Petition to Ban Crib Rail Bumpers
December
21, 2015
Chairman
Elliot F. Kaye
Commissioner
Robert Adler
Commissioner
Ann Marie Buerkle
Commissioner
Joseph Mohorovic
Commissioner
Marietta Robinson
U.S.
Consumer Product Safety Commission
4330
East West Highway
Bethesda,
Maryland 20814
Petition to Ban Crib
Rail Bumpers
Dear
Chairman Kaye and Commissioners:
According
to a study published in the November 2015 Journal of Pediatrics, there were
three times more crib bumper deaths in the last seven years than in the last 3
time periods (CPSC records from 1985 to 2012). Bumpers caused 48 suffocations,
67% by a bumper alone and 33% by wedging between a bumper and another object.
The CPSC data were compared with data from the National Center for the Review
and Prevention of Child Deaths, which reported substantially more deaths (figures
from 2008 to 2011), raising the total to 77.
Another 146 crib bumper incidents were reported in which the babies
nearly suffocated, choked, or were strangled.
Empire
State Consumer Project, Inc. (ESCP), founded in 1971,
is a registered 501c3 Not-for-Profit Organization dedicated to reducing the use
of unsafe children’s products and chemicals toxic to human and environmental
health. We accomplish this by educating consumers and industry, conducting
product testing and reporting, and by advocating for regulation where needed to
protect the public interest. One of our most important goals is
the protection of children’s health and safety. Our annual Children’s Products
Safety Report highlights unsafe children’s products, including crib bumpers, soft
bedding, and other items that pose a safety risk. https://drive.google.com/file/d/0B10JrTWWsJzRX0YyYm9BQW5rcGM/view
In
an effort to prevent child deaths and injuries, we are petitioning the Consumer
Product Safety Commission to ban the sale of crib rail bumpers. Maryland was
the first state to ban the sale of crib bumpers; the federal government must
follow.
Parents
trust that products sold for use in cribs are safe to be used in cribs. Most
would be surprised to learn that the CPSC recommends against their use – as have
the American Academy of Pediatrics, the National Institutes of Health, and the
Centers for Disease Control. A ban on the sale of crib bumpers will make CPSC’s
Safe to Sleep initiative more meaningful to consumers by reducing the confusion
caused by the availability of these dangerous products.
Thank
you.
Sincerely,
Judy
Braiman, President
Empire State Consumer
Project, Inc.
Carol Chittenden,
Director
50 Landsdowne Lane
Rochester, New York
14618
585-383-1317
Petition to Ban Unsafe Items from Cribs in Nursery Product Advertising
December
7, 2015
Chairman
Elliot F. Kaye
Commissioner
Robert Adler
Commissioner
Ann Marie Buerkle
Commissioner
Joseph Mohorovic
Commissioner
Marietta Robinson
U.S.
Consumer Product Safety Commission
4330
East West Highway
Bethesda,
Maryland 20814
Petition to Ban
Unsafe Items from Cribs in Nursery Product Advertising
Dear
Chairman Kaye and Commissioners:
According
to CPSC records, deaths and injuries from nursery furniture and related
products surpass those from unsafe toys. For the 3-year period 2009-2011, CPSC
has reports of 336 deaths, an annual average of 112 deaths, associated with
nursery products among children younger than 5. Causes of death included
positional asphyxia, strangulation, and drowning, among others. In some
instances, the fatalities were attributed to the product; in other cases, the
fatalities resulted from a hazardous environment in or around the product.
Sudden Infant Death Syndrome (SIDS) deaths accounted for another 1500 deaths in
2013. SIDS deaths occur in part due to soft bedding being used where babies
sleep.
Empire
State Consumer Project, Inc. (ESCP), founded in 1971,
is a registered 501c3 Not-for-Profit Organization dedicated to reducing the use
of unsafe children’s products and chemicals toxic to human and environmental
health. We accomplish this by educating consumers and industry, conducting
product testing and reporting, and by advocating for regulation where needed to
protect the public interest.
One of our most important goals is the
protection of children’s health and safety. Our annual Children’s Products
Safety Report highlights unsafe children’s products, including cribs that are
advertised with soft bedding and other items that pose a safety risk. Of seven
companies that signed a 2000 agreement with the CPSC to promote safe bedding
through their catalogs and advertising, all but one continue to show comforters
and crib rail bumpers, among other soft items in cribs in their advertising (one
company no longer sells crib bedding on its website).
http://www.cpsc.gov/en/Newsroom/News-Releases/2000/Retailers-Join-CPSC-in-Promoting-Safe-Bedding-Practices-for-Babies---Each-Year-900-SIDS-Deaths-May-be-Caused-by-Soft-Bedding-/
http://www.cpsc.gov/en/Newsroom/News-Releases/2000/Retailers-Join-CPSC-in-Promoting-Safe-Bedding-Practices-for-Babies---Each-Year-900-SIDS-Deaths-May-be-Caused-by-Soft-Bedding-/
Most
parents trust that products advertised for use in cribs are safe to be used in
cribs. Most would be surprised to learn that the CPSC recommends against using
any blankets, crib rail bumpers, sleep positioners, pillows, stuffed animals or
other items in cribs because, contrary to CPSC recommendations, the cribs they
see in stores and in advertising often contain those items. Also shown in
nursery product advertising are:
Cribs placed next to windows and window blind
cords.
Long mesh crib canopies that encircle the
crib from ceiling to floor.
Cat and insect netting over cribs and play
yards.
New crib models with attached changing tables
showing items within a child’s reach from the crib.
In
an effort to prevent child deaths and injuries and to educate parents,
caregivers, and retailers about the importance of safe sleep practices, we are
petitioning the Consumer Product Safety Commission to ban the use soft bedding,
sleep positioners, crib rail bumpers, pillows, toys, and other unsafe items in
cribs in nursery product displays and advertising. All cribs in nursery product
advertising would be empty except for a mattress and tightly fitted sheet – and
a baby on its back in a sleeper, if included. Several states have crib bumper
bans; Maryland was the first. http://dhmh.maryland.gov/newsroom1/Pages/Maryland%E2%80%99s-Ban-on-Sale-of-Crib-Bumper-Pads-Takes-Effect-Tomorrow.aspx
It
is apparent that companies that sell these products cannot be relied upon to
adhere to a voluntary agreement. A ban on unsafe crib advertising will make
CPSC’s Safe to Sleep initiative more meaningful to consumers by reducing the
confusion caused by advertising that contradicts CPSC recommendations.
Thank
you.
Sincerely,
Judy
Braiman, President
Empire
State Consumer Project, Inc.
50
Landsdowne Lane
Rochester,
New York 14618
585-383-1317
