Recent CPSC Consent Decrees require use of “Independent Product Safety Coordinators”

Two California  toy importers  have agreed to use Independent Product Safety Coordinators to create compliance programs to settle allegations of violating CPSC requirements, the Justice Department noted in a October 6 press release. They are decreed from selling and importing toys or other children’s products until these programs have been set up.

The companies are Unik Toyz Trading and Brightstar Group, both of Los Angeles. The complaints and settlements also name company officers: Julie Tran and Kiet Tran (Unik) and Sherry Chen (Brightstar)

Both decrees mandate the creation of compliance programs requiring the following:

  •  Use of Independent “Product Safety Coordinators” (no financial or personal ties) who would help set up a comprehensive product safety compliance program and audit products to determine which require testing and certification to CPSC rule. 
  • Engage  an CPSC accredited third party lab for product testing 
  • Periodic product testing plan according to 16 CFR 1107.
  • Conformity certificates retained and available to provide at CPSC’s request. The companies must have processes to verify that all underlying requirements are satisfied.
  • Warning labels on all products requiring them.
  • Tracking labels  on all products that require them.
  • Correction procedures to fix problems, conduct recalls, and respond to CPSC letters of advice.
  •  Incident reporting procedures to investigate incident reports, meet CPSC reporting requirements, and correct “systemic issues” found by the investigations.

Under both decrees, the companies must certify to the Compliance Office that they have met all provisions, accept CPSC facility inspections to ensure such compliance, and submit to at least two years of CPSC monitoring.


The CPSC sent 21 letters of advice to Unik from November 2011 to January 2015. The allegations involved lead content, phthalates, small parts, accessible batteries, art material labeling, third-party certification, and tracking labels


The Brightstar allegations involved lead content, warning labels on marbles, strollers’ folding mechanisms, third-party certification, and tracking labels. The CPSC sent nine letters of advice to Brightstar from September 2013 to April 2015.


Over the last several years, the creation of a compliance program has become a mandatory element of every settlement with the CPSC. 


The CPSC expects companies to have a robust compliance plan in place. Do you have all of the required elements in place?  Let Jacoby Solutions be your Independent Product Safety Coordinator and call us to schedule a CORE audit to see how your People, Process and Technology stack up..

Marc Schoem to lead ICPHSO

The International Consumer Product Health & Safety Organization (ICPHSO)  announced that Marc Schoem, currently with the US Consumer Product Safety Commission (CPSC), will be taking the reins as Executive Director of ICPHSO on October 15, 2015. The position has been unfilled since the founding Executive Director Ross Koeser retired in February of this year. Schoem will retire from CPSC in early October.

Founded in 1993, ICPHSO (pronounced IC – FAH – SO) is the only organization which attracts a global membership of consumer product health and safety professionals, all of whom come together to exchange ideas, share information, and address health and safety concerns affecting all consumers. ICPHSO members represent U.S. and global government agencies, manufacturers, importers, retailers, trade associations, certification/testing laboratories, law firms, academia, standards development organizations, media, and consumer advocacy groups.

Al Kaufman, current ICPHSO president, stated, “I know I speak for the entire ICPHSO board of directors when I say that we are very excited to have Marc on board. Having someone of Marc’s caliber, with the vast experience he brings to this role, serving as Executive Director will enable ICPHSO to grow and prosper, furthering our mission of providing a neutral forum where product safety practitioners from many organizations can come together to advance the art and science of protecting consumers.”

Schoem brings 40+ years of experience at CPSC to IPCHSO, working directly with many of the members and stakeholders in the product safety arena. His current position is Deputy Director, Office of Compliance and Field Operations, U.S. Consumer Product Safety Commission. Since joining the Commission in 1974, Mr. Schoem has served in a number of positions in its Bureau of Information and Education, Office of Education, Global Outreach and Small Business Ombudsman and the Office of Compliance and Field Operations.

