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 th e 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 alread y invested time and resources to develop working solutions to those requirements prov ided in the NPR. However, the CPSC has recently furnished IDI 110825CAA2853 to the ASTM task group and has subsequently

communicated an additional concern associ ated with missing components for bassinet accessories used in play yards. As particip ants within the ASTM process, manufacturers have responded quickly to anal yze 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 undergon e 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, manufactur ers are only beginning to comprehend the options available for complia nce 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 reco mmended effective date of 6 months from publication of final rule.

Manufactures concur with th e staff’s point under Section VIII Alternatives of the NPR, that establishing an effective date late r 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 ti me to modify and/or develop compliant play yards and spread the asso ciated costs over a longer period of time. To add specifics to this point, manufacturers are faced with the many additi onal 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 produ cts that are presently in the market, (5) Assessing the retailers reac tion to the changes and addressing those accordingly . All of these points require consider ation 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 Fi nal Rule be 12 months from publication in the federal register and that it be app licable to product manufactured after such

date. This timeframe recommendation is in li ne with the CPSC allowance for many established regulations.

We are eager to continue to work with deve loping 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 a ppropriately establish a reasonable effective date for the Play Yard Final Rule.

Sincerely,

Michael R. Dwyer, CAE

Executive D irector

 Website: www.jpma.org