Comment from Ryan Burr

Document ID: CPSC-2010-0075-0006
Document Type: Public Submission
Agency: Consumer Product Safety Commission
Received Date: August 21 2010, at 12:00 AM Eastern Daylight Time
Date Posted: August 26 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: July 23 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: October 6 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b36f94
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I support the proposal for stricter safety standards of full size and non-full size cribs. Parents need to have confidence that their child is safe and manufacturers have an obligation to ensure they take all necessary measures to produce safe and reliable cribs for their consumers. 10 million drop-side cribs were recalled since 2007 and had more proactive regulations such as this been in place the immense costs to crib manufacturers and consumer safety may have been avoided. As stated in the proposal between November 1, 2007 and April 11, 2010, a total of 147 fatalities associated with full-size cribs were reported to the Commission, this is too high of a toll to pay to not have increased safety standards imposed. The proposed standards may have a small cost to a companies bottom line to test and ensure adherence to safety requirements, but the potential savings in human life and consumer peace of mind far outweighs any required business investment. I agree with the arguments of the commission in strengthening tests by not allowing the re-tightening of screws between the crib side latch test and mattress support vertical impact tests, as pointed out in the proposal this is not an overly restrictive tests and other countries that do not allow re-tightening do not have problems with a majority of their cribs passing the tests. Cribs should be able to withstand these tests to simulate the stresses that may be placed upon it by an infant child over the life of the crib. I also concur with the necessity of changes to make standards for non-full size cribs more consistent with those of full size cribs in order to properly address their injury potential. In summary, I believe it is in the best interests of the Commission to move forward with these proposed regulations for the sake of concerned consumers as well as crib manufacturers. Sources: http://www.greenbaypressgazette.com/article/20100815/GPG03/8150594/Safety-agency-gears-up-to-ban-drop-side-cribs

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