Comment from Sharon Forshpan

Q: Whether the CAMI Newborn Dummy, weighing 7.5 pounds, is appropriate to use for the catastrophic failure test, and if it is not, what should be used; Whether the language of the proposed requirements and test methods should be changed in order to improve repeatability and clarity, and if so, what those changes should be; Whether 6 months is an appropriate effective date for this provision; and A: (SF: All these will take time to investigate. Rushing to publish the final rules will only cause more changes in the future, with unknown consequences along the way. Q: Descriptions of the possible impact of this proposed requirement on small manufacturers and importers, A: (SF: Arm’s Reach is considered one of the ‘small importers’. Besides the financial cost of re-engineering, retooling and increases in the final product costs (thus the retail costs to the consumers) as the packaging will need to be larger in order to accommodate the changes, there is the cost of the unknown – the unintended consequences vs. what has already been proven as safe. To me, this is the biggest cost to the manufacturers and to the consumers that we must avoid. Q: as well as alternatives to the proposed rule that would accomplish the stated objectives of the proposed rule, A: (SF: Again, this is not something that can be rushed into. Q: and at the same time, reduce the economic impact on small businesses. A: (SF: One suggestion for this is to exempt those products that are unique in designs and had been market tested for a number of years without the problem on the Bassinet Misassembly test requirements. We support product safety improvement through regulatory means. But without fully investigating the risks and benefits of a new requirement could defeat that purpose. Thank you for your consideration. (part 2)