In the Notice of Proposed Rulemaking, the Commission proposes a mandatory safety standard for infant inclined sleep products that is based on the voluntary standard developed by ASTM International (ASTM F3118-17), but with one definition change. As we express in the following comments, we have significant concerns with the hazards posed by the entire product class of infant inclined sleepers. While we support the implementation of a strong mandatory safety standard – with a goal of making these products as safe as a compliant full-size crib – we propose several recommendations to improve the standard in a manner that will ensure it protects our most vulnerable family members.

For the full comments, click here.