“I am looking forward to this unique opportunity to lead ICPHSO,” stated Schoem. “ICPHSO is an organization that exists to bring together consumers, members of industry, global government regulators and other key players in the consumer product safety field to discuss and exchange ideas to improve consumer product safety throughout the world. This is a natural extension of the role I have played at CPSC for the last 40 years. My hope is to build ICPHSO into an even stronger and more vibrant organization that can help stakeholders address emerging safety issues and further the dialogue between all parties involved with consumer product safety in a non-partisan and inclusive approach.”

Schoem will make his first appearance as executive director of ICPHSO at the organization’s International Symposium in Billund, Denmark on October 20-21, 2015.


JPMA Moderates Panel at ICPHSO

Jacoby Solutions at ICPHSO


At the International Consumer Product Health and Safety Organization (ICPHSO) Conference held on Feb. 23-26 in Orlando, JPMA moderated the panel: How Data Sharing Can Lead to More Effective Policy. The panel explored not only the importance of how sharing of data can improve federal rulemaking and regulatory policy, but also improve and refine corporate policy.

The session was moderated by JPMA Managing Director of Government and Public Affairs, Julie Vallese, and the panel participants were Joan Lawrence from the Toy Industry Association, Jennifer Schechter from Consumer Reports, Bill Jacoby of Jacoby Solutions and George Borlase from the CPSC. Drawing lessons from industry experts and regulatory agencies currently working in collaboration with regards to data sharing, this panel addressed ways to effectively share data and discuss how the interpretation of data can affect public policy, corporate policy and protections, and the public perception of issues.


Small Batch Manufacturers – Register for 2015

Small Batch Registry

If you are  currently a registered small batch manufacturer with the U.S. Consumer Product Safety Commission (CPSC) for calendar year 2014 and you wish to continue in this status, you must register again for calendar year 2015

Registration must be submitted annually. 

If you have not previously registered your small business with CPSC, but now wish to do so, please follow the instructions below but note that you will first have to create a user ID and password before you will be able to follow all of the steps below.

Registration is now open for calendar year 2015. 

If you wish to register as a small batch manufacturer for calendar year 2015, your registration must be based upon the total number of the same product units sold (7,500 units) and the total gross revenues ($1,068,336 or less) from the sales of all consumer products in the previous calendar year – January 1, 2014 through December 31, 2014.  If you meet those two requirements (the total gross revenues figure has been updated for inflation this year), you may now register for calendar year 2015 by logging into your user account in the Business Portal at:

Step 1:  Login:  When you log in to your account at: and you click the “Small Batch Manufacturer” tab with your cursor, you will be asked to attest that your company satisfies the criteria you first used to register; the criteria are nearly the same as last year and only the gross total revenue figure has been updated to account for inflation.

If you do not see the “Small Batch Manufacturer” tab on your screen when you login, you may be using the wrong email login.  Remember that you may have used multiple emails when you created your account.  You should use the Business Account User ID login, which is often a general address, such as, and not your personal or other email address, such as  If you login correctly, you will be able to see all the tabs, including ‘Small Batch Manufacturer.’  If you need further assistance logging in, contact

Step 2:  Registration:  Once you are certain that you can attest to the truth and accuracy of the statements for your sales and your revenues in calendar year 2015, you may check the boxes and submit your registration.  Within the next day or so, you will receive a confirmation e-mail message with your new, unique Small Batch Manufacturer Registration Number for 2015.  *Please save that e-mail message for your reference.* 

Please note that when you log in to your account after your registration for calendar year 2015 is accepted, your Business Portal account will display your unique Small Batch Manufacturer Registration Number for both calendar year 2014 and calendar year 2015.  Please use the appropriate number (from 2014 or 2015, based on the date of your product’s manufacture or final assembly) in drafting your Children’s Product Certificate.

