Comment from Terry Emerson

RE: Docket No CPSC-2012-0068 Consumer Product Safety Commission Safety Standard for Hand Held Infant Carrier Dorel Juvenile Group is supportive of the NPRM with one major exception. The proposal to use the test cylinder in place of the CAMI Mark II 6 month ATD is not acceptable. DJG has tested with the cylinder and it yields inconsistent results. This is because of its’ structure and that of HHICs. The cylinder is, of course, cylindrical and rolls from side to side when placed in the carrier. This in itself presents inconsistent results. In addition, because the bottom of the cylinder is a right angle and carriers are not, as the carrier is moved by hand to a more upright locked position position (a provision of the procedure if the carrier does not freely rotate to a locked position), the cylinder may reach it’s pivot point and shift forward in the carrier. This yields very inconsistent and unrealistic results. DJG also has concerns with the safety of the individuals performing this test as the cylinder may unexpectedly fall out of the carrier to the surface below, potentially striking the tester or an observer. DJG believes the current test method utilizing the CAMI Mark II 6-month-old infant dummy is adequate and it is a proven infant surrogate for use in this safety standard. The few inconsistencies observed by the CPSC in utilizing the test dummy are far more easily addressed than those posed by utilizing the proposed aluminum test cylinder. The aluminum test cylinder does not adequately represent an infant regarding structure or center of gravity. If the CAMI Mark II 6-month-old infant dummy is incorporated into the proposed regulations, the six month implementation schedule is sufficient. If the aluminum cylinder is to be incorporated, a much longer effective date would be needed as the aluminum cylinder infant surrogate changes the test outcome and will likely require further product design changes. Respectfully Submitted Terry Emerson DJG