Statement of Diana Zuckerman, President National Research Center for Women & Families On Behalf of Members of the Patient, Consumer and Public Health Coalition
I am Dr. Diana Zuckerman, president of the National Research Center for Women & Families. I am very pleased to speak today on behalf of our Center and to reflect the views of members of the Patient, Consumer, and Public Health Coalition. I am a long-time Maryland resident and was formerly the chair of Maryland’s Women’s Health Promotion Council (appointed by Gov. Glendening), as well as a member of the Montgomery County Commission for Women. Just as important for today’s hearing, I am a mother of two children who had no idea that there were any risks when I bought crib bumper pads for my children years ago.
I speak today from my perspective as a mother, a professional who has devoted her career to improving the health and safety of children and adults, and as a researcher trained in epidemiology at Yale Medical School and a former faculty member at Vassar and Yale, and researcher at Harvard. From all those perspectives, I strongly support efforts to protect our children by removing crib bumper pads from our stores and hopefully from our homes.
Members of our coalition of nonprofit organizations 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.”
DHMH has carefully followed the law in this matter and provided many opportunities for public comment. As we noted in our July letter, crib pads were originally designed 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. The pads are now purely decorative, and no health expert has suggested any benefit that outweighs the risks.
The Juvenile Products Manufacturers Association (JPMA) claims that bumper pads with a thickness of 2 inches (the ASTM standard) or less are safer than thicker bumper pads. However, they offer no scientific evidence to support that 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. The risks of suffocations, strangulations, and entrapment are well-established while the safety of thinner bumpers are unproven.
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 by adults who are not new parents and therefore unaware of the risks. 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 firstname.lastname@example.org
- 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