Comment from Mo Anooshah

I understand the need of having some kind of test / verification when the misassembled product by the consumers present safety hazard to children. Please note my comments, questions, and suggestions below. 1- The definition of key structural element is not very clear. There are playards in the market that have multiple clips sewn to the bassinet accessory that attach to the playard rails on 4 sides, and metal bars in multiple sections that provide additional support for the bassinet mattress. Are the clips and the individual sections of metal bar considered a key structural element? 2- The bassinet miss assembly requirement as is written will make some of the robust play yards in the market less safe. There are play yards in the market that have 12 clips sewn to the bassinet accessory. The play yards also have separate metal bars on the bottom of the accessory. Removing, eliminating, or miss assembly of metal bars do not present any safety concern such as fall, suffocation, or strangulation hazard. The bassinet accessory is sturdy enough that complies with bassinet flatness requirement when the mattress is placed in it (without the metal bar(s). However, based on this requirement, these robust products will need to be re-designed. In another word, why do we need to modify the product per this requirement if the product is safe when one of the key structural elements is not assembled at all? I would suggest that we add another step to the requirement similar to the bassinet standard. This additional step will make the bassinet accessories acceptable as long as product complies with specific requirements such as bassinet flatness when the key structural element is removed or misassembled.