to the overall safety of cribs, cradles and bassinets. Manufacturers of cribs, cradles and bassinets have historically requested greater alignment of the Canadian CCBR with other recognized international standards, particularly those of the United States, as it minimizes the impact on their industry. The second option would also address important safety issues that have specifically been identified with traditional crib drop sides.

This consultation involved the publication of a news release by Health Canada, as well as the posting of the consultation document on Health Canada’s Web site. Health Canada also directly mailed the consultation document to a targeted group of approximately 2 000 stakeholders, which included public health organizations, provincial/territorial public health authorities, retailers, manufacturers, importers and product-testing laboratories. Notification of this consultation was also sent to interested parties via email through Health Canada’s Consumer Product Safety listserv. Interested parties were invited to provide comments on the proposal within 75 days.

A total of twenty-five submissions were received during the comment period. Fourteen of the respondents supported the option to further align Canadian and U.S. safety standards and to allow the uppermost portion of the crib side to move, nine respondents were not in support of the proposal to prohibit the sale, importation, manufacture and advertisement of the traditional style of crib drop-sides (option 3), and two respondents did not give a clear indication of their position with respect to the proposal.

Responses were received from ten consumers, seven public health organizations, three retailers, one provincial coroner’s office, two importers, one inventor and one industry group. Six consumers opposed the prohibition of the sale, importation, manufacture and advertisement of traditional crib drop sides because they were concerned about the impact on caregivers who are of smaller stature or have back problems. Two retailers indicated that they did not feel that traditional crib drop sides were unsafe and expressed concerns regarding the impact on Canadian businesses. One importer was concerned that the proposal limiting the movement of crib sides to the uppermost portion would result in pinching and toehold hazards.

The majority of public health organizations supported the proposed CCBR, but some expressed concerns regarding the impact upon the second-hand market, daycares and lower socio-economic families. The provincial coroner’s office was in support of the proposal to further align Canadian and U.S. safety standards and to allow the uppermost portion of the crib side to move. However, the coroner’s office stressed the need to ensure that regulatory actions are supported by incident data. The industry was in support of the proposed changes for the most part, but urged Health Canada to consider reasonable implementation periods, such as 6 to 12 months, when implementing any regulations. A general response email was sent to the stakeholders that provided comments.

As many of the comments received in response to the consultation mentioned the impact that the proposed CCBR would have on lower-income families, the second-hand market, daycares and Canadian businesses, it was necessary to commission a cost- benefit analysis to determine if the regulatory proposals would have a benefit for Canadians. As previously stated, the cost-benefit analysis determined that the proposed CCBR would provide a net benefit to Canadians.

Consultation with provincial and territorial governments regarding child care facilities

In 2011, 2012 and 2014, Health Canada consulted with its provincial and territorial counterparts regarding the proposed CCBR. Those provincial and territorial government departments responsible for regulating child care facilities were contacted, by telephone and in writing, to inform them of the proposed changes to the CCBR and to solicit their input regarding the impact that these proposed changes may have on provincial and territorial legislation. It is important to note that the proposed changes to the CCBR do not prohibit the “use” of cribs with traditional drop sides, or other products that do not meet the new performance standards or follow the new test methods.

The use of drop-side cribs in child care facilities varies greatly across Canada (approximately 90% to 1%). A number of provinces and territories were unable to comment on the level of use of drop-side cribs in their jurisdictions. In provinces with legislation requiring the use of either a crib or a playpen, child care facilities were more likely to make use of playpens (which are not impacted by this proposal). Playpens were also predominantly used in provinces and territories with legislation that is not directly linked to the Hazardous Products Act (of which Part I and Schedule I have been repealed and replaced by the CCPSA), the CCPSA or the CCBR. The provinces and territories were unable to comment on what period of time would be afforded to child care facilities required to replace drop-side cribs. Some provinces and territories provide limited funding for the replacement of equipment or to cover administrative costs.

In 2014, Health Canada sent a letter to the affected provinces and territories, soliciting feedback regarding the potential impact of the proposed regulatory changes. Responses were received from Prince Edward Island, Ontario, Manitoba, Nova Scotia and Quebec. Prince Edward Island indicated that there may be costs associated with replacing drop-side cribs in daycares. Ontario would determine an appropriate period for the replacement of drop-side cribs, coupled with a knowledge-dissemination strategy regarding the impact of the regulatory changes on daycares. Manitoba stated that the province would need time to notify daycares of the changes and daycares would need time to make the necessary adjustments. Nova Scotia commented that the province did not anticipate that the proposed regulatory changes for cribs would have a negative impact on child care legislation. Quebec indicated that consideration may be given to including a transition period for the replacement of drop-side cribs in the province’s child care legislation in order to reduce the financial impact on child care centres.

Some public health organizations that provided responses during the 2010 consultation on the proposed CCBR expressed concern regarding the financial impact of the proposal on child care facilities. There was also concern that the lack of access of drop-side cribs would make it difficult for many employees of child care facilities, who are usually female and of smaller stature, to access children in regular cribs.

Regulatory cooperation

The proposed CCBR would further align requirements with those of the United States and provide clarity for industry.

