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INTRODUCTION
This consumer safety specification addresses incidents of head and neck entrapment in children’s
expansion gates and expandable enclosures. It also addresses the ability of a pressure gate to resist a
push-out force.
The U.S. Consumer Product Safety Commission (CPSC) identified incidents that generally involved
a child’s head or neck, or both, becoming entrapped in diamond shaped openings and strangulation of
children in V-shapes at the top of accordion style expansion gates or expandable enclosures.
Additional incidents and injuries were identified that involved children attempting to climb up and
over expansion gates and expandable enclosures, and pushing or pulling pressure gates out of
doorways.
This consumer safety specification is written within the current state-of-the-art of gate and enclosure
technology. It is intended that this consumer safety specification will be updated whenever substantive
information becomes available, which necessitates additional requirements or justifies the revision of
existing requirements.
This specification does not address incidents in which gates or enclosures are blatantly misused
although warnings and safety instructions are required to be displayed prominently on and with each
gate or enclosure.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959, United States.
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2.2 Federal Regulations:3 from a gap between a wall surface and the main structure of a
16 CFR 1303 Ban of Lead-Containing Paint and Certain baby gate would be considered a partially-bounded opening.
Consumer Products Bearing Lead Containing Paint 3.1.10 static load, n—a vertically downward force applied
16 CFR 1500 Hazardous Substances Act Regulations, In- by a calibrated force gage or by dead weights.
cluding Parts:
16 CFR 1500.48 Technical Requirements for Determining a 4. Calibration and Standardization
Sharp Point in Toys and Other Articles Intended for Use 4.1 All testing shall be conducted on a concrete floor which
by Children Under Eight Years of Age may be covered with 1⁄8-in. (3-mm) thick vinyl floor cover,
16 CFR 1500.49 Technical Requirements for Determining a unless the test instructs differently.
Sharp Metal or Glass Edge in Toys and Other Articles 4.2 The gate/expandable enclosure shall be completely as-
Intended for Use by Children Under Eight-Years of Age sembled, unless otherwise noted, in accordance with the
16 CFR 1501 Method for Identifying Toys and Other manufacturer’s instructions.
Articles Intended for Use by Children Under Three Years 4.3 No testing shall be conducted within 48 h of manufac-
of Age Which Present Choking, Aspiration, or Ingestion turing.
Hazards Because of Small Parts 4.4 The product to be tested shall be preconditioned in a
3. Terminology room with an ambient temperature of 73° 6 9°F (23° 6 5°C)
for at least 1 h prior to testing. Testing then shall be conducted
3.1 Definitions of Terms Specific to This Standard: within this temperature range.
3.1.1 completely-bounded opening, n—any opening in the 4.5 All testing required by this specification shall be con-
main structure of a product that is enclosed totally by bound- ducted on the same unit.
aries on all sides.
3.1.2 conspicuous, adj—a label which is visible, when the 5. General Requirements
gate/expandable enclosure is in a manufacturer’s recom-
mended use position, to a person standing near the gate/ 5.1 Wood Parts—Prior to testing, any exposed wood parts
expandable enclosure at any one position around the gate/ shall be smooth and free from splinters.
expandable enclosure, but not necessarily visible from all 5.2 Screws shall not be used in the assembly of any
positions. components or locking or attaching device (or devices) that are
3.1.3 double-action locking mechanism, n—a locking intended to be removed by the consumer during daily opera-
mechanism that requires two distinct and separate actions in a tions.
single lock to activate the release mechanism. 5.3 There shall be no hazardous sharp edges or points as
3.1.4 expandable enclosures, n—a self-supporting barrier defined by 16 CFR 1500.48 and 16 CFR 1500.49 before or
intended to completely surround an area or play-space within after testing to this consumer safety specification.
which a young child (see 1.2) may be confined. Enclosures 5.4 There shall be no small parts as defined by 16 CFR 1501
may be marketed for indoor or outdoor use, or both. before testing or liberated as a result of testing to this
3.1.5 expansion gate, n—a barrier intended to be erected in specification.
