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May 2022 Regulatory Update

USA: Consumer Product Safety Commission (CPSC) Issues Final Rule for Baby Changing Products



On 26 April 2022, the Consumer Product Safety Commission (CPSC) published a final rule for 16 CFR 1235 Safety Standard for Baby Changing Products, incorporated by reference to ASTM F2388-21.
The effective date will be 31 July 2022.

On 1 February 2022, ASTM notified the Consumer Product Safety Commission (CPSC) that it had revised the voluntary standard for baby changing products, approving ASTM F2388-21 Standard Consumer Safety Specification for Baby Changing Products for Domestic Use on 15 November 2021. Based on the CPSC staff’s review of ASTM F2388-21, the Commission will allow the revised voluntary standard to become the mandatory standard because the revised requirements in the voluntary standard either improve the safety of baby changing products or are neutral with respect to safety.

ASTM F2388-21 includes two substantive changes and some non-substantive revisions.

Substantive Changes:

  1. Two notes have been added to Figure 9 to provide the overall width and length dimensions for the tension tool used and a metric equivalent dimension has been added for one of the dimensions shown in the figure.
  2. Section 9.5 which provides warning statements that must be addressed on product labels and which requires that the warnings align with the format and text requirements illustrated in the standard have been updated:
    1. Section 9.5.1 “Fall Hazard,” at the beginning of the warning statement, in ASTM F2388-21, this hazard statement has been revised to be capitalized as “FALL HAZARD”
    2. Section 9.5.3 “Suffocation Hazard” at the beginning of the warning statement, in ASTM F2388-21, this warning statement has also been revised to be capitalized as “SUFFOCATION HAZARD”

Non-Substantive Revisions:

  1. Footnote 1 has been revised to include “baby changing products,” instead of “changing tables,”
  2. Figure 11, which provides examples of left-aligned warning label text, has been renumbered as Figure X1.1 and relocated from section 9, Marking and Labeling, to section X1, Rationale.
  3. Minor wording changes and grammatical corrections have been made, including:
    1. changing “example warning labels” to “example warning statements” (section 9.4.7);
    2. changing the warning label statement regarding fall hazards from “stay within arm’s reach” to “stay in arm’s reach of your child” (section 9.5.1);
    3. correcting the title of updated Figure X1.1 from “Example of Left Aligned Text” to “Example of Left-aligned Text.”
  4. Several figure names have been revised in section 9 Marking and Labeling and section 10 Instructional Literature.
For More Information About This Story:
Contact: Vivian Chan (Technical Consultant)
Phone: (852) 3185 8052
Email: regulatoryupdates@qima.com

Vivian Chan

Vincent Wong

Alex Hui

Elaine Tam

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