Health Canada has actively collaborated with the U.S. CPSC through its participation on ASTM crib, cradle and bassinet standard subcommittees and in discussions with U.S. CPSC staff. All of the proposed major changes would further align the Canadian Regulations with the requirements recently adopted for cribs, cradles and bassinets in the United States. Over the past few years, Health Canada and the U.S. CPSC have worked closely together to develop a common set of test requirements for particular hazards.

Minor differences between Canadian and U.S. requirements remain; however, they are not anticipated to have a significant impact on movement or trade of products between the two countries. These differences exist where Canadian requirements are more stringent and protective, where evidence has suggested the potential for increased safety benefits, or where differences were necessitated as a result of Canadian drafting conventions.

Although this regulatory proposal is not a commitment under the Joint Action Plan for the Canada–United States Regulatory Cooperation Council, it reflects the objectives of the Council by further aligning regulatory requirements between the United States and Canada, and helping to reduce regulatory barriers to cross-border trade.

Rationale

In the recent past, Health Canada has worked in collaboration with a number of companies for them to voluntarily recall various models of drop-side cribs when reported incidents have underlined potential health and safety hazards related to the use of these products.

The proposed CCBR would further Health Canada’s objective of addressing emerging hazards in order to help protect the health and safety of young children using cribs, cradles and bassinets.

Greater alignment of Canadian requirements, such as those for traditional drop-side cribs, crib impacting, crib slat strength and accessories to cribs, cradles and bassinets, with internationally recognized standards should ease the regulatory burden on industry. U.S. companies that are selling their products in Canada should benefit from the increased alignment between Canadian and U.S. requirements.

Over the past few years, Health Canada has been actively participating in discussions with Canadian and U.S. manufacturers, safety advocates and government officials regarding the overall safety of cribs. Health Canada has identified the need for regulatory changes relating to traditional drop-side cribs in order to further safeguard the health of infants and young children.

Additionally, the cost-benefit analysis demonstrates that there is a strong economic basis for adopting the proposed CCBR. The costs of the regulatory proposal have a present value of $12.19 million over 20 years and discounted at a rate of 7%. The benefits have a present value of $32.79 million over 20 years and discounted at a rate of 7%. Thus, the regulatory proposal would deliver net benefits to Canadians in excess of $20.60 million.

Strategic environmental assessment

This proposal underwent a preliminary scan in accordance with the strategic environmental assessment (SEA) policy and a SEA form was completed. The SEA concluded that this regulatory proposal is not expected to have any environmental impacts.

Implementation, enforcement and service standards

These proposed CCBR would not result in any major changes to Health Canada’s enforcement activities. Compliance and enforcement would be facilitated by more clearly worded requirements laid out by the amended CCBR, as well as greater alignment between Canadian and U.S. requirements.

Compliance and enforcement of the proposed CCBR will follow established departmental approaches and procedures, including sampling and testing of products, inspection at retail and follow-up on complaints made by the Canadian public, public health organizations and trade. Non-compliant products will be subject to the actions available to Health Canada inspectors and other officials and will depend on the seriousness of the circumstances. These actions may include obtaining a voluntary commitment to product correction by industry, negotiation with industry for the voluntary removal of non-compliant products from the market, seizure, orders for recall or other measures, administrative monetary penalties and prosecution under the CCPSA. Health Canada will also seek to maximize compliance with the CCBR through ongoing industry and retailer education, and maximize crib, cradle and bassinet safety through consumer education.

Contact

Ms. Megan Fairfull
Consumer Product Safety Directorate
Healthy Environments and Consumer Safety Branch
Health Canada
Address Locator: 4908B
269 Laurier Avenue West
Ottawa, Ontario
K1A 0K9
Fax: 613-952-2551
Email: megan.fairfull@hc-sc.gc.ca

