Mandatory Safety Standards for High Chairs under Consideration

The Consumer Product Safety Commission is seeking comments from interested parties by 25 January 2016 on a proposal to establish mandatory safety standards for high chairs. The Commission is proposing to incorporate by reference into its regulations voluntary standard ASTM F404-15, Standard Consumer Safety Specification for High Chairs, and establish more stringent requirements for rearward stability and warnings on labels and in instructional literature. The CPSC notes that after examining four international standards that apply to high chairs, including the current European and Australian standards, it determined that ASTM F404-15 is generally a more stringent standard and better tailored to address the hazard patterns shown in the incident data.

ASTM F404-15 defines a “high chair” as “a free standing chair for a child up to 3 years of age which has a seating surface more than 15 in. above the floor and elevates the child normally for the purposes of feeding or eating.” The standard further specifies that a high chair may be sold with or without a tray, have adjustable heights and recline for infants. There are various designs and construction materials for high chairs. They typically consist of a plastic, wood or metal frame, often with a padded fabric seat, and may fold for storage and transport or convert for continued use as a child grows. Some high chairs include a removable snack tray or mounted toy accessories and some have no trays. High chairs may have a passive crotch restraint (i.e., two separate bounded openings for the occupant’s legs), a rigid front torso support, a three-point restraint system, or a five-point restraint system with shoulder harnesses. High chair designs include restaurant-style chairs, four-legged A-frame styles, single-leg pedestals and Z-frame styles.

The proposed mandatory standard includes a rearward stability index rating that evaluates the factors that contribute to rearward tip-overs and sets a minimum SI score for high chairs. The SI was developed after reviewing various stability requirements and the incident data and testing numerous high chair models, including those involved in rearward tip-over incidents and those not reported to be involved in such incidents. The SI measures the elements associated with high chair occupants pushing back from a surface and rates high chairs based on two characteristics associated with rearward tip-overs: the force required to tip the chair over in the rearward direction and the distance that a reference point on the seat travels as the chair tilts from the manufacturer’s recommended use position to the point of instability just before tipping over. A chair design will score well if it requires a large push-off force and/or a long distance to reach its tipping point.

The proposed test method includes the following elements:

• attach a force gauge to the centre line of the back of the seat, 7.25 inches above the seating surface, and preload it with three pounds of force to eliminate any slack in fabric or loose seats;

• establish an initial reference point along the plane of the force gauge;

• gradually apply a rearward, horizontal force until the point at which the chair becomes unstable and begins to tip over backward;

• record the maximum force applied during the tip test along with the total distance the reference point moved from its pre-determined position; and

• calculate the SI by multiplying the force by a factor of two and adding the distance.

Based on the product testing conducted, the CPSC is proposing a minimum SI score of 50. The high chair seat back, tray, seat and wheels would have to be in specific positions for rearward stability testing in an effort to decrease variability in test methods and results. Moreover, a specific test surface would be required, including 60-grit sandpaper to prevent sliding and maximum parameters for the stop block placed behind a high chair with wheels to instigate tipping. The proposal would also require high chairs to bear labels that address the following statements:

• Children have suffered skull fractures after falling from high chairs. Falls can happen quickly if child is not restrained properly.

• Always use restraints, and adjust to fit snugly. Tray is not designed to hold child in chair.

• Stay near and watch your child during use.

• In addition, the CPSC is proposing to require the following warnings for high chairs:

• a statement describing the speed with which incidents can occur;

• a detailed description of what “attending” means, including staying near and watching a child;

• an instruction to use the restraint system and a statement that the tray is not part of the restraint system;

• an instruction to adjust the restraints to fit the child snugly; and

• a warning statement regarding the hazard, consequences and appropriate actions to appear together on a label.

Similarly to ASTM F404–15, for high chairs that have a seating component that is also used as a seating component for a stroller the content of the labels would be required to comply with ASTM F833, Standard Consumer Safety Performance Specification for Carriages and Strollers. However, while ASTM F404–15 only requires compliance with section 8.2.2.2 of ASTM F833, the CPSC is also proposing to require the additional warning provided in section 8.2.2.1. The Commission incorporated the most recent revision of this standard (ASTM F833–13b) into 16 CFR part 1227 as the safety standard for carriages and strollers, with some modifications, effective 10 September 2015.