LOG OF PHONE CALL

DIRECTORATE FOR ENGINEERING SCIENCES

SUBJECT: Correspondence from Nancy Gold regarding 

the NPR on Frame Child Carriers 

DATE OF CALL: July 28, 2014

LOG ENTRY SOURCE: Patricia Edwards, Project Manager, Frame 

Child Carriers Rulemaking Project

COMMISSION ATTENDEES: Patricia Edwards

OTHER ATTENDEES: Nancy Gold, President Tough Traveler

BACKGROUND:

Ms. Gold sent a letter, via Todd Stevenson, to the CPSC, dated July 19, 2014, 

regarding the open regulation on Frame Child Carriers. Specifically, Ms. Gold 

requested an extension of the open comment period for the NPR and in her 

letter, she outlines several problems, most in the form of questions, regarding the 

proposed rule and third party testing. With the comment period deadline fast 

approaching, I was instructed to call Ms. Gold to answer some of the questions in 

her letter. 

Ms. Gold is the President of Tough Traveler, a domestic manufacturer of a 

variety of travel oriented products, including frame child carriers. Ms. Gold was 

first made aware of the upcoming regulation via a phone call from Dr. Jill Jenkins 

from the Directorate for Economic Analysis in the spring of 2014. Dr. Jenkins was 

obtaining information from suppliers in order to prepare a memorandum 

regarding the impact of the proposed rule on small businesses. 

SUMMARY OF PHONE CALL:

In our phone conversation, Ms. Gold was provided with contact information for

three separate laboratories that were knowledgeable and capable of testing 

frame child carriers to the proposed rule. In addition, I provided Ms. Gold with 

some general information regarding the ASTM process, the CPSIA (specifically 

the durable nursery products regulatory process outlined in section 104), and 

clarified some information that was in the staff’s NPR briefing package. During 

our conversation, Ms. Gold had several other questions that she requested 

answers to and I told her that along with her letter dated July 19, 2014, I would 

add these additional questions, in the form of a phone call log, to the public 

comments for the open regulation. Staff will review and respond to her comments 

in the briefing package for the final rule. 
Page 2 of 2 

Phone Log

July 28, 2014

Nancy Gold, Tough Traveler

Additional questions from Ms. Gold:

1) Tough Traveler is a registered small batch manufacturer. Ms. Gold 

would like to know why the CPSC cannot apply the small batch rules to 

the third party testing requirements in section 104 of the CPSIA. 

2) Ms. Gold is interested in what the Directorate for Economic Analysis 

means (as outlined in the briefing package) by the word “insignificant”. 

And, would the staff recommend anything different if the rule was found 

to be significant on most/all small businesses? 

3) Ms. Gold believes that the term “domestic manufacturer” should mean 

that the physical manufacturing of the product takes place in the US. 

And she feels that the rules for determining significant vs. insignificant 

impact should be different between manufacturers who produce product 

in the US vs. those who have manufacturing facilities overseas. She 

believes there is a need for treating them differently, based on the 

differences in manufacturing costs and profit. 

4) Ms. Gold had questions regarding what constitutes a different model of 

a product or what changes in the product will require additional 3rd party 

testing. For example, she was told by a testing laboratory that a color 

change of the fabric would require new testing. Also, if the fabric was 

from a new bolt of material, this too would constitute enough of a 

change to require additional testing. In addition, she was told that if she 

buys the same type of metal washer, but from a new source, this would 

also require new testing. She would like some clarification as to what 

changes to the frame child carrier would constitute enough of a 

difference that it requires additional 3rd party testing with respect to the 

104 rules.