Small Business Lens Checklist

1. Name of the sponsoring regulatory organization:

Health Canada

2. Title of the regulatory proposal:

Cribs, Cradles and Bassinets Regulations

3. Is the checklist submitted with a RIAS for the Canada Gazette, Part I or Part II?

checked check box Canada Gazette, Part I     check box Canada Gazette, Part II

A. Small business regulatory design

I Communication and transparency Yes No N/A
1. Are the proposed Regulations or requirements easily understandable in everyday language? checked check box check box check box
These Regulations have been rewritten and reorganized to clarify requirements and language for industry, and to better reflect the wording of the requirements currently set out in the United States, with which many industry members are already familiar.
2. Is there a clear connection between the requirements and the purpose (or intent) of the proposed Regulations? checked check box check box check box
The requirements directly address health and safety concerns with cribs, cradles and bassinets identified by Health Canada and the United States via reports of incidents and injuries.
3. Will there be an implementation plan that includes communications and compliance promotion activities, that informs small business of a regulatory change and guides them on how to comply with it (e.g. information sessions, sample assessments, toolkits, Web sites)? checked check box check box check box
Health Canada is committed to working with small businesses to aid them in understanding and complying with the new requirements. Additional supporting information and industry guidance will be made available on Health Canada’s Web site, and regional product safety inspectors are available to assist businesses with any regulatory and compliance questions.
4. If new forms, reports or processes are introduced, are they consistent in appearance and format with other relevant government forms, reports or processes? check box check box checked check box
No new forms, reports or processes are being introduced.
II Simplification and streamlining Yes No N/A
1. Will streamlined processes be put in place (e.g. through BizPaL, Canada Border Services Agency single window) to collect information from small businesses where possible? check box check box checked check box
Currently, relevant information is collected from industry on a case-by-case basis to verify compliance. No changes are occurring to the type of information that would be collected.
2. Have opportunities to align with other obligations imposed on business by federal, provincial, municipal or international or multinational regulatory bodies been assessed? check box check box checked check box
No ongoing obligations are affected by these proposed Regulations.
3. Has the impact of the proposed Regulations on international or interprovincial trade been assessed? checked check box check box check box
The proposed Regulations are not expected to have any impact on international or interprovincial trade, as they are moving towards improved alignment with our major trading partner, the United States.
4. If the data or information, other than personal information, required to comply with the proposed Regulations is already collected by another department or jurisdiction, will this information be obtained from that department or jurisdiction instead of requesting the same information from small businesses or other stakeholders? (The collection, retention, use, disclosure and disposal of personal information are all subject to the requirements of the Privacy Act. Any questions with respect to compliance with the Privacy Act should be referred to the department’s or agency’s ATIP office or legal services unit.) check box check box checked check box
Any data that is required to be collected by these Regulations to verify compliance is not collected by any other department.
5. Will forms be pre-populated with information or data already available to the department to reduce the time and cost necessary to complete them? (Example: When a business completes an online application for a licence, upon entering an identifier or a name, the system pre-populates the application with the applicant’s personal particulars such as contact information, date, etc. when that information is already available to the department.) check box check box checked check box
No forms are required for these Regulations. Health Canada provides flexibility to industry on how the information to verify compliance is completed.
6. Will electronic reporting and data collection be used, including electronic validation and confirmation of receipt of reports where appropriate? check box check box check box
These proposed Regulations do not include any reporting requirements.
7. Will reporting, if required by the proposed Regulations, be aligned with generally used business processes or international standards if possible? check box check box checked check box
No reporting is required by these Regulations.
8. If additional forms are required, can they be streamlined with existing forms that must be completed for other government information requirements? check box check box checked check box
No forms are required by these Regulations.
III Implementation, compliance and service standards Yes No N/A
1. Has consideration been given to small businesses in remote areas, with special consideration to those that do not have access to high-speed (broadband) Internet? checked check box check box check box
Health Canada regional product safety inspectors are available to small business in remote areas. The Consumer Product Safety Program has 12 regional offices across the country. There is a toll-free phone number that connects the caller to the closest regional office, along with a general email address.
2. If regulatory authorizations (e.g. licences, permits or certifications) are introduced will service standards addressing timeliness of decision making be developed that are inclusive of complaints about poor service? check box check box checked check box
No regulatory authorizations are introduced with these Regulations.
3. Is there a clearly identified contact point or help desk for small businesses and other stakeholders? checked check box check box check box
Health Canada’s regional product safety inspectors are available to small businesses in any province. There is a toll-free telephone number that connects the caller to the closest regional office, along with a general email address.

B. Regulatory flexibility analysis and reverse onus

IV Regulatory flexibility analysis Yes No N/A
1.

Does the RIAS identify at least one flexible option that has lower compliance or administrative costs for small businesses in the small business lens section?

Examples of flexible options to minimize costs are as follows:

  • Longer time periods to comply with the requirements, longer transition periods or temporary exemptions;
  • Performance-based standards;
  • Partial or complete exemptions from compliance, especially for firms that have good track records (legal advice should be sought when considering such an option);
  • Reduced compliance costs;
  • Reduced fees or other charges or penalties;
  • Use of market incentives;
  • A range of options to comply with requirements, including lower-cost options;
  • Simplified and less frequent reporting obligations and inspections; and
  • Licences granted on a permanent basis or renewed less frequently.
checked check box check box check box
It is proposed that a six-month coming-into-force period be established in these Regulations. This provides stakeholders with greater flexibility prior to implementation.
2. Does the RIAS include, as part of the Regulatory Flexibility Analysis Statement, quantified and monetized compliance and administrative costs for small businesses associated with the initial option assessed, as well as the flexible, lower-cost option? check box check box checked check box
No flexible option has been provided, as no options were found to reduce costs for small businesses.
3. Does the RIAS include, as part of the Regulatory Flexibility Analysis Statement, a consideration of the risks associated with the flexible option? (Minimizing administrative or compliance costs for small business cannot be at the expense of greater health, security or safety or create environmental risks for Canadians.) checked check box check box check box
Risks are minimal, as the majority of cribs, cradles and bassinets manufactured currently are expected to meet the requirements, as they have been in place in the United States since 2012. Therefore, the introduction of a similar Canadian prohibition on the sale, advertisement, import and manufacture of traditional drop-side cribs is projected to have a relatively smaller impact on the costs faced by all businesses, regardless of their size.
4. Does the RIAS include a summary of feedback provided by small business during consultations? checked check box check box check box
Small businesses were consulted by Health Canada, and their input was taken into consideration.
V Reverse onus Yes No N/A
1. If the recommended option is not the lower-cost option for small business in terms of administrative or compliance costs, is a reasonable justification provided in the RIAS? check box check box checked check box
A six-month coming-into-force period would provide industry with time to redesign, test and supply new product models.