Total Gross Revenues:  Note that the total gross revenues for your company from the prior calendar year (e.g., calendar year 2014 sales to qualify for calendar year 2015) from the sale of all consumer products must be $1,068,336 or less

(If your company’s revenues are currently $900,000 or more, we recommend that you defer registering with the CPSC until the final 2014 figures are released – the figure above will not be finalized until early 2015.  The size of the final inflation adjustment is still unknown.  If you register before the release and your revenues exceed the maximum allowed amount as adjusted in 2014, you must notify the CPSC to cancel your registration.) 

Registration is ongoing, and you may register at any time during the next calendar year – through December 2015.

Assistance:  If you have any questions or require assistance with the registration process, please e-mail:


If you have any questions about how registration as a small batch manufacturer with the CPSC affects your obligations to test and certify your products as compliant with applicable consumer product safety rules or compliance with other CPSC rules, regulations, standards, or bans, please review the program information at:  If you need further assistance, please e-mail Neal Cohen, CPSC Small Business Ombudsman at:


CPSC Proposes Three Areas for Reducing Third-Party Testing

During the Senate confirmation hearing for incoming CPSC Chairman Elliot Kaye and Commissioner Joe Mohorovic, Senator John Thune (R-SD) asked each candidate what the CPSC could do to reduce the burden of Third-Party testing for manufacturers and importers of children’s products. In response to the Senator Thune questioning, both Chairman Kaye and Commissioner Mohorovic submitted a joint letter outlining three areas of focus for the Commission to reduce the burden of testing.

  1. Expanding the CPSC’s “determinations” for lead to include the other seven (7) heavy metals that are required for testing under ASTM F963-11. A CPSC determination exempts certain materials from testing based on either scientific data or consistent third-party test results which demonstrate that the heavy element(s) do not naturally occur in the material. Currently for lead materials such as wood, CMYK inks, natural and synthetic fibers are exempt from lead testing. These materials and perhaps others would be expanded to include the other seven (7) heavy metals.
  2. Research and compare other international standards such as ISO 8124 or EN-71 to current US Standards such as ASTM F963-11 for “equivalency” in testing methods and safety standards. If found to be equivalent, then manufacturers or importers who have previously tested their products to these standards would not need to test their products to the equivalent U.S. Standards.
  3. Producing guidance for the allowance of “de minimis” third-party testing exemptions where the area requiring testing on the product has a mass weight of less than 10 mg would require testing. While these very small areas on the product would still need to comply with any applicable chemical content limits, the CPSC would not require testing to demonstrate compliance.

While the Chairman and Commissioner did not give a timeline for beginning the process of implementing the points outlined in the letter, it is expected to be a “hot button” for Senator Thune who is expected to become the Chairman of the U.S. Senate Committee on Commerce, Science, and Transportation in the next Congress which oversees the CPSC.

Green Chemistry Initiatives by State

Green Chemistry initiatives by State, beginning with California in 2008, have quickly grown to several states with either proposed or enacted “Green Chemistry” bills to regulate hazardous substances in consumer products. California through the Safer Consumer Products (SCP) and their Department of Toxic Substances Control, published the first list of priority products. These priority products were placed on the list based on two criteria; the potential to expose people or the environment to one or more Candidate Chemicals, and the potential to “contribute to or cause significant or widespread adverse impacts”.

Several bills currently pending in states,  seek to regulate the use of chemicals. Of these, Vermont SB 239 is the most controversial and wide-reaching. The bill’s original scope was so broad that it would have allowed the Department of Health to regulate all products. As amended, the bill only relates to children’s products and would require companies to report to the Department of Health if their products contain any of the 66 chemicals on a “watch list”.

Massachusetts also recently introduced MA HB 3997, which would ban the sale of products containing priority chemicals designated by the Administrative Council on Toxic’s Use Reduction. Many states have attempted to ban the use of flame retardant chemicals in children’s products including; Alaska, Connecticut, Maryland and Washington. Washington, through the enactment of the Children’s Safe Products Act (CSPA) also requires manufacturers to report toxic chemicals in their products which are sold to children. The requirement to report is based on a list of 66 chemicals currently on the Chemicals of High Concern to Children (CHCCs) along with the amount of the chemical present in the product and the function of the chemical in the product.