an opening, such as a doorway, to prevent the passage of young 5.5 Latching or Locking Mechanisms—Any unit that folds,
children (see 1.2), but which can be removed by older persons or has a moveable panel, shall have a latching or locking
who are able to operate the locking mechanism. Such gates are device or other provision in the design that will prevent the unit
available in a number of different styles of construction and are from unintentionally folding when properly placed in the
manufactured from a variety of different materials. manufacturer’s recommended use position. The unit shall
3.1.6 manufacturer’s recommended use position(s)—any remain in its manufacturer’s recommended use position during
position to prevent passage of a child which the manufacturer and upon completion of the test, described at 7.1. If a unit is
represents as a normal, allowable or acceptable configuration. designed with a latching or locking device in order to prevent
This specifically excludes positions, which the manufacturer folding or to keep the unit in the closed position, that device
shows in a like manner in its literature to be unacceptable, shall remain engaged and operative after testing.
unsafe or not recommended. 5.6 Openings—Holes or slots that extend entirely through a
3.1.7 nonpaper label, n—any label material, such as plastic wall section of any rigid material less than 0.375 in. (9.53 mm)
or metal, which either will not tear without the aid of tools or thick and admit a 0.210–in. (5.33–mm) diameter rod shall also
tears leaving a sharply-defined edge. admit a 0.375–in. (9.53–mm) diameter rod. Holes or slots that
3.1.8 paper label, n—any label material, which tears with- are between 0.210 in. (5.33 mm) and 0.375 in. (9.53 mm) and
out the aid of tools and leaves a fibrous edge. have a wall thickness less than 0.375 in. (9.53 mm) but are
3.1.9 partially-bounded opening, n—any opening in the limited in depth to 0.375 in. (9.53 mm) maximum by another
main structure of a product that is not enclosed totally by rigid surface shall be permissible (see Fig. 1). The product shall
boundaries on all sides. For example, a V-shape in the top of an be evaluated in all manufacturer’s recommended positions.
accordion slat-style product or a rectangular notch resulting 5.7 Exposed Coil Springs—Any exposed coil spring, which
is accessible to the occupant having or capable of generating a
space between coils of 0.210 in. (5.33 mm) or greater during
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Code of Federal Regulations is available from the Superintendent of Docu- static load testing in accordance with 7.1 shall be covered or
ments, Government Printing Office, Washington, DC 21402. otherwise designed to prevent injury from entrapment.
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FIG. 1 Openings
5.8 Scissoring, Shearing, and Pinching—The gate/ push-out force shall exceed 30 lbf (133 N). In addition, each
expandable enclosure when in the manufacturer’s recom- individual force shall exceed 20 lbf (89 N). Pressure gates that
mended use position(s) shall be designed and constructed to fail to meet these requirements shall bear a warning that they
prevent injury to the child from any scissoring, shearing, or shall not be used at the top of stairs, in accordance with 8.5.5.
pinching when members or components rotate about a common
axis or fastening point, slide, pivot, fold, or otherwise move 6. Performance Requirements
relative to one another. Scissoring, shearing, or pinching that 6.1 The following performance requirements apply to gates
may cause injury shall not be permissible when the edges of and enclosures when they are erected or installed in the
any rigid parts admit a probe greater than 0.210 in. (5.33 mm) manufacturer’s recommended use position.
and less than 0.375 in. (9.53 mm) diameter at any accessible 6.1.1 Completely-Bounded Openings—Openings shall not
point through the range of motion of such parts. permit the passage of the Small Torso Template A (see Fig. 2)
5.9 Labeling: when tested in accordance with 7.3
5.9.1 Warning labels (whether paper or nonpaper) shall be 6.1.2 Height of Sides—The vertical distance from the floor
permanent when tested in accordance with 7.6.1-7.6.3. to the lowest point of the uppermost surface shall not be less
5.9.2 Warning statements applied directly onto the surface than 22 in. (560 mm) when measured from the floor.
of the product by hot stamping, heat transfer, printing, wood 6.1.3 Vertical Strength—Top rails, slats, and framing com-
burning, etc., shall be permanent when tested in accordance ponents of the gates or enclosures shall be tested in accordance
with 7.6.4. with 7.1 and shall not fracture, disengage, fold, or have a
5.9.3 Nonpaper labels shall not liberate small parts when permanent defection that reduces the lowest point of the
tested in accordance with 7.6.5. uppermost surface of a gate or enclosure (see 6.1.2) to a
5.10 Push-Out Test—Pressure-mounted gates shall be tested dimension of less than 22 in. (560 mm) when measured
in accordance with 7.7. At each test location the average vertically from the floor.