PROPOSED REGULATORY TEXT

Notice is given that the Governor in Council, pursuant to section 37 of the Canada Consumer Product Safety Act (see footnote a), proposes to make the annexed Cribs, Cradles and Bassinets Regulations.

Interested persons may make representations concerning the proposed Regulations within 75 days after the date of publication of this notice. All such representations must cite the Canada Gazette, Part I, and the date of publication of this notice, and be addressed to Megan Fairfull, Project Officer, Risk Management Bureau, Consumer Product Safety Directorate, Department of Health, Address Locator 4908B, 269 Laurier Avenue W., Ottawa, Ontario K1A 0K9 (fax: 613-952-2551; email: megan.fairfull@hc-sc.gc.ca).

Ottawa, July 15, 2015

JURICA ČAPKUN
Assistant Clerk of the Privy Council

CRIBS, CRADLES AND BASSINETS REGULATIONS

INTERPRETATION

Definitions

1. The following definitions apply in these Regulations.

INFORMATION AND ADVERTISING

GENERAL PROVISIONS

Reference to Act or Regulations

2. Information that appears on or that accompanies a crib, cradle, bassinet, accessory or stand, and any advertisement of one, must not make any direct or indirect reference to the Act or these Regulations.

Advertising

3. An advertisement must not show a crib, cradle, bassinet, accessory or stand in any way that is contrary to the warnings set out in sections 10 to 36.

PRESENTATION OF INFORMATION

Presentation — general

4. The information required by these Regulations must meet all of the following requirements:

Print

5. (1) The required information must be printed in a standard sans-serif type that

Height of type

(2) The height of the type is determined by measuring an upper-case letter or a lower-case letter that has an ascender or a descender, such as “b” or “p”.

Signal words

6. (1) The signal words “WARNING” and “MISE EN GARDE” must be displayed in boldfaced, upper-case type not less than 5 mm in height.

Other information — height of type

(2) All other required information must be displayed in type not less than 2.5 mm in height.

REQUIREMENTS FOR CRIBS, CRADLES, BASSINETS, ACCESSORIES AND STANDS

Required information

7. The following information must appear on every crib, cradle and bassinet and on every accessory and stand that is sold separately, as well as on any packaging in which one of those products is displayed to the consumer:

Assembly and use — cribs, cradles and bassinets

8. (1) The following information must appear on every crib, cradle and bassinet in text, drawings or photographs, or in any combination of them, that illustrate the same information:

Assembly and use — accessories

(2) The following information must appear on every accessory in text, drawings or photographs, or in any combination of them, that illustrate the same information:

Exception — accessories supplied with product

(3) If the accessory is supplied with a crib, cradle or bassinet, the information required by subsection (2) may appear on either the accessory or on the crib, cradle or bassinet.

Assembly and use — stands

(4) The following information must appear on every stand in text, drawings or photographs, or in any combination of them, that illustrate the same information:

Exception — stands supplied with product

(5) If the stand is supplied with a crib, cradle or bassinet, the information required by subsection (4) may appear on either the stand or on the crib, cradle or bassinet.

Warnings — pouches

9. Despite paragraph 4(b), the information that is required by section 8 may be contained in or on a pouch that is permanently affixed to the crib, cradle, bassinet, accessory or stand if the relevant warnings set out in sections 10 to 36 are provided with that information.

ADDITIONAL REQUIREMENTS FOR CRIBS

Warning — all cribs

10. The following warning or its equivalent must appear on every crib:

WARNING

MISE EN GARDE

Warning — cribs with access side

11. The following warning or its equivalent must appear on every crib that has an access side, immediately after the warning required by section 10:

WARNING

MISE EN GARDE

Warning — cribs sold without mattress

12. The following warning or its equivalent must appear on every crib that is designed to be used with a mattress but is sold without one, immediately after the warnings required by sections 10 and 11:

WARNING

MISE EN GARDE

Warning — cribs supplied with mattress

13. The following warning or its equivalent must appear on every crib that is supplied with a mattress, immediately after the warnings required by sections 10 and 11:

WARNING

MISE EN GARDE

Warning — cribs designed to be used without mattress

14. The following warning or its equivalent must appear on every crib that is designed to be used without a mattress, immediately after the warnings required by sections 10 and 11:

WARNING

MISE EN GARDE

Warning — when crib used as accessory

15. The following warning or its equivalent must appear on every crib that, when it is used as an accessory, extends over or into the occupant retention area, immediately after the warnings required by sections 10 to 14:

WARNING

MISE EN GARDE

ADDITIONAL REQUIREMENTS FOR CRADLES

Warning — all cradles

16. The following warning or its equivalent must appear on every cradle:

WARNING

MISE EN GARDE

Warning — cradles with access side

17. The following warning or its equivalent must appear on every cradle that has an access side, immediately after the warning required by section 16:

WARNING

MISE EN GARDE

Warning — cradles sold without mattress

18. The following warning or its equivalent must appear on every cradle that is designed to be used with a mattress but is sold without one, immediately after the warnings required by sections 16 and 17:

WARNING

MISE EN GARDE

Warning — cradles supplied with mattress

19. The following warning or its equivalent must appear on every cradle that is supplied with a mattress, immediately after the warnings required by sections 16 and 17:

WARNING

MISE EN GARDE

Warning — cradles designed to be used without mattress

20. The following warning or its equivalent must appear on every cradle that is designed to be used without a mattress, immediately after the warnings required by sections 16 and 17:

WARNING

MISE EN GARDE

Warning — when cradle used as accessory

21. The following warning or its equivalent must appear on every cradle that, when it is used as an accessory, extends over or into the occupant retention area, immediately after the warnings required by sections 16 to 20:

WARNING

MISE EN GARDE

ADDITIONAL REQUIREMENTS FOR BASSINETS

Warning — all bassinets

22. The following warning or its equivalent must appear on every bassinet:

WARNING

MISE EN GARDE

Warning — bassinets with access side

23. The following warning or its equivalent must appear on every bassinet that has an access side, immediately after the warning required by section 22:

WARNING

MISE EN GARDE

Warning — bassinets sold without mattress

24. The following warning or its equivalent must appear on every bassinet that is designed to be used with a mattress but is sold without one, immediately after the warnings required by sections 22 and 23:

WARNING

MISE EN GARDE

Warning — bassinets supplied with mattress

25. The following warning or its equivalent must appear on every bassinet that is supplied with a mattress, immediately after the warnings required by sections 22 and 23:

WARNING

MISE EN GARDE

Warning — bassinets designed to be used without mattress

26. The following warning or its equivalent must appear on every bassinet that is designed to be used without a mattress, immediately after the warnings required by sections 22 and 23:

WARNING

MISE EN GARDE

Warning — when bassinet used as accessory

27. The following warning or its equivalent must appear on every bassinet that, when it is used as an accessory, extends over or into the occupant retention area, immediately after the warnings required by sections 22 to 26:

WARNING

MISE EN GARDE

ADDITIONAL REQUIREMENTS FOR ACCESSORIES

General

Non-application

28. Sections 29 to 34 do not apply to a crib, cradle or bassinet that can be used as an accessory.

Warning — all accessories

29. (1) The following warning or its equivalent must appear on every accessory:

WARNING

MISE EN GARDE

Warning — accessories that extend over or into occupant retention area

(2) The following warning or its equivalent must appear on every accessory that extends over or into the occupant retention area, immediately after the warning required by subsection (1):

WARNING

MISE EN GARDE

Warning — accessories other than sleep accessories

30. The following warning or its equivalent must appear on every accessory other than a sleep accessory, immediately after the warnings required by section 29:

WARNING

MISE EN GARDE

Sleep Accessories

Warning — sleep accessories

31. The following warning or its equivalent must appear on every sleep accessory immediately after the warnings required by section 29:

WARNING

MISE EN GARDE

Warning — sleep accessories sold without mattress

32. The following warning or its equivalent must appear on every sleep accessory that is designed to be used with a mattress but is sold without one, immediately after the warning required by section 31:

WARNING

MISE EN GARDE

Warning — sleep accessories supplied with mattress

33. The following warning or its equivalent must appear on every sleep accessory that is supplied with a mattress, immediately after the warning required by section 31:

WARNING

MISE EN GARDE

Warning — sleep accessories designed for use without mattress

34. The following warning or its equivalent must appear on every sleep accessory that is designed for use without a mattress, immediately after the warning required by section 31:

WARNING

MISE EN GARDE

ADDITIONAL REQUIREMENTS FOR STANDS

Warning — product on stand

35. The following warning or its equivalent must appear on every stand on which a crib, cradle or bassinet is designed to be placed:

WARNING

MISE EN GARDE

Warning — product fixed to stand

36. The following warning or its equivalent must appear on every stand on which a crib, cradle or bassinet is designed to be fixed by a latching or locking mechanism:

WARNING

MISE EN GARDE

CONSTRUCTION AND PERFORMANCE STANDARDS

STANDARDS FOR CRIBS, CRADLES, BASSINETS, ACCESSORIES AND STANDS

Key structural components — assembly

37. Every key structural component must meet one of the following requirements:

Coatings

38. Every crib, cradle, bassinet, accessory and stand must be free from any surface coating that contains any of the following substances:

Angle

39. (1) Every crib, cradle, bassinet and sleep accessory must be constructed so that the angle of the mattress support does not exceed 10° from the horizontal.

Angle — stands

(2) Every stand must be constructed so that the angle of the mattress support of a crib, cradle or bassinet that is placed on or fixed to it does not exceed 10° from the horizontal.

Angle — products that rock or swing

40. Every crib, cradle, bassinet, sleep accessory and stand that rocks or swings must be constructed to meet the following requirements:

Shearing and pinching

41. Every crib, cradle, bassinet, accessory and stand, and every part of one that is accessible to the child, must be constructed in a way that prevents the child from being injured from shearing or pinching.

Types of sides

42. A crib, cradle, bassinet and sleep accessory must have only stationary sides and access sides.

Strength and integrity of slats

43. The slats of a side of a crib, cradle, bassinet or sleep accessory must not turn or dislodge or become deformed or otherwise damaged when tested in accordance with Schedule 2.

Posts

44. (1) Subject to subsection (2), a post of a crib, cradle, bassinet or sleep accessory must not extend more than 1.5 mm — measured within a radius of 76 mm from the centre line of the post — above the lowest point on the upper surface of the higher of the sides that adjoin the post.

