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Petition CP 15-2: Petition Requesting Ban on Supplemental Mattresses for Play Yards with Non-Rigid Sides

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Petition CP 15-2: Petition Requesting Ban on Supplemental Mattresses for Play Yards with Non-Rigid Sides UNITED STATES CONSUMER PRODUCT SAFETY COMMISSION 4330 EAST WEST HIGHWAY BETHESDA, MD 20814 DATE: BALLOT VOTE SHEET TO: The Commission Todd A. Stevenson, Secretary THROUGH: Mary T. Boyle, General Counsel Patricia H. Adkins, Executive Director FROM: Patricia M. Pollitzer, Assistant General Counsel Mary A. House, Attorney, OGC SUBJECT: Petition CP 15-2: Petition Requesting Ban on Supplemental Mattresses for Play Yards with Non-Rigid Sides BALLOT VOTE DUE ____________________ CPSC staff is forwarding a briefing package to the Commission regarding a petition requesting a ban on supplemental mattresses for play yards with non-rigid sides, which are currently marketed to be used with non-full-size cribs, play yards, portable cribs, and play pens (petition). The petition was submitted by Joyce Davis, president of Keeping Babies Safe (KBS) (petitioner). Petitioner contends that supplemental mattresses for play yards that are thicker than 1.5 inches create a suffocation hazard. CPSC staff recommends that the Commission defer the petition so that staff can work with stakeholders on several voluntary standards committees to improve safety for all aftermarket mattresses intended to be used with play yards. Please indicate your vote on the following options: I. Grant the petition and direct staff to begin developing a notice of proposed rulemaking or an advance notice of proposed rulemaking. (Signature) (Date) CPSC Hotline: 1-800-638-CPSC(2772) CPSC's Web Site: http://www.cpsc.gov Page 1 of 2 THIS DOCUMENT HAS NOT BEEN REVIEWED CLEARED FOR PUBLIC RELEASE OR ACCEPTED BY THE COMMISSION. UNDER CPSA 6(b)(1) II. Defer the petition and direct the staff to work through the voluntary standards process to improve the safety of aftermarket mattresses sold for use in play yards. (Signature) (Date) III. Deny the petition and direct staff to draft a letter of denial to the petitioner. (Signature) (Date) IV. Take other action. (Please specify.) (Signature) (Date) Attachment: Staff Briefing Package for Petition CP 15-2: Petition Requesting Rulemaking on Supplemental Mattresses for Play Yards with Non-Rigid Sides Page 2 of 2 THIS DOCUMENT HAS NOT BEEN REVIEWED CLEARED FOR PUBLIC RELEASE OR ACCEPTED BY THE COMMISSION. UNDER CPSA 6(b)(1) Staff Briefing Package Petition CP 15-2: Petition Requesting Rulemaking on Supplemental Mattresses for Play Yards with Non-Rigid Sides May 10, 2017 Hope E J. Nesteruk, Children’s Program Manager Division of Mechanical and Combustion Engineering Directorate for Engineering Sciences U.S. Consumer Product Safety Commission The contents of this package have not been reviewed or approved by the Commission and do not necessarily represent its views. THIS DOCUMENT HAS NOT BEEN REVIEWED CLEARED FOR PUBLIC RELEASE OR ACCEPTED BY THE COMMISSION. UNDER CPSA 6(b)(1) I. TABLE OF CONTENTS EXECUTIVE SUMMARY ............................................................................................................................................... III BRIEFING MEMORANDUM.......................................................................................................................................... V I. INTRODUCTION................................................................................................................................................... 1 II. HAZARD INFORMATION ................................................................................................................................ 4 III. VOLUNTARY STANDARDS.............................................................................................................................. 8 IV. ECONOMIC CONSIDERATIONS .................................................................................................................... 13 V. PUBLIC COMMENTS ........................................................................................................................................ 14 VI. STAFF CONCLUSION .................................................................................................................................... 21 VII. COMMISSION OPTIONS ............................................................................................................................... 22 VIII. OPTIONS .................................................................................................................................................. 23 IX. STAFF RECOMMENDATION ........................................................................................................................ 