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NOTE 1—Small Torso Template A is to be constructed of smooth rigid material not less than 1⁄8 in. (3.18 mm) thick.
FIG. 2 Small Torso Template A
6.1.4 Bottom Spacing—The vertical distance from the floor joint. If the joints are different, apply load to the joints, which
to the highest point of the lowermost surface of the unit shall are more likely to result in a nonconformance as defined in 5.3.
not permit the passage of the Small Torso Template A (see Fig. 7.2 Locking Mechanism Test:
2) as tested in accordance with 7.3. For foot pedal actuated gates, apply a force of 35 lbf (156 N)
6.1.5 Configuration of Uppermost Edge—A partially in the direction tending to unlock it. The force shall be applied
bounded opening at any point in the uppermost edge of a to the foot pedal through a 2 by 2 by 3⁄4 –in. (50 by 50 by
product that is greater than 1.5 in (38 mm) in width and more 19–mm) wooden block. Gradually apply the force within 5 s
than 0.64 in. (16.2 mm) in depth shall be subjected to the test and maintain for an additional 10 s.
procedure in 7.4 (see Fig. 3). During the test, no portions of the 7.3 Size of Completely-Bounded Openings (6.1.1 and
boundaries of the opening shall simultaneously contact more 6.1.4)—The size of any completely-bounded opening shall not
than one of surfaces “B,” “C,” or corner “BC” or “CC” in any permit passage of Small Torso Template A (see Fig. 2) when
combination if they are not opposing sides of the center line of the template is rotated to any orientation about its own axis and
Test Template B (see Fig. 4). parallel to the plane of the opening (see Figs. 1 and 5).
6.1.6 Protective Components—If a child can grasp protec- 7.4 Partially-Bounded Openings at the Uppermost Edge
tive components, such as caps, sleeves, or plugs used for (6.1.5):
protection from sharp edges, points, or entrapment of fingers or 7.4.1 Place Test Template B (see Fig. 4) vertically down-
toes, between the thumb and forefinger, or teeth, or if there is ward into the opening with its center line vertical and the plane
at least a 0.040 in. (1.00 mm) gap between the component and of the template parallel to the plane of the opening, until
its adjacent parent component, such components shall not be downward motion is arrested by contact between the test
removed when tested in accordance with 7.5. template and the boundaries of the opening. By visual inspec-
tion, determine if there is simultaneous contact between more
7. Test Methods than one of surfaces “B” or “C,” or corners “BC” or “CC,” in
7.1 Vertical Strength (6.1.3 and 5.5): any combination, that are on opposite sides of the template
7.1.1 Gates—Adjust the gate to the maximum opening center line.
width recommended by the manufacturer. Apply a static load 7.4.2 If the opening conforms to the requirements, but is not
of 45 lbf (200 N) vertically downward five times to each of the symmetrical about a vertical centerline, perform the following
top points of the gate (or on center for gates with horizontal top additional test:
rail). The force shall be applied through a 2 by 2 by 3⁄4 in. (50 7.4.2.1 Rock the template sideways (parallel to the plane of
by 50 by 19 mm) wood block. Gradually apply the force within the opening), while maintaining contact between the boundary
5 s and maintain for an additional 10 s, with approximately 5 of the opening and surface “A” or corners “AB,” or both. The
s intervals between applications. Repeat the test with the gate rocking motion shall be terminated when there is either contact
adjusted to the minimum opening width recommended by the between a boundary of the opening and a surface or corner of
manufacturer. the template other than surface “A” or corners “AB,” or until
7.1.2 Enclosures—The same loading procedure as specified surface “B” attains a vertical orientation. Again, visually
in 7.1.1 is applicable but shall be applied to every other top determine if there is simultaneous contact between more than
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NOTE 1—Use a rectangular template to determine when a partially-bounded opening must be tested with Test Template B in accordance with 7.4.
FIG. 3 Walk-Through Style Baby Gate and Walls or Doorposts
one of surfaces “B” or “C,” or corners “BC” or “CC,” in any component and the structural member of the gate/expandable
combination, that are on opposite sides of the template center enclosure to which they are attached.
line. If such contact occurs, the opening fails to conform to the 7.5.3.1 The attachment device shall not compress or expand
requirement. the component so that it hinders any possible removal.