Exception

(2) A post may extend more than 406 mm above the highest point on the upper surface of the higher of the sides that adjoin the post if the crib, cradle, bassinet or sleep accessory meets the requirements of the cut-out test method set out in section 7.9 of the ASTM International standard F1169-13, entitled Standard Consumer Safety Specification for Full-Size Baby Cribs, as amended from time to time.

Extensions

(3) A post whose height is extended by the attachment of one or more removable extensions must meet the requirements of subsection (2).

Openings in cribs — entrapment

45. (1) When a crib is tested in accordance with the following provisions of Schedule 3, there must not be any completely bounded opening through which a solid rectangular block with the dimensions 60 mm 100 mm 100 mm is capable of passing in any orientation:

Openings in other products — entrapment

(2) When a cradle, bassinet or sleep accessory is tested in accordance with the following provisions of Schedule 3, there must not be any completely bounded opening through which a solid rectangular block with the dimensions 60 mm 100 mm 100 mm is capable of passing in any orientation:

Openings formed or exposed — structural covers of cribs

46. (1) When tested in accordance with section 2 of Schedule 3, a structural cover of a crib must not form or expose any completely bounded opening that permits the passage of a solid rectangular block with the dimensions 60 mm 100 mm 100 mm in any orientation.

Openings formed or exposed — structural covers of other products

(2) When tested in accordance with section 4 of Schedule 3, a structural cover of a cradle, bassinet or sleep accessory must not form or expose any completely bounded opening that permits the passage of a solid rectangular block with the dimensions 60 mm 100 mm 100 mm in any orientation.

Mesh — strength and integrity

47. (1) Any mesh that is made of a textile or other pliable material and that forms part of the sides or bottom of a crib, cradle, bassinet or accessory must not, when tested in accordance with Schedule 4, tear or become detached from its supporting structure or anything to which it is attached.

Size of openings in mesh

(2) The openings of mesh that is made of a textile or other pliable material of a crib, cradle, bassinet or accessory must be of such a size that the tip of a probe described in Schedule 5 is unable to pass through the openings, when tested in accordance with that Schedule.

Flammability

48. Any part of a crib, cradle, bassinet, accessory or stand that contains a textile or any other pliable material must have a flame spread time greater than seven seconds, when tested in accordance with National Standard of Canada CAN/CGSB-4.2 No. 27.5-2008, entitled Textile Test Methods: Flame Resistance — 45° Angle Test — One-Second Flame Impingement, as amended from time to time, in either of the following circumstances:

Entanglement — cribs

49. (1) When a crib or stand is tested in accordance with Schedule 6, the instrument illustrated in Figure 1 of that Schedule must not catch on any projection, fastener or mechanism of the crib or stand that is located above the mattress support or that protrudes above it.

Entanglement — other products

(2) When a cradle, bassinet, sleep accessory or stand is tested in accordance with Schedule 6, the instrument illustrated in Figure 1 of that Schedule must not catch on any projection, fastener or mechanism of the cradle, bassinet, sleep accessory or stand that is located in the occupant retention area or that protrudes into it.

Presumption

(3) For the purpose of subsections (1) and (2), a post that is described in subsections 44(2) and (3) is not a projection.

Wood, plastic or similar hard material

50. (1) Every exposed part of a crib, cradle, bassinet, accessory or stand that is made of wood, plastic or a similar hard material must be free from cracks, burrs and other defects and be smoothly finished to eliminate sharp edges and points.

Metal

(2) Every exposed part of a crib, cradle, bassinet, accessory or stand that is made of metal must be smoothly finished to eliminate sharp edges and points.

Metal tubing

(3) Every cut edge of any metal tubing that is part of a crib, cradle, bassinet, accessory or stand must meet one of the following requirements if it is accessible to the child:

Bolts

(4) The threaded end of every bolt of a crib, cradle, bassinet, accessory or stand must be protected by an acorn nut or an equally effective device if the end is accessible to the child.

Small parts

51. Every part of a crib, cradle, bassinet, accessory or stand that is small enough to be totally enclosed in a small parts cylinder illustrated in Figure 1 of Schedule 7 must be affixed to the product so that the part does not become detached when it is subjected to a force of 90 N, applied in any direction.

Openings — parts

52. Every slot, notch, groove or other opening in a wooden, plastic or metal part of a crib, cradle, bassinet, accessory or stand — or in a part of one made of a similar hard material — that is located above the mattress support when it is in any position and that is accessible to the child must meet one of the following requirements:

Restraint systems

53. No crib, cradle, bassinet or sleep accessory shall have a child restraint system.

Maximum length of cords and straps

54. (1) A cord, strap or other similar item that is attached by only one of its ends to a crib, cradle, bassinet, accessory or stand must not measure more than 188 mm in length when it is stretched by the gradual application of a force of 22 N.

Change table accessory

(2) In the case of a change table accessory, subsection (1) applies only to the length of the cord, strap or other similar item that extends into the occupant retention area of the product with which it is used.

Cords and straps — loops

55. (1) When tested in accordance with Schedule 8, a cord, strap or other similar item that is attached to a crib, cradle, bassinet, sleep accessory or stand must not be capable of forming either of the following loops:

Cords and straps — change table accessories

(2) When tested in accordance with Schedule 8, a cord, strap or other similar item that is designed to restrain a child in a change table accessory must not be capable of forming a loop that can be pulled into the occupant retention area of the product with which it is used and that permits the passage of the small head probe illustrated in Figure 1 of that Schedule.