Since it is unlikely that the debate over the safety of chemicals used in consumer products [especially children’s products] will end, the topic of chemicals in consumer products will remain a popular issue in state legislatures for the foreseeable future.

CPSC Workshop April 3 – Potential Ways To Reduce Third Party Testing Costs Through Material Determinations Consistent with Assuring Compliance

Potential Ways to Reduce Third Party Testing Costs Through Material Determinations Consistent with Assuring Compliance:           cpsc logo

CPSC Workshop – April 3, 2014 

Tomorrow, beginning at 9 am, CPSC staff will hold a workshop on potential ways to reduce third party testing costs, to be held at CPSC’s National Product Testing and Evaluation Center in Rockville, Maryland. You may find out more information and attend by registering here or you may watch the webcast at (Note: Viewers will not be able to interact with the panels and presenters.)  Written comments may also be submitted by April 17, 2014. The goal of the workshop is to provide CPSC staff with information and evidence concerning possible Commission determinations that certain materials will comply with applicable safety standards with a high degree of assurance and without requiring third party testing.  Staff would like to emphasize that the workshop will focus on technical questions and information as detailed in the FR notice.



Maine proposes four chemicals for priority designation

Maine proposes four chemicals for priority designation. The Maine Department of Environmental Protection (DEP) Maine Priority Chemicalshas proposed four rules that would designate cadmiumformaldehydemercury and arsenic as priority chemicals. Manufacturers, importers or distributors of certain children’s products which are in the stream of commerce in Maine will have to report the use of these four chemicals in their products if they are above a certain “minimum amount”.

The proposed rule states that, “No later than 180 days after the effective date of this chapter, the manufacturer [this would include an importer as well] of any of the following: bedding, childcare articles, clothing, cosmetics, craft supplies, footwear, games, jewelry and embellishments, safety seat, occasion supplies, personal accessories, personal care products, school supplies, or toys which are intended for use by a child under the age of 12 years, that contain intentionally-add [chemicals] shall report to the department the following information:

  1. The name and address of the manufacturer [including importers]
  2. The name, address and phone number of a contact person for the manufacturer [including importers]
  3. Description of the product or products containing [the chemical], including the overall size of the product and/or component of the product that contains [the chemical] and whether the product or chemical-containing component of the product, can be placed in the mouth (typically if the item is smaller than 5 cm in one dimension, it is regarded as mouthable)
  4. The number of items sold or distributed in Maine or nationally
  5. The amount of [the chemical] in the product reported
  6. The function of [the chemical] in the product reported
  7. Any other information the manufacturer deems relevant to the reporting of the chemical, such as relevant independent scientific study on exposure specific to the amount of chemical present in the finished product reported or product of similar functionality.

A public comment period on the proposed rules expired on January 31, 2014. The proposed rules would implement Maine’s Toxic Chemicals in Children’s Products law, which aims to protect the health, safety and welfare of children by reducing their exposure to chemicals of high concern by providing substitutes when feasible. Maine has already listed bisphenol A (BPA) and nonylphenol/nonylphenol Ethoxylates (NP/NPE) as priority chemicals.

Unsure how this might impact your product or future product development? Contact us today to see how we can help. or 866-873-7335 ext. 101


FTC Announces Changes to Textile Labeling Rules

The FTC Announces Changes to Textile Labeling Rules, addressing fiber content and country-of-origin disclosures.FTC Label Changes

The Rules implement the Textile Fiber Products Identification Act, which requires that certain textiles sold in the United States carry labels disclosing the generic names and percentages by weight of the fibers in the product, the manufacturer or marketer name, and the country where the product was processed or manufactured.

