Comment from Kenneth Wittenauer

Britax Child Safety, Inc submits these comments in response to the Notice of Proposed Rulemaking issued by the CPSC as Docket # CPSC-2102-0068. The CPSC has invited comments on two issues in which the agency seeks to modify the Voluntary Standard ASTM F2050-12. One of those issues involves amending the test method for ensuring that the carrier will not rotate when the caregiver picks up the carrier and the handle is not locked. The current test method for ASTM F 2050 -12 requires the use of the standard CAMI 6 month old infant dummy. The agency proposes the use of an aluminum cylinder designed as a surrogate for the 6 month old infant to avoid the testing variances introduced by the CAMI dummy. As noted, the CAMI dummy may become wedged in the seat padding or be otherwise positioned to influence the test results. Britax has tested its infant carriers with the use of both the CAMI dummy and the aluminum cylinder and supports the agency recommendations of moving away from the CAMI dummy as the test device. The aluminum cylinder by its structure and composition ensures more consistent and relevant results. The use of the cylinder also diminishes the potential for the stroller soft goods and covers to influence the test results. With the use of the cylinder, Britax recommends that the test be conducted with the soft goods in place to reduce the time in testing the stroller and to produce results that are more indicative of real world conditions. Another issue for which the agency invited comment is the possible impact of the rule on manufacturers and whether setting a later effective date other than 6 months would be beneficial in reducing the compliance burden. For manufacturers that source their infant carriers from Asian based suppliers, there is generally an 18 month time line for new product development, production and shipment. For manufacturers that will be required to modify product design or apply additional labels to fabric covers, without additi