Federal law requires that non-full-size baby cribs comply with the non-full-size crib standard and with additional requirements, including those of the Consumer Product Safety Improvement Act of 2008 (CPSIA).
Manufacturers and importers of cribs must certify in a Children's Product Certificate that the cribs comply with the standard and the additional requirements after the cribs have been tested for compliance at a CPSC-accepted, third party laboratory. These requirements are reviewed in greater detail at www.cpsc.gov/cpsia.
What is a non-full-size baby crib?
A non-full-size crib is a bed designed to provide sleeping accommodations for an infant, in or around the home, for travel, in a child care facility, in a family child care home, in a place of public accommodation affecting commerce, and for other purposes. A non-full-size crib has an interior length dimension that is either greater than 139.7 cm (55 in.) or smaller than 126.3 cm (49 3/4 in.), or, an interior width dimension either greater than 77.7 cm (30 5/8 in.) or smaller than 64.3 cm (25 3/8 in.), or both. A non-full-size crib is either smaller or larger than a regular full-size crib and includes:
1. a crib designed to be folded or collapsed without being taken apart so that it has a smaller volume than when it is in use;
2. a crib pen (with hard sides) that has legs that can be removed to make a play pen for a child; and
3. a circular, hexagonal, or other unconventionally shaped crib that has a special mattress or other unconventional parts.
A non-full-size crib does not include mesh/net/screen cribs, nonrigidly constructed cribs, cradles, car beds, baby baskets, and bassinets. Other CPSC standards may apply to these products.
What is the purpose of the non-full-size baby crib standard?
The standard seeks to prevent deaths and injuries from falls, entrapment, and contact with parts inside or outside a crib.
Where can I find the standard for non-full-size baby cribs?
The standard is published in the Code of Federal Regulations at 16 CFR Part 1220. The standard incorporates by reference ASTM F406-10a, with the following four modifications: (1) The CPSC's standard excludes the provision in section 6.12 of the ASTM standard that requires retightening of screws and bolts between the crib side latch test and the mattress support vertical impact test (§ 1220.2(b)(3) of the CPSC's standard). (2) The CPSC's standard adds a sentence to clarify the testing of cribs with folding or movable sides. (3) The third modification to ASTM F 406-10a revises a warning in section 18.104.22.168 of the ASTM standard that cautions against using netting or other covers (§ 1220.2(b)(12) of the CPSC's standard). (4) The final modification to ASTM F 406-10a removes the provisions that relate only to play yards (§ 1220.2(b)(1), (2), (4), and (6) through (11) of the CPSC standard). The specific requirements and descriptions of the tests for non-full-size cribs are in ASTM F 406-10a, which can be purchased from ASTM.
Which cribs must comply with these requirements, and when do they need to comply?
Non-full-size cribs manufactured, sold, resold, or otherwise placed in the stream of commerce (except for leasing) must meet all requirements of the non-full-size crib standard by June 28, 2011. Child care centers, family child care homes, and places of public accommodation (such as hotels and motels) that provide cribs for use must meet the non-full-size crib requirements by December 28, 2012. Companies that lease cribs also have until December 28, 2012, to meet the crib requirements. Cribs that are medical devices, as determined by the U.S. Food and Drug Administration are not subject to the CPSC's non-full-size crib standard.
What are the requirements for non-full-size cribs?
The principal requirements for non-full-size cribs are:
- dynamic impact testing of the mattress support system-intended to address incidents involving collapse or failure of mattress support systems;
- impact testing of side rails and slat strength/integrity testing-intended to prevent slats and spindles from breaking and/or detaching during use;
- mattress support system testing-intended to ensure that the mattress support does not become detached from the frame, potentially resulting in a fall;
- latching mechanism tests-intended to ensure that latching and locking mechanisms work as intended, preventing unintended folding while in use; also requires that latching mechanisms be used with drop gates and movable sides;
- crib side configurations-intended, in part, to limit movable (drop) sides; addresses the numerous incidents related to drop-side failures;
- label requirements-cover numerous hazards, such as falls from the crib, suffocation on soft bedding, and strangulation on strings and cords;
- openings requirement for mattress support systems-addresses gaps in the mattress support system to minimize the possibility of entrapment;
- requirements for wood screws and other fasteners-address hazards that exist when wood screws are the primary method of attachment; also includes other fastener requirements to address incidents related to loose hardware and poor structural integrity;
- cyclic testing-addresses incidents involving hardware loosening and poor structural integrity;
- misassembly issues-addresses the need to make it impossible to misassemble key elements, or those elements must have markings that make it obvious when they have been misassembled;
- test requirement for accessories-intended to address any cribs that now or may in the future include accessories, such as bassinets or changing tables;
- crib interior dimensions, as noted above; and
- component spacing - intended to prevent child entrapment between both uniformly and nonuniformly spaced components, such as slats.