Coil springs

56. Every coil spring of a crib, cradle, bassinet or accessory that is accessible to the child must be covered or constructed so as to prevent injury to the child.

Mattress

57. A mattress that is supplied with a crib, cradle, bassinet or sleep accessory must meet all of the following requirements:

ADDITIONAL STANDARDS FOR CRIBS

Structural integrity

58. A crib must not exhibit any damage, its latching or locking mechanisms must not disengage or deform permanently and its fasteners must not loosen, when the crib is tested in accordance with Schedule 9.

Mattress support

59. The mattress support of a crib must not dislodge, its mechanisms must not disengage or deform permanently and its fasteners must not loosen, when the mattress support is tested in accordance with Schedule 10.

Height of sides — mattress support in lowest position

60. Every side of a crib must meet the following requirements when the mattress support is in its lowest position:

Height of sides — mattress support in highest position

61. Every side of a crib must meet the following requirements when the mattress support is in its highest position:

Latching or locking mechanisms of access sides — requirements

62. The movable part of an access side of a crib must be held in each of its adjustment positions by means of a mechanism that meets all of the following requirements:

Latching or locking mechanisms of folding cribs — requirements

63. A folding crib must have a latching or locking mechanism that meets all of the following requirements:

Slat strength

64. A crib slat must not completely break or completely separate at either end from the top and bottom horizontal rails of the crib side when the slat is tested in accordance with Schedule 11.

Toeholds

65. (1) A crib must be constructed so that any horizontal slat, rail, projection or ledge that is capable of being used as a toehold by the child is not located at any point that is more than 76 mm and less than 510 mm above the mattress support, when the mattress support is in its lowest position and, if the crib has an access side, when the movable part is in any adjustment position.

Presumption

(2) For the purpose of subsection (1), a slat, rail, projection or ledge is capable of being used as a toehold if it has a depth of 10 mm or more.

ADDITIONAL STANDARDS FOR CRADLES AND STANDS

Stability

66. (1) A cradle must not tip over when tested in accordance with Schedule 12.

Cradle on stand

(2) A cradle when used with a stand must not tip over when tested in accordance with Schedule 12.

Structural integrity

67. A cradle must not exhibit any damage, its latching or locking mechanisms must not disengage or deform permanently and its fasteners must not loosen, when the cradle is tested in accordance with Schedule 9.

Mattress support

68. The mattress support of a cradle must not dislodge, its mechanisms must not disengage or deform permanently and its fasteners must not loosen, when the mattress support is tested in accordance with Schedule 10.

Height of sides

69. Every side of a cradle must meet the following requirements when the mattress support is in any position:

Latching or locking mechanisms of access sides — requirements

70. The movable part of an access side of a cradle must be held in each of its adjustment positions by means of a mechanism that meets all of the following requirements:

Latching or locking mechanisms of folding cradles — requirements

71. A folding cradle must have a latching or locking mechanism that meets all of the following requirements:

ADDITIONAL STANDARDS FOR BASSINETS AND STANDS

Stability

72. (1) A bassinet must not tip over when tested in accordance with Schedule 12.

Bassinet on stand

(2) A bassinet when used with a stand must not tip over when tested in accordance with Schedule 12.

Structural integrity

73. A bassinet must not exhibit any damage to any of its components, including the handles, when tested in accordance with Schedule 9.

Height of sides

74. Every side of a bassinet must meet the following requirements when the mattress support is in any position:

Latching or locking mechanisms of access sides — requirements

75. The movable part of an access side of a bassinet must be held in each of its adjustment positions by means of a mechanism that meets all of the following requirements:

Latching or locking mechanisms of folding bassinets — requirements

76. A folding bassinet must have a latching or locking mechanism that meets all of the following requirements:

ADDITIONAL STANDARDS FOR ACCESSORIES

Openings — entrapment

77. (1) When tested in accordance with section 1 of Schedule 13, any opening that is created when an accessory is placed on or fixed to a product must not permit the passage of the small head probe illustrated in Figure 1 of Schedule 8 unless it also permits the passage of the large head probe illustrated in Figure 1 of Schedule 13.

Openings — detachment or displacement

(2) When tested in accordance with section 2 of Schedule 13, any opening that is created when an accessory detaches or is displaced from a product must not permit the passage of the small head probe illustrated in Figure 1 of Schedule 8.

Structural integrity

78. Every sleep accessory and change table accessory must be capable of supporting the following load for a period of 60 seconds without any damage to any of its components:

Height of sides — sleep accessory

79. Every side of a sleep accessory must meet the following requirements:

DOCUMENTS

Retention period

80. (1) The responsible person must keep documents that show that a crib, cradle, bassinet, accessory or stand meets the requirements of these Regulations, for a period of at least three years after the date of its manufacture in Canada or the date of its importation.

Inspection

(2) The responsible person must provide an inspector with any of the documents that the inspector requests in writing, within 15 days after they receive the request.