In May 2013, the FTC proposed changes to the Rules and sought public comment. Based on comments received, the agency proposed amendments to the Rules and sought public comments. After weighing the comments it received, the Commission approved the changes announced today, including amendments that would:

  • incorporate the updated International Organization for Standardization standard establishing generic fiber names for manufactured fibers;
  • allow certain hang-tags disclosing fiber names and trademarks, and performance information, without the need to disclose the product’s full fiber content;
  • clarify that an imported product’s country of origin is the country where it was processed or manufactured, as determined under laws and regulations enforced by U.S. Customs and Border Protection;
  • better address electronic commerce with revised definitions of “invoice” and “invoice or other paper,”
  • replace the requirement that guarantors sign continuing guarantees under penalty of perjury with a requirement that they acknowledge that providing a false guaranty is unlawful, and certify that they will actively monitor and ensure compliance with the applicable law; and
  • clarify the provision identifying textile fiber product categories and products that are exempt from the Act’s requirements.

Based on the comments received, the Commission decided not to adopt its proposal to make continuing guaranties effective for one year unless revoked earlier. Thus, continuing guaranties filed with the Commission will remain effective until revoked.

The Commission vote to publish the Federal Register Notice amending the Rules and Regulations under the Textile Fiber Products Identification Act was 4-0. It will be published in the Federal Register soon. The amended Rules will become effective 30 days after the Federal Register Notice is posted.

Unsure how this might impact your product or future product development? Contact us today to see how we can help. or 866-873-7335 ext. 101

CPSC Issues Final Rule Safety Standard Soft Infant Toddler Carriers

The CPSC has issued a Final Rule on the Safety Standard for Soft Infant and Toddler Carriers, 16 CFR 1226 on March 28, 2014. This final rule will become effective on September 29, 2014 and apply to products manufactured or imported on or after that date. The ASTM standard for Soft Infant and Toddler Carriers, ASTM F2236-14, which was released on January 1, 2014, incorporates all the new mandatory requirements of the Final Rule.Front Soft Carriers

ASTM F2236-14’s definition of a “soft infant and toddler carrier” distinguishes soft infant and toddler carriers from other types of infant carriers that are also worn by a caregiver but that are not covered under ASTM F-2236-14, specifically slings (including wraps), and framed backpack carriers.

Soft infant and toddler carriers are designed to carry a child in an upright position. Slings are designed to carry a child in a reclined position. However, some slings may also be used to carry a child upright. The primary distinction between a sling and a soft infant and toddler carrier is that a sling allows for carrying a child in a reclined position. Different hazard patterns arise from carrying a child in a reclined position. Accordingly, slings are not covered by the standard for soft infant and toddler carriers.

Like soft infant and toddler carriers, framed backpack carriers are intended to carry a child in an upright position. However, framed backpack carriers are distinguishable from soft infant and toddler carriers because typically, backpack carriers are constructed of sewn fabric over a rigid frame and are intended solely for carrying a child on the caregiver’s back.

ASTM F2236-14 includes the following key provisions: scope, terminology, general requirements, performance requirements, test methods, marking and labeling, and instructional literature.


The scope of the voluntary standard was broadened in December 2012 to include soft infant and toddler carriers with an upper weight limit of up to 45 pounds. Previously, it was unclear whether carriers with upper weight limits over 25 pounds fell within the standard. Expanding the scope of the standard clarifies that all soft infant and toddler carrier products currently on the market fall within the standard.


Section 3.1 of the standard includes 14 definitions to help explain general requirements and performance requirements. Section 3.1.7 of the standard explains that a “leg opening” is the “opening in the soft carrier through which the occupant’s legs extend when the product is used in the manufacturer’s recommended use position.” Sections 3.1.4 and 3.1.13 of ASTM F2236-14, respectively, explain that a “dynamic load” is the “application of impulsive force through free fall of a weight,” and that a “static load” is a “vertically downward force applied by a calibrated force gage or by dead weights.” Beginning in 2012, the standard included a new definition for “carrying position” to clarify methods for dynamic and static load testing in section 7 of the standard. Finally, in 2013, the standard was updated to include a new definition for “fastener” to aid in a new test for fastener strength and strap retention.

