Juvenile Products Manufacturers Association, Inc.

15000 Commerce Parkway, Suite C  Mt. Laurel, NJ 08054  856.638.0420  856.439.0525 

E‐mail: jpma@ahint.com  Website: www.jpma.org 

May 7, 2012 

Mr. Gregory K. Rea 

U.S. Consumer Product Safety Commission 

4330 East West Highway 

Bethesda, MD 20814 

RE: Notice of Proposed Rulemaking Safety Standard for Play yards effective date 

Dear Mr. Rea: 

Manufacturers who have participated in the voluntary standards process for ASTM F 

406-11, Standard Consumer Safety Specification for Non-Full-Size Baby Cribs/Play 

Yards have been planning to meet the draft requirements set forth in the Notice of 

Proposed Rulemaking (NPR). They have already invested time and resources to develop 

working solutions to those requirements provided in the NPR. However, the CPSC has 

recently furnished IDI 110825CAA2853 to the ASTM task group and has subsequently 

communicated an additional concern associated with missing components for bassinet 

accessories used in play yards. As participants within the ASTM process, manufacturers 

have responded quickly to analyze the details associated with the IDI provided and they 

have also assisted in the development of a draft requirement to address this recently 

discovered concern. The requirement has undergone several revisions in a short time thus 

demonstrating; the difficulty in creating the language necessary to address the concern, 

and the measure to which the task group has diligently supported the effort by supplying 

comments and recommendations for improvement. 

Although the draft language is near finalization, manufacturers are only beginning to 

comprehend the options available for compliance in a manner in which design solutions 

may be developed. Consequently the addition of this late requirement has manufacturers 

very concerned over the staff’s original recommended effective date of 6 months from 

publication of final rule. 

Manufactures concur with the staff’s point under Section VIII Alternatives of the NPR, 

that establishing an effective date later than the staff-recommended 6-month-period, 

would reduce the impact on firms whose play yards are not expected to meet ASTM F 

406-11. This would allow suppliers additional time to modify and/or develop compliant 

play yards and spread the associated costs over a longer period of time. To add specifics 

to this point, manufacturers are faced with the many additional challenges including but 

not limited to: (1) Training staff on new requirements, (2) Innovating solutions that have 

the capability of being manufactured, (3) addressing products that are midway through 

the development process, (4) Addressing products that are presently in the market, (5) 

Assessing the retailers reaction to the changes and addressing those accordingly. All of 

these points require consideration to ensure a safe and compliant product is produced. 
Juvenile Products Manufacturers Association, Inc.

15000 Commerce Parkway, Suite C  Mt. Laurel, NJ 08054  856.638.0420  856.439.0525 

E‐mail: jpma@ahint.com

Deviation or compression of the schedules brings added risk, cost and potentially 

inferior products. 

For these reasons, manufacturers within the task group are requesting that 

the CPSC staff recommendation for the Final Rule be 12 months from publication 

in the federal register and that it be applicable to product manufactured after such 

date. This timeframe recommendation is in line with the CPSC allowance for many 

established regulations. 

We are eager to continue to work with developing and solidifying the final requirements 

using the ASTM process but find this to be a major area of importance and we are 

seeking your support with the recommendation. We urge you to consider this 

recommendation in order to appropriately establish a reasonable effective date for the 

Play Yard Final Rule. 

 Sincerely, 

Michael R. Dwyer, CAE 

Executive Director 

 Website: www.jpma.org