Which specifications must be met for a mattress supplied with a non-full-size crib?
Non-full-size cribs must be sold with the mattress included. The mattress must meet the following requirements:
1. When noncompressed, the mattress must be thick enough to provide:
- a distance of at least 20 inches from the top of the mattress to the top of the crib side and/or end panel at the highest adjustable position when the mattress support is at its lowest position; and
- a distance of at least 3 inches from the top of the mattress to the top of the crib side and/or end panel at the lowest adjustable position when the mattress support is at its highest position;
2. When the noncompressed mattress is centered in the crib at any of the adjustable mattress support positions, the gap between the perimeter of the mattress and the perimeter of the crib cannot be greater than 1/2 inch at any point. When the mattress is placed against the perimeter of the crib, the resulting gap cannot be greater than 1 inch at any point.
What are the additional requirements for non-full-size cribs required by the Consumer Product Safety Improvement Act of 2008?
Non-full-size cribs are subject to surface coating requirements, lead and phthalate content limits, testing and certification, registration cards, and tracking label requirements. These requirements are discussed below:
- Surface Coating Limit Non-full-size cribs may not be painted with paint that contains more than 0.009 percent lead.
- Lead Content Limit Non-full-size cribs cannot contain greater than 100 ppm (0.01 percent) of total lead content in any accessible component part.
- Phthalate Content Limits Plasticized components of non-full-size cribs cannot contain more than 0.1% of the following phthalates: di-(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), or benzyl butyl phthalate (BBP). Plasticized components of non-full-size cribs also may not contain more than 0.1 percent of diisononyl phthalate (DINP), diisodecyl phthalate (DIDP), or di-n-octyl phthalate while an interim statutory ban of these phthalates remains in effect.
- Testing and Certification Non-full-size cribs, like all products that are designed or intended primarily for children 12 years of age or younger, must be tested by an accredited third party laboratory accepted by the CPSC for compliance with the non-full-size crib standard and all other applicable children's product safety rules, including the lead paint, lead content, and phthalate content limits. Based on that testing, a domestic manufacturer (or importer) of non-full-size cribs must issue a Children's Product Certificate specifying each applicable rule and indicating that the product complies with those rules.
- Registration Cards Each manufacturer of a non-full-size crib must (1) provide a postage-paid consumer registration form with each product and (2) keep records of consumers who register their products with the manufacturer. In addition, manufacturer's add permanent markings to the product that state (3) the manufacturer's name and contact information, (4) the model name and number, and (5) the date of manufacture permanently on each such product.
- Tracking Labels Non-full-size cribs must have a tracking label or other distinguishing permanent mark affixed to the product and its packaging. The tracking label shall be a permanent distinguishing mark on the product and its packaging, to the extent practicable, and must contain certain basic information, including the (1) name of the manufacturer or private label, (2) the location and date of manufacture, and (3) cohort information, such as a batch or run number.
To the extent that the information required to be marked on the product (by the tracking label requirement and the registration card rule) is duplicative, you may combine the markings on the product to satisfy both requirements. Note that the tracking label requirement must also be marked on the product's packaging.
Where can I find additional information?
For more information on the requirements for Non-Full-Size Baby Cribs, contact the U.S. Consumer Product Safety Commission:
- Office of Education, Global Outreach, & Small Business Ombudsman (Assistance in Understanding and Complying with CPSC Regulations): e-mail: Business@cpsc.gov; telephone: (301) 504-7999.
- Office of Compliance (Enforcement Inquires): e-mail: firstname.lastname@example.org; telephone: (301) 504-7520.
For additional information on crib safety, visit the CPSC Crib Information Center
Additional information on enforcement for child care providers.
To obtain copies of ASTM F406-10a, contact ASTM International at: www.astm.org or via telephone: (610) 832-9585.