September 28, 2012
Michele Phinney, Director
Office of Regulation and Policy Coordination
Department of Health and Mental Hygiene
201 W. Preston St.
Baltimore, MD 21201
Re: Request for Public Comment: ASTM International Standard Consumer Safety Performance Specification for Infant Bedding and Related Accessories.
Dear Director Phinney,
As members of the Patient, Consumer, and Public Health Coalition, we are writing to strongly oppose the use of ASTM International Standard (F1917-12) as a safety standard for baby bumper pads. The standard is not a useful alternative to the Department of Health and Mental Hygiene’s (DHMH) proposed ban. As we stated in our July 19, 2012 letter to DHMH, we agree with DHMH that “the pads pose a risk of suffocation, strangulations, and death.”
We noted in our July letter that crib pads were originally developed to prevent an infant’s head from becoming entrapped between crib slats. However, for many years cribs have been required to place their slats closer together, so that design problem has been solved without the use of risky crib bumper pads. As a result, the pads are now purely decorative.
The Juvenile Products Manufacturers Association (JPMA) is attempting to use ASTM standards to distinguish between safe and unsafe baby bumper pads. JPMA claims that bumper pads with a thickness of 2 inches (the ASTM standard) or less are safer than thicker bumper pads. However, JPMA offers no scientific evidence to support this claim and it would be impossible to ethically conduct such research. If a bumper pad (no matter how thick or thin) blocks an infant’s airway, the infant will suffocate. And, although it may seem logical to conclude that thinner bumper pads are safer than thicker pads, that would not mean they are as safe as no pads at all. Given that doctors on Maryland’s expert advisory panel reviewing crib baby bumpers concluded that there was no evidence for meaningful benefits of bumper pads to infants, even a small risk is unacceptable.
The U.S. Consumer Product Safety Commission reviewed its databases from January 1, 1990 to May 6, 2010 and found “a total of 52 infant deaths where bumper pads were mentioned in the narrative.” In ten of the reports, there were no other contributing factors to the deaths other than the infant sleeping face-down next to the bumpers. The reports included statements such as “face obstructed by bumper pad” and “suffocated in corner against bumper pad.” There is no evidence that a thinner bumper pad would not cause suffocation if the child is lying in a corner against the pad. Any possible benefits from these new crib bumper pads would be wishful thinking and clearly eclipsed by the already established serious risks of suffocation and injury.
ASTM F1917 waffles when it comes to safety. In section 1.4, ASTM issues a “safety hazards caveat” pertaining to the testing method. It states, “This standard does not purport to address the safety concerns, if any associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use” (emphasis in original). However, in the Rationale section of the standard (Section X 1.1), it states that testing to limit “the overall thickness of bumpers [to 2 inches] has not been known to present a hazard.” ASTM provides no evidence to back up that statement, and it is inconsistent with the previously quoted statement. Moreover, in section 8.2.1, it states: “Warning to reduce the risk of suffocation, keep top of bumper up and in position.” Obviously, the risk of suffocation still exists or they would not require a warning label about the risk.
Members of the Patient, Consumer, and Public Health coalition support DHMH’s proposed ban on the sale of baby bumper pads in the state of Maryland. The ASTM standard is absolutely not a viable alternative. F1917-12’s performance requirements will not mitigate the severe risks (suffocations, strangulations, and entrapment) associated with bumper pads. The risk of bumper pads in cribs are well established while the safety or benefits of “safer” bumpers are unproven and certainly do not outweigh those risks. The performance requirements address the thickness of the pads, not the fact that the pads—no matter how thin or thick—can block an infant’s airways.
In the ideal world, parents would understand the risks of crib bumpers and would decide not to use them. However, in the real world, not all parents understand these risks, and it is not uncommon for crib bumpers to be given as baby gifts, especially by adults who are not new parents and therefore unaware of the risks. The ASTM standard that claims some bumper pads are less risky will muddle the safety issue even more and give parents a false sense of security. Maryland’s proposed ban on crib bumper pads will help to protect more than 70,000 babies born in the state each year, and that is a bottom line upon which we should all agree.
American Medical Women’s Association
National Consumers League
National Research Center for Women & Families
National Women’s Health Network
For more information, contact Paul Brown at (202) 223-4000 or email@example.com
 Maryland Department of Health and Mental Hygiene (2012). Q & A – Proposed Regulations Banning Baby Bumper Pads.
 Pediatrics, SIDS and Other Sleep-Related Infant Deaths: Expansion of Recommendations for a Safe Infant Sleeping Environment; Pediatrics 2011; 128; e1341; originally published online October 17, 2011.
 Maryland Department of Health and Mental Hygiene (2012). Background and Assessment for Proposal to Prohibit Safe of Baby Bumper Pads.
 Consumer Product Safety Commission (2010). White Paper – Unsafe Sleep Settings Hazards Associated with the Infant Sleep Environment and Unsafe Practices Used by Caregivers: A CPSC Staff Perspective.
 ASTM published new infant bedding standard (August 14, 2012). Kids Today. http://www.kidstodayonline.com/article/554341-ASTM_publishes_new_infant_bedding_standard.php
 ASTM F1917-12 (2012). Standard Consumer Safety Performance Specification for Infant Bedding and Related Accessories. http://www.astm.org/VIEWER_TEMP_PDFS/F1917_md_dhmh.8982.pdf