Proposed Regulatory Amendment to the Cribs and Cradles Regulations and Item 25 of Schedule I to the Hazardous Products Act (HPA)

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07-108092-639

Mechanical and Electrical Hazards Division
Consumer Product Safety Bureau
MacDonald Building
123 Slater Street
Address Locator: 3504D
Ottawa, Ontario K1A 0K9

Dear Stakeholder:

Subject: Proposed Regulatory Amendment to the Cribs and Cradles Regulations and Item 25 of Schedule I to the Hazardous Products Act (HPA)

The purpose of this letter is to provide you with information concerning an initiative that relates to the safety of cribs, cradles and bassinets, and to solicit your input with respect to this proposal. There will be a formal 75-day comment period once the proposed Cribs and Cradles Regulations are republished in Canada Gazette, Part I.

Background

On May 1, 2004, proposed amendments to the Cribs and Cradles Regulations and Item 25 of Schedule I to the Hazardous Products Act (HPA) were published in the  Canada Gazette, Part I (http://gazetteducanada.gc.ca/partI/2004/20040501/html/regle2-e.html). However, comments received by Health Canada from interested parties during the 75-day comment period required substantive changes to these proposed regulations. As a result, it is the intention of the Department to re-publish proposed amendments in the Canada Gazette, Part I in the near future. Health Canada's Consumer Product Safety Bureau (CPSB) is seeking the views of interested parties on this initiative.

Proposed Changes to the Legislation

The revised proposed amendment to the current Cribs and Cradles Regulations and to Schedule I of the HPA will seek to:

• Update the Regulations, which includes amending Item 25 of Part II, Schedule I to the HPA from "Standard cribs, portable cribs and cradles" to "Cribs, cradles and bassinets" broadening the definition of a crib to eliminate the distinction between standard and portable cribs, as well as including bassinets within the scope of the Regulations;
• Include bassinets and requirements relating to their required information (packaging and labeling) and construction and performance (flammability, side height, static load, shearing and pinching hazards, etc) within the scope of the Regulations;
• Eliminate toeholds that could enable a child to climb out of a crib and fall to the floor with a risk of injury;
• Establish the same side-height requirement of 660 mm for portable and standard cribs, thereby eliminating any distinction between the requirements for portable and standard cribs;
• Establish a minimum side height barrier of 230 mm that must be maintained at all times for all crib, cradle and bassinet products;
• Clarify the definitions of the various types of sides in cribs;
• Include additional warning requirements for cribs and cradles regarding blind cords, moveable sides and substituting parts;
• Amend the reference to the flammability standard, D 1230-61, Standard Method of Test for Flammability of Clothing Textiles, by replacing it with an equivalent Canadian standard, CAN/CGSB 4.2 NO. 27.5-94, Textile Test Methods - Flame Resistance - 45˚ Angle Test - One Second Flame Impingement;
• Harmonize aspects of the Canadian requirements with those of the United States concerning the safety of crib corner post extensions and cut-outs; and
• Include a requirement specifying that responsible persons must maintain records relating to the sale, advertisement and testing of crib, cradle and bassinet products.

Rational

Between 1972 and 1986, a total of 74 deaths directly involving cribs were reported to Health Canada. An amendment was brought to the Regulations in 1986 and since then, no deaths involving a crib, which met the requirements of the Regulations, have been reported to Health Canada. Each year, however, falls from cribs continue to be the primary cause of injuries. Data from Health Canada's Canadian Hospital Injury Reporting and Prevention Program indicates that 75 percent of crib injuries reported in ten paediatric and five general hospitals between 1990 and April 2002 were the result of falls. Two thirds of these falls occurred when the child climbed over the rail and out of the crib. The same set of data also indicates that approximately 56 percent of crib-related injuries involved the head, face and neck, thereby, highlighting the potential for serious injury. Given the high incidence of head injuries to children who climb out of their cribs, it is not considered acceptable to permit the sale of a class of cribs with less stringent safeguards such as a lower side-height requirement for portable cribs. The high rate of falls associated with cribs also underscores the need to eliminate toeholds that enable a child to climb out of the crib and to establish a minimum side height barrier that must be maintained at all times.

In response to requests by members of industry, this proposal will also seek to clarify the definitions of moveable crib sides, as well as clearly establishing which products fall within the scope of the Regulations. It is believed that these clarifications will facilitate compliance with the Regulations by various stakeholders by eliminating current ambiguities that have resulted in confusion for crib, cradle and bassinet manufacturers concerning the requirements that apply to their particular products.

This regulatory initiative will also include a technical amendment to the Regulations. The flammability standard that is currently referenced in the Regulations is no longer published or available for purchase. The standard that the proposed Regulations will reference is an identical bilingual Canadian standard that is currently available from the Canadian General Standards Board (CGSB).

The proposal to harmonize aspects of the Canadian requirements related to the safety of crib corner post extensions and cut-outs with the American requirements is also the direct result of requests from the manufacturing industry. This proposed amendment will allow a greater range of design without jeopardizing the safety of these products.

Additionally, it is the intention of this proposed amendment to include bassinets within the scope of the Regulations. Bassinets are currently unregulated in Canada. Recently, these products have become more popular as sleeping accommodation devices for babies in the first few months of their infancy. As infants may be left unsupervised in these products, the establishment of basic safety requirements for bassinets will enhance their safety.

Test Methods

Please be aware that Health Canada's Consumer Product Safety Program has developed a test method for determining the compliance of a crib or cradle product with the current Cribs and Cradles Regulations. This test method will be amended when the new Regulations come into force. The current Test Method for Cribs and Cradles (M-12) can be accessed on the Health Canada Web site at the following address:
http://hc-sc.gc.ca/cps-spc/alt_formats/hecs-sesc/pdf/prod-test-essai/_method-engin-ingen/m-12-eng.pdf

Your Comments

Health Canada is committed to ensuring that interested parties have the opportunity to participate in the development of initiatives that result in legally binding requirements. Accordingly, you are invited to forward your comments by mail, email or fax to the Consumer Product Safety Bureau:

Mail:
Cribs, Cradles and Bassinets Consultation
Mechanical & Electrical Hazards Division
Consumer Product Safety Bureau
Health Canada
123 Slater Street, 4^th Floor
MacDonald Building, Address Locator: 3504D
Ottawa, Ontario K1A 0K9

E-mail: M&E@hc-sc.gc.ca
Fax: (613) 952-9138; (Attention: Mechanical & Electrical Hazards Division)

Please provide your comments and suggestions by July 3, 2007.

Should you require further information, do not hesitate to contact your nearest Health Canada Product Safety Office.

Burnaby
(604) 666-5003

Montréal
(514) 283-5488

Calgary
(403) 292-4677

Québec
(418) 648-4327

Edmonton
(780) 495-2626

Saskatoon
(306) 975-4502

Halifax
(902) 426-8300

St. John's
(709) 772-4050

Hamilton
(905) 572-2845

Toronto
(416) 973-4705

Longueuil
(450) 646-1353

Winnipeg
(204) 983-5490

Moncton
(506) 851-6638

Consumer Product Safety would like to invite you to subscribe to our electronic newsletter to receive updates when new information regarding consumer product safety is posted.

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