REPEAL

81. The Cribs, Cradles and Bassinets Regulations (see footnote 10) are repealed.

COMING INTO FORCE

Six months after publication

82. These Regulations come into force six months after the day on which they are published in the Canada Gazette, Part II.

SCHEDULE 1
(Paragraph 5(1)(b))

STANDARD SANS-SERIF TYPE

FIGURE 1

Figure - check box

SCHEDULE 2
(Section 43)

TEST FOR STRENGTH AND INTEGRITY OF SLATS

1. The following method is to be used for testing the strength and integrity of slats:

SCHEDULE 3
(Sections 45 and 46)

TEST FOR OPENINGS

CRIBS WITH RIGID SIDES

1. The following method is to be used for testing completely bounded openings that are located above the mattress support of a crib that has rigid sides:

FIGURE 1

Figure - check box

CRIBS WITH A STRUCTURAL COVER OR TEXTILE OR OTHER PLIABLE MATERIAL SIDES

2. The following method is to be used for testing completely bounded openings that are present or that are created or exposed above or in the mattress support of a crib that has a structural cover or a textile or other pliable material side:

CRADLES, BASSINETS AND SLEEP ACCESSORIES WITH RIGID SIDES

3. The following method is to be used for testing completely bounded openings in the surfaces that form the occupant retention area of a cradle, bassinet or sleep accessory that has rigid sides:

CRADLES, BASSINETS AND SLEEP ACCESSORIES WITH A STRUCTURAL COVER OR TEXTILE OR OTHER PLIABLE MATERIAL SIDES

4. The following method is to be used for testing completely bounded openings that are present or that are created or exposed in the surfaces that form the occupant retention area of a cradle, bassinet or sleep accessory that has a structural cover or a textile or other pliable material side:

SCHEDULE 4
(Subsection 47(1))

TEST FOR STRENGTH OF MESH AND INTEGRITY OF ATTACHMENT

1. The following method is to be used for testing the strength of mesh and the integrity of its attachment to a crib, cradle, bassinet or accessory:

SCHEDULE 5
(Subsection 47(2))

TEST FOR DETERMINATION OF MESH SIZE

1. The following method is to be used for testing the size of openings of mesh on a crib, cradle, bassinet or accessory:

SCHEDULE 6
(Subsections 49(1) and (2))

TEST FOR ENTANGLEMENT

CRIBS AND STANDS

1. The following method is to be used for determining whether a projection, fastener or mechanism of a crib or stand that is located above the mattress support or that protrudes above it poses an entanglement hazard:

CRADLES, BASSINETS, SLEEP ACCESSORIES AND STANDS

2. The following method is to be used for determining whether a projection, fastener or mechanism that is located in the occupant retention area of a cradle, bassinet or sleep accessory poses an entanglement hazard, or whether a projection, fastener or mechanism of a stand that protrudes into the occupant retention area poses such a hazard:

FIGURE 1

Figure - Detailed information can be found in the surrounding text.

SCHEDULE 7
(Section 51)

SMALL PARTS CYLINDER

FIGURE 1

Figure - Detailed information can be found in the surrounding text.

SCHEDULE 8
(Sections 55 and 77)

TEST FOR LOOPS

CRIBS, CRADLES, BASSINETS, SLEEP ACCESSORIES AND STANDS

1. The following method is to be used for testing a loop formed by a cord, strap or other similar item that is attached to a crib, cradle, bassinet, sleep accessory or stand:

CHANGE TABLE ACCESSORIES

2. The following method is to be used for testing a cord, strap or other similar item that is designed to restrain a child and that is attached to a change table accessory:

FIGURE 1

Figure - Detailed information can be found in the surrounding text.

SCHEDULE 9
(Sections 58, 63, 67, 71, 73 and 76)

TEST FOR STRUCTURAL INTEGRITY

CRIBS

1. The following method is to be used for testing the structural integrity of a crib under dynamic conditions:

FIGURE 1

Figure - Detailed information can be found in the surrounding text.

2. The following method is to be used for testing the structural integrity of a crib under horizontal force conditions:

3. The following method is to be used for testing the structural integrity of a crib under vertical force conditions:

CRADLES

4. The following method is to be used for testing the structural integrity of a cradle under dynamic conditions:

BASSINETS

5. The following method is to be used for testing the structural integrity of a bassinet under static conditions:

SCHEDULE 10
(Sections 59 and 68)

TEST OF MATTRESS SUPPORT

CRIBS

1. The following method is to be used for testing the mattress support of a crib:

CRADLES

2. The following method is to be used for testing the mattress support of a cradle:

SCHEDULE 11
(Section 64)

STATIC LOAD TEST OF SLAT STRENGTH

1. The following method is to be used for testing the strength of crib slats under a static load:

SCHEDULE 12
(Sections 66 and 72)

TEST FOR STABILITY OF CRADLES, BASSINETS AND STANDS

1. The following method is to be used for testing the stability of a cradle or bassinet or of a stand when it is used with such a product:

SCHEDULE 13
(Section 77)

ENTRAPMENT IN ACCESSORIES TEST METHOD

1. The following method is to be used for testing openings that are created when an accessory is placed on or fixed to a product:

FIGURE 1

Figure - Detailed information can be found in the surrounding text.

2. The following method is to be used for testing openings that are created by the detachment or displacement of an accessory from a product:

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