24 TAB A: PETITION FOR A BAN ON SUPPLEMENTAL MATTRESSES FOR PLAY YARDS WITH NON-RIGID SIDES ................................................................................................................................................................................... 25 TAB B: FATALITIES INVOLVING AFTERMARKET MATTRESSES FOR PLAY YARDS WITH NON-RIGID SIDES . 32 TAB C: HUMAN FACTORS ASSESSMENT OF PLAY YARDS WITH NON-RIGID SIDES AND THE USE OF AFTERMARKET MATTRESSES ................................................................................................................................. 41 TAB D: HEALTH SCIENCES STAFF REVIEW OF THE MECHANISMS OF DEATH ASSOCIATED WITH USE OF AFTERMARKET MATTRESSES IN PLAY YARDS. ....................................................................................................... 51 TAB E: MECHANICAL ENGINEERING ASSESSMENT FOR PETITION CPSC-2015-0020, PETITION REQUESTING THE BAN OF SUPPLEMENTAL MATTRESSES FOR PLAY YARDS WITH NON-RIGID SIDES .......... 58 TAB F: PETITION REQUESTING A BAN ON SUPPLEMENTAL MATTRESSES FOR PLAY YARDS WITH NON- RIGID SIDES – ECONOMIC CONSIDERATIONS ........................................................................................................ 68 ii THIS DOCUMENT HAS NOT BEEN REVIEWED CLEARED FOR PUBLIC RELEASE OR ACCEPTED BY THE COMMISSION. UNDER CPSA 6(b)(1) Executive Summary On June 16, 2015, the president of Keeping Babies Safe (KBS) and the mother of a child that died in an incident involving an aftermarket mattress, petitioned the CPSC requesting a ban on supplemental mattresses for play yards with non-rigid sides, which are currently marketed to be used with non-full-size cribs, play yards, portable cribs, and play pens. In addition, KBS stated that they did not intend their petition to cover mattresses sold by the play yard manufacturer as a replacement part. Specifically, the petitioner contended that the supplemental mattresses are thicker than the 1.5 inches allowed for mattresses supplied with a play yard pursuant to the mandatory standard for play yards, codified at 16 C.F.R. part 1221. In addition, the petitioner alleges that “thicker mattresses create a suffocation hazard because they create a gap between the mattress pad sides and the side of the portable crib where a baby can suffocate when the baby’s head falls in such gap while lying in the prone position.” Furthermore, the petitioner concluded that “no feasible consumer product safety standard would adequately protect babies from the unreasonable risk of injury and death associated with the product.” CPSC staff analyzed potentially relevant play yard entrapment fatalities between 2000 and 2016 and identified 14 incidents involving or potentially involving a mattress other than the original mattress used in a play yard with non-rigid sides. Of the 14 incidents, nine incidents involved a child entrapped within a pocket formed between the mattress and the non-rigid side of a play yard. These incidents involved mattresses other than the original mattress, but included incidents involving a mattress that was used alone, as well as incidents involving a mattress that was used on top of an original mattress (a “supplemental mattress”). Although a ban on the product category would keep supplemental mattresses off the market, staff’s analysis of additional play yard suffocation-related incident data, online product reviews, and data from the Durable Nursery Product Exposure Study suggest that if supplemental mattresses are not available, other soft bedding may be used to increase the child’s actual or perceived comfort. In 2014, the ASTM International (ASTM) F15.66 Crib Mattress subcommittee formed a task group and is actively working through ballot proposals to incorporate requirements for aftermarket mattresses into a voluntary standard. Recently, ASTM F15.66 passed a ballot that broadens the scope of the voluntary standard for crib mattresses, ASTM F2933, to include aftermarket play yard and non-full-size crib mattresses. ASTM F2933 will require aftermarket mattresses to meet the same thickness, support system, and attachment requirements as the original mattress included with the specific play yard for which the mattress is intended to fit and to carry additional warning messages. ASTM’s intent appears to be to ensure that aftermarket mattresses are virtually identical to the original mattress. However, ASTM defined an “aftermarket mattress” to be a mattress “intended to replace” the original mattress. Such definition arguably excludes mattresses that can be used on top of an original mattress. Thus, ASTM’s current effort will improve safety, but staff concludes that to improve safety for all iii THIS DOCUMENT HAS NOT BEEN REVIEWED CLEARED FOR PUBLIC RELEASE OR ACCEPTED BY THE COMMISSION. UNDER CPSA 6(b)(1) mattresses intended for use in a play yard, ASTM should also address safety requirements for “supplemental mattresses” that consumers currently use along with an original mattress. The ASTM F15.18 subcommittee
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