We support the staff recommendation to adopt ASTM F2670-13 as well as the inclusion of specific changes to the instructions and warnings and additional changes in other areas. Infant bath tubs are more commonly used now that there are currently no infant bath seats made or sold in the United States that meet CPSC’s mandatory standard (16 C.F.R. Part 1215). The biggest danger with any product used by infants and toddlers in water is drowning as shown by the incident data CPSC reviewed in preparing the proposed rule.  While design can help direct more parental supervision, warnings are used to communicate the drowning risk directly.

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