Full-Size Baby Cribs Business Guidance

 

Federal law requires that full-size baby cribs comply with the full-size crib standard and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).

Manufacturers and importers of cribs must certify in a Children's Product Certificate that the cribs comply with the standard and the additional requirements after the cribs have been tested for compliance at a CPSC-accepted, third party laboratory. These requirements are reviewed in greater detail at www.cpsc.gov/cpsia.

What is a full-size baby crib?

A full-size crib is a bed that: (1) is designed to provide sleeping accommodations for an infant; (2) is intended for use in the home, in a child care facility, in a family child care home, or in places of public accommodation affecting commerce; and (3) that has interior dimensions of 28 ± 5/8 inches (71 ± 1.6 centimeters) in width x 52 3/8 ± 5/8 inches (133 ± 1.6 centimeters) in length.

 

What is the purpose of the full-size baby crib standard?

The standard seeks to prevent the risk of deaths and injuries from falls or entrapment due to parts failure, dislodgment, or poor maintenance or assembly of the crib. The CPSC published a new standard in 2010, which improves significantly the safety of full-size cribs.

 

Where can I find the standard for full-size baby cribs?

The standard is published in the Code of Federal Regulations at 16 CFR Part 1219. The standard incorporates by reference ASTM F1169-11, with two differences. First, the CPSC's standard excludes the provision in section 6.12 of the ASTM standard that requires retightening of screws and bolts between the crib side latch test and the mattress support vertical impact test (§ 1219.2(b)(1) of the CPSC's standard). Second, the CPSC's standard adds a sentence to section 7.7.1 of ASTM F 1169-11 to clarify how to conduct the spindle/slat static force test with a crib that has folding or movable sides (§ 1219.2(b)(2) of the CPSC's standard). The specific requirements and descriptions of the tests for full-size cribs are in ASTM F 1169-11, which can be purchased from ASTM.

 

Which cribs must comply with these requirements, and when do they need to comply?

Full-size cribs manufactured, sold, resold, or otherwise placed in the stream of commerce (except for leasing) must meet all requirements of the full-size crib standard by June 28, 2011. Child care centers, family child care homes, and places of public accommodation (such as hotels and motels) that offer cribs for use, must provide cribs that meet the full-size crib requirements by December 28, 2012. Companies that lease cribs also have until December 28, 2012, to provide cribs that meet the crib requirements. Cribs that are medical devices, as determined by the U.S. Food and Drug Administration, are not subject to the CPSC's full-size crib standard.

What are the requirements for full-size cribs?

The standard prohibits traditional drop sides and has stringent requirements for various parts of the crib, such as mattress supports, slats, and hardware. More specifically, the principal requirements for full-size cribs include:

  • dynamic impact testing of the mattress support system - intended to address incidents involving collapse or failure of mattress support systems;
  • impact testing of side rails and slat strength/integrity testing - intended to prevent slats and spindles from breaking and/or detaching during use;
  • mattress support system testing - intended to ensure that the mattress support does not become detached from the frame, potentially resulting in a fall;
  • latching mechanism tests - intended to ensure that latching and locking mechanisms work as intended, preventing unintended folding while in use;
  • crib side configurations - intended, in part, to limit movable (drop) sides; addresses the numerous incidents related to drop-side failures;
  • label requirements - cover numerous hazards, such as falls from the crib, suffocation on soft bedding, and strangulation on strings and cords;
  • openings requirement for mattress support systems - addresses gaps in the mattress support system to reduce the possibility of entrapment;
  • requirements for wood screws and other fasteners - eliminate the use of wood screws that serve as the primary method of attachment on key structural elements; also includes other fastener requirements to address incidents related to loose hardware and poor structural integrity;
  • cyclic testing - addresses incidents involving hardware loosening and poor structural integrity;
  • misassembly issues - addresses the need to make it impossible to misassemble key elements or that those elements have markings that make it obvious when they have been misassembled;
  • test requirement for accessories - intended to address any cribs that now, or may in the future, include accessories, such as bassinets or changing tables;
  • component spacing - intended to prevent child entrapment between uniformly and non-uniformly spaced components, such as slats.

 

What type of mattress should I use in a full-size crib?

To prevent head entrapment and suffocation between the mattress and crib sides, a mattress used in a full-size crib must be at least 27 1/4 inches x 51 1/4 inches, with a thickness not exceeding 6 inches. The assembly instructions, the retail carton for the crib, and the crib itself must contain a specific warning statement that notes these dimensions.

 

What are the additional requirements for full-size cribs required by the Consumer Product Safety Improvement Act of 2008?

Full-size cribs are subject to surface coating requirements, lead and phthalate content limits, third party testing and certification, registration cards, and tracking label requirements. These requirements are discussed below:

  • Surface Coating Limit: Full-size cribs may not be painted with paint that contains more than 0.009 percent lead.
  • Lead Content Limit: Full-size cribs cannot contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
  • Phthalate Content Limits: Plasticized components of full-size cribs cannot contain more than 0.1% of the following phthalates: di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl butyl phthalate (BBP). Plasticized components of full-size cribs also may not contain more than 0.1 percent of diisononyl phthalate (DINP), diisodecyl phthalate (DIDP), or di-n-octyl phthalate while an interim statutory ban of these phthalates remains in effect.
  • Testing and Certification: Full-size cribs, like all products that are designed or intended primarily for children 12 years of age or younger, must be tested by an accredited third party laboratory accepted by the CPSC for compliance with the full-size crib standard and all other applicable children's product safety rules, including the lead paint, lead content, and phthalate content limits. Based on that testing, a domestic manufacturer (or importer) of full-size cribs must issue a Children's Product Certificate specifying each applicable rule and indicating that the product complies with those rules.
  • Registration Cards: Each manufacturer of a full-size crib must (1) provide a postage-paid consumer registration form with each product and (2) keep records of consumers who register their products with the manufacturer. In addition, manufacturer's add permanent markings to the product that state (3) the manufacturer's name and contact information, (4) the model name and number, and (5) the date of manufacture permanently on each such product.
  • Tracking Labels: Full-size cribs must have a tracking label or other distinguishing permanent mark affixed to the product and its packaging. The tracking label shall be a permanent distinguishing mark on the product and its packaging, to the extent practicable, and must contain certain basic information, including the (1) name of the manufacturer or private label, (2) the location and date of manufacture, and (3) cohort information, such as a batch or run number.

To the extent that the information required to be marked on the product (by the tracking label requirement and the registration card rule) is duplicative, you may combine the markings on the product to satisfy both requirements. Note that the tracking label requirement must also be marked on the product's packaging.

 

Where can I find additional information?

For more information on the requirements for Full-Size Baby Cribs, contact the U.S. Consumer Product Safety Commission:

  • Office of Education, Global Outreach, & Small Business Ombudsman (Assistance in Understanding and Complying with CPSC Regulations): e-mail: Business@cpsc.gov; telephone: (301) 504-7999.
  • Office of Compliance (Enforcement Inquires): e-mail: sect15@cpsc.gov; telephone: (301) 504-7520.

For additional information on crib safety, visit the CPSC Crib Information Center

Additional information on enforcement for child care providers.

To obtain copies of ASTM F1169-11, contact ASTM International at: www.astm.org or via telephone: (610) 832-9585.