General Requirements

ASTM F2236-14 includes general requirements that the products must meet, as well as specified test methods to ensure compliance with the general requirements, which include:

  • restrictions on sharp points or edges, as defined by 16 CFR §§ 1500.48 and .49;
  • restrictions on small parts, as defined by 16 CFR part 1501;
  • restrictions on lead in paint, as set forth in 16 CFR part 1303;
  • requirements for locking and latching devices;
  • requirements for permanent warning labels;
  • restrictions on flammability, as set forth in 16 CFR part 1610;
  • requirements for toy accessories, as set forth in ASTM F 963.

The flammability requirement in section 5.7 of the standard was changed, beginning with ASTM F2236-13, from a flammable solids requirement (16 CFR 1500.3(c)(6)(vi)), to meet the more stringent flammability requirement for wearing apparel (16 CFR part 1610). Adopting the wearing apparel flammability requirement in the soft infant and toddler standard makes it consistent with other wearable infant carriers made of sewn fabric, such as slings, to prevent a foreseeable fire hazard in all wearable infant carriers.

Performance Requirements and Test Methods

ASTM F2236-14 provides performance requirements and test methods that are designed to protect against falls from the carrier due to large leg openings, breaking fasteners or seams, and straps that slip, including:

Leg Openings

Tested leg openings must not permit passage of a test sphere weighing 5 pounds that is 14.75 inches in circumference.

Dynamic and Static Load

Beginning with the 2012 version of ASTM F2236, the dynamic load test was strengthened from requiring a 25-pound shot bag to be dropped, free fall, from 1 inch above the seat area onto the carrier seat 1,000 times, to requiring testing with a 25-pound shot bag, or a shot bag equal to the manufacturer’s maximum occupant weight limit, whichever is heavier. Additionally, the static load test was revised—from requiring a 75-pound weight for testing—to requiring a 75-pound weight, or a weight equal to three times the manufacturer’s recommended maximum occupant weight, whichever is greater, to be placed in the seat area of the carrier for 1 minute. Such revisions to the dynamic and static load tests strengthen the test requirements, by requiring that products with a maximum recommended weight of 45 pounds be tested to a 135-pound weight instead of 75 pounds, which represents an 80 percent increase in the severity of the requirement.

ASTM F2236-14 requires that testing conducted with the new required loads must not result in a “hazardous condition,” as defined in the general requirements, or result in a structural failure, such as fasteners breaking or disengaging, or seams separating when tested in accordance with the dynamic and static load testing methods. Additionally, the standard provides that dynamic and static load testing must not result in adjustable sections of support/shoulder straps slipping more than 1 inch per strap from their original adjusted position after testing.

Section 6.2.2 of the standard on Support/Shoulder Strap Slippage was modified beginning with ASTM F2236-13a. The modification clarifies what constitutes passing or failing the strap slippage test. Section 6.2.2 was amended to state: “Adjustable sections of support/shoulder straps shall not slip, in a manner that loosens the strap, more than 1 in. (25 mm) per strap from their original adjusted position after dynamic and static load testing is performed in accordance with 7.2.1 and 7.2.2, respectively.” The amendment allows straps to tighten during testing but not loosen more than 1 inch, which is the intent of the testing.

Fastener Strength and Strap Retention

ASTM F2236-14 includes a new component-level performance requirement that was added to the standard in 2013 to evaluate the strength of fasteners and strap retention to help prevent falls from a carrier. Previously, soft infant and toddler carriers were recalled due to an occupant fall hazard caused by broken fasteners that passed the static and dynamic performance requirements in the then existing standard, ASTM F2236-10. Accordingly, the performance requirement in section 6.4 of ASTM F2236-14 states that load-bearing fasteners at the shoulder and waist of soft infant and toddler carriers, such as buckles, loops, and snaps, may not break or disengage; nor may their straps slip more than 1 inch when subjected to an 80-pound pull force. Adjustable leg opening fasteners must also be tested but are subjected to lower loads, a 45-pound pull force, because these fasteners do not carry the same load as fasteners at the shoulders and waist. ASTM F2236-14 requires that when tested, fasteners must not break or disengage, and adjustable elements must not slip more than 1 inch.

