Case Study on Standards: Baby Cribs
As part of its 125th anniversary celebration, ASTM International invited case study submissions from committee members around the world, highlighting standards that have made a significant impact in society – and that have bettered the world around us. Numerous exceptional submissions were received, making the work of ASTM’s panel of judges even more difficult in narrowing down the list to eight winners.
Standardization News is publishing all eight winning entries in 2023. We continue the series with a standard for baby cribs from the committee on consumer products (F15): Standard consumer safety specification for full-size baby cribs (F1169).
Identify the need for the development of this standard. What problem was this standard trying to solve?
The first version of the standard was published in 1988. The development of the standard started a few years prior in an effort to address an increasing trend of mechanical failures of structural components in cribs that caused or contributed to the deaths of many children. Full-sized cribs were first regulated by the U.S. Consumer Product Safety Commission (CPSC) in 1973, under 16 Code of Federal Regulations Part 1508, Requirements for Full-Size Baby Cribs. The regulation contained very few requirements, the most notable ones being the component spacing and cutout requirements (added in 1982). These two performance requirements used specific test probes to ensure the spaces between slats and the size of any decorative panel cutouts were not large enough to admit an infant’s hips or head, thereby effectively preventing entrapment and strangulation deaths in these parts of the crib. As mentioned, in the 1980s, stakeholders collaborated to develop an ASTM standard to address the ongoing structural crib failures that were not addressed in the CPSC regulation. Those first ASTM requirements included static and cyclic load testing on the mattress support and crib side rails. In addition, testing of the attachments of the side latches and plastic teething rails were added. The standard also restricted the use of finials on corner posts that were associated with strangulation deaths. Since the initial publication, the standard has been updated eight times, with the last version published in 2019. The most significant revision was in response to over 40 different recalls of over 11 million cribs, issued by the CPSC from 2007-2010, attributed to structural problems or failures of the cribs. Almost all the crib recall issues (detachments, disengagements, and breakages) created openings between the drop side rails and headboards or footboards in which infants became entrapped. During the time between November 2007 and April 2010, there were 36 deaths reported to the CPSC attributable to structural problems or failures of cribs.
Identify the interest groups that participated in the development and/or revision to the standard?
Crib manufacturers, retailers, consumer groups, CPSC staff, Health Canada staff, testing laboratories, industry consultants, and other general interest groups.
How is this standard commonly used by industry?
In December 2010, the CPSC issued a new federal safety standard (regulation) for full-sized baby cribs, 16 CFR 1219, that became effective in June 2011. The new regulation referenced F1169, with one change to the voluntary standard. The most significant revision in concerned performance requirements that effectively prohibited the manufacture and sale of cribs with drop-side rails. Other important revisions include stricter mattress support and crib slat testing, fastener requirements, and improved labeling and instructions. Since the regulation first became effective, ASTM has revised F1169 three times, and the CPSC has updated its regulation accordingly, to refer to the latest ASTM version. The impact of this voluntary standard cannot be fully emphasized. Since June 2011, every crib sold or put into commerce (including at second-hand stores) has had to comply with a specific version of the ASTM full-sized crib standard (F1169). Manufacturers are required to have their cribs tested for compliance, and all third-party testing laboratories must be certified in order to conduct testing of cribs to the ASTM standard.
How has the standard impacted health and safety?
This standard has had a substantial impact on the safety of our most vulnerable populations: infants and babies. The one place where a parent should feel comfortable leaving infants alone is in a crib. If a safe crib is not available, parents might resort to other, non-safe options. Having the strictest, safest crib standard – which became mandatory through a U.S. federal regulation – essentially saved the lives of many children. Cribs sold in the last decade in the U.S. are substantially safer due to the standard.
Can you provide any data to support the safety, economic or other impacts of the standard? If yes, please summarize the data and provide citations.
According to the U.S. CPSC report, “Nursery Product-Related Injuries and Deaths Among Children Under Age Five,” from December 2011, there were approximately 40 deaths resulting from a range of hazards associated with a crib during the three-year period of 2006-2008. The hazards include incomplete assembly, missing, broken, or nonfunctioning components, or ineffective crib repairs (Risana Chowdhury, 2011). The same annual report published the following year in December 2012 also notes 40 deaths due to crib related hazards for the years 2007-2009. Note these counts do not include fatalities due to the presence of hazardous crib surroundings (cord strangulations, plastic bag suffocations, etc.) nor do they include deaths that were attributed to extra or soft bedding in the crib.
According to CPSC’s last two annual nursery product reports, published December 2020 and December 2021, the number of deaths attributed to crib related hazards (not associated with soft bedding or crib surroundings) were 11 for the three-year period of 2015-2017 and 10 for the three-year period of 2016-2018. Thus, the number of crib hardware/component related deaths fell substantially from before the standard was significantly revised in 2010 and became a federal regulation, to after.
Considering that there are still older cribs being used in homes, and many have been tied to fatalities after the ASTM standard was approved (a saferproducts.gov search from 2011-2020 contains reports for four fatal incidents involving drop-side crib hardware failures and no crib hardware fatalities for ASTM compliant cribs), some if not many of these continuing fatalities are associated with older, non-compliant cribs, showing even more than a significant drop in deaths.
How do consumers and the public benefit from this standard?
On December 28, 2010, the CPSC published (75 Federal Register 81766) the final rule, 16 CFR 1219, Safety Standard for Full-Size Baby Cribs. In this regulation, (effective June 28, 2011), F1169 was specifically referenced as CPSC’s mandatory crib standard. Because the ASTM standard for cribs has been mandatory in the U.S. since June 28, 2011, consumers do not have to think about the safety of a crib when buying one for their children. Peace of mind is valuable for parents when dealing with child safety.
Are you aware of any regulatory adoption (domestic or international) or broad international use of the standard? If yes, please provide details.
As mentioned previously, the U.S. CPSC directly references the ASTM crib standards in their CPSIA Section 104 rulemaking for both full-sized cribs and non-full-sized cribs. Additionally, based on the data in ASTM’s Global Cooperation Department report, Canada references the standard in its regulation. Hong Kong normatively references the standard. Both Chile and Jamaica use the standard as the basis for their national standards and the Philippines has adopted the standard. Other ASTM MoU bodies have bought and consulted the standard.
Does this standard address any of the 17 United Nations Sustainable Development Goals?
SDG 3: Good Health and Well Being. Under the progress and info section of this goal, the importance of reproductive, maternal, and child health is considered. This section discusses the under-5 mortality rate, which has been positively impacted because of this standard. In addition
to cribs being mechanically and structurally safer, thus lowering the number of fatalities to the very young, the standard also includes labeling and warnings requirements that help alert new parents to some of the other hazards associated with cribs, such as soft bedding and hazardous sleeping environments.
Please provide any additional information here.
The CPSIA mandated the CPSC to update the crib standard. By working with ASTM and all the participating stakeholders, this was accomplished in record time and addressed all the issues known at the time. ■