Comment from Sharon Forshpan

My earlier comment submitted was made within the framework of the proposed language. I would like to further comment to the specific ‘Requests’ below for you consideration. Q: Whether this proposed requirement and test method will address the hazards associated with play yard bassinet accessories that can be assembled with missing key structural elements, A: SF: It does not address completely the hazards that caused the infant death specifically identified in the IDI which formed the basis of this proposed rule change). Q: and if not, what alternative requirements and test methods would address this hazard; A: (SF: This is a complex issue and more time should be allowed for studies by CPSC staff and stakeholders). Q: Whether the second avenue of compliance, referred to as the ``catastrophic failure test'' is necessary, A: (SF: This should be part of the studies mentioned above. There has to be reasonable rationale to support this test). Q: or if manufacturers should be required to attach all key structural elements permanently; A: (SF: This will be very design restrictive and ignores the existence of unique designs of products on the market for a number of years, which won’t meet these new test criteria, but nonetheless with a good safety record. This new requirement will put those unique and safe products in jeopardy. There will be no way to predict the unintended consequences to the new designs, even if they are able to meet the new requirement, the historical data to is just not present to support the new designs. The new requirements will be forcing proven safe products to change to the unknown. Manufacturers who have spent years developing unique designs, with years of feedback from users will now face the need to re-start. CPSC should take into consideration these important historical efforts, so safe products aren’t taken off the market and in its place, unproven products without any benefit of consumer tested history for misuse(part1- continue