Similar to the strap slip requirement in the static and dynamic load testing section of the standard, ASTM also clarified the strap slip section of the fastener strength test section in ASTM F2236-13a. Sections 6.4.1 and 6.4.2 were amended to state: “Each unique fastener, except for leg opening adjustment fasteners as tested per 6.4.2, shall not break or disengage, and adjustable elements in straps shall not slip , in a manner that loosens the strap, more than 1 in. (2.5 cm) . . . .” This amendment allows straps to tighten during testing but not to loosen more than 1 inch, which is the intent of the testing.

Additionally, Note 1 to section 6.4 of the standard provides that the fastener strength and strap retention testing apply only to load-bearing fasteners. ASTM F2236-13 stated: “Fasteners intended to retain items such as, but not limited to, hoods, bibs and toy rings, are exempt from these requirements.” ASTM approved two changes to the language in Note 1 to clarify that several non-load-bearing features, “sleeping hoods” and “head adjustment fasteners,” are included in the list of examples exempted from fastener strength testing when such features are non-load-bearing. Note 1 in section 6.4 of ASTM F2236-14 now provides that: “Fasteners intended to retain items such as, but not limited to, sleeping hoods, head adjustment fasteners, bibs and toy rings, are exempt from these requirements.”

Unbounded Leg Opening

The voluntary standard was updated in 2013 to clarify the unbounded leg opening test procedure to improve test repeatability. ASTM F2236-14 requires that an unbounded leg opening must not allow complete passage of a truncated test cone that is 4.7 inches long, with a major diameter of 4.7 inches and a minor diameter of 3 inches. The standard requires a test cone to be pulled through the leg opening with a 5-pound force for 1 minute.

Marking, Labeling, and Instructional Literature

ASTM F2236-14 requires that each product and its retail package be marked or labeled with certain information and warnings. The warning label requirement was updated in 2013 to address fall and suffocation hazards. ASTM F2236-14 requires that the warning label provide a fall hazard statement addressing that infants can fall through wide leg openings or out of the carrier. The standard requires the following fall-related precautionary statements be addressed on the warning label: Adjust leg openings to fit baby’s legs snugly; before each use, make sure all [fasteners/knots] are secure; take special care when leaning or walking; never bend at waist, bend at knees; only use this carrier for children between _ lbs. and _ lbs. Additionally, ASTM F2236-14 requires that a suffocation hazard statement must address the fact that infants under 4 months old can suffocate in the carrier if the child’s face is pressed tightly against the caregiver’s body. The standard requires that the warning label must also address the following suffocation-related precautionary statements: Do not strap infant too tightly against your body; allow room for head movement; keep infant’s face free from obstructions at all times. Products must also contain an informational statement that a child must face toward the caregiver until heor she can hold his or her head upright. All products are required to come with instructional literature on assembly, use, maintenance, cleaning, and required warnings.

ASTM F2236-14 includes an example warning label that identifies more clearly the hazards, the consequences of ignoring the warning, and how to avoid the hazards. The label format was designed to communicate more effectively these warnings to the caregiver (Fig. 1). Manufacturers may alter the rectangular shape of the label to fit on shoulder straps, if the manufacturer chooses not to place label in the occupant space. However, the standard requires that the label be placed in a prominent and conspicuous location, where the caregiver will see the label when placing the soft infant and toddler carrier on their body.

Unsure how this might impact your product or future product development? Contact us today to see how we can help. or 866-873-7335 ext. 101