7.4.3 If a product contains any partially-bounded openings, 7.5.3.2 Apply force on the scale in a direction that normally
which change their configuration if the product is erected to would be associated with the removal of the protective
less than the maximum dimension claimed by the manufac- component.
turer, the test for conformance shall be repeated at the 7.5.3.3 Apply the force gradually over a 5 s period and hold
minimum dimension and, at the discretion of the test personnel, for an additional 10 s. The force required to break or remove
at any dimension between the claimed minimum and maxi- the component shall not be less than 15 lbf (67 N). Repeat this
mum. procedure once.
7.4.4 For any product in which the uppermost edge is a 7.5.4 Torque Test—A torque of 3 lbf-in. (0.3 N-m) shall be
nonrigid member, the visual inspection for conformance to the applied gradually within a period of 5 s in a clockwise direction
requirement shall be performed when a force of 30 lbf (134 N) until a rotation of 180° from the original position has been
is applied vertically downwards to Test Template B (see Fig. attained or 3 lbf-in. (0.3 N-m) has been reached. The torque or
4). maximum rotation shall be maintained for an additional 10 s.
7.5 Removal of Protective Components (6.1.6): The torque shall then be removed and the test components
7.5.1 Components shall be tested in accordance with each of permitted to return to a relaxed condition. This procedure shall
the following methods in the sequence listed. then be repeated in the counter clockwise direction.
7.5.2 Securely affix the gate/expandable enclosure so that it 7.6 Label Testing (5.9):
cannot move during performance of the following tests. 7.6.1 A paper label (excluding labels attached by a seam)
7.5.3 Tension Test—Attach a force gauge to the component shall be considered permanent if, during an attempt to remove
(cap, sleeve, or plug) by means of any suitable device. A clamp, it without the aid of tools or solvents, it cannot be removed, it
such as shown in Fig. 6 may be a suitable device for tears into pieces upon removal, or such action damages the
components that cannot reasonably be expected to be grasped surface to which it is attached.
by a child’s fingers on their outer diameter but which have a 7.6.2 A nonpaper label (excluding labels attached by a
gap of 0.040 in. (1.00 mm) or more between the rear face of the seam) shall be considered permanent if, during an attempt to
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NOTE 1—Test Template B is to be constructed of smooth rigid material not less than 1⁄8 in. (3.18 mm) thick.
FIG. 4 Test Template B
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7.7.2.1 Gate security tests shall be conducted at the mini- the pressure bar. If there is no pressure bar, at the midpoint in
mum and maximum opening widths recommended by the height of the gate, thread the cord through the mesh or bars in
manufacturer. the gate. Location 3 should be at the side of the gate most likely
7.7.2.2 Follow the manufacturer’s installation instructions to cause failure. Each location shall be tested five times and the
when installing the gate in the test opening. For a gate in which five readings then shall be averaged.
the installation force may influence the test results, install the
gate by applying a maximum force of 25 lbf (111 N) to a hand 8. Marking and Labeling
operated mechanism or a maximum force of 35 lbf (157 N) to 8.1 Each gate/expandable enclosure shall have a permanent
a foot operated mechanism. label or marking that identifies the name and address (city,
7.7.2.3 To ensure alignment, install the gate in the test state, and zip code) of either the manufacturer, distributor, or
opening with the sides of the pressure pads touching the seller.
molding that simulates a door stop. Care should be exercised to
8.2 A permanent code mark or other product identification
ensure that, when pressure is applied to the gate through the
shall be provided on the gate/expandable enclosure and its
locking mechanism, bending of the gate’s vertical end mem-
package or shipping container, if multiple packaging is used.
bers does not cause these members to touch the doorstop
The code will identify the date (month and year) of manufac-
molding.
ture and permit future identification of any given model.
7.7.2.4 Attach a cord (such as a venetian blind cord) to the
gate at Location No. 1 (see Fig. 8). Secure the cord to a force 8.3 The manufacturer shall change the model number of the
gage with a range of at least 0 to 100 lbf (0 to 445 N) so that gate/expandable enclosure whenever it undergoes a significant
it passes over the top edge of the upper horizontal member. structural or design modification or change which affects its
7.7.2.5 Gradually apply a tensile force on the cord over a conformance to this specification.
period of 5 s until it reaches 100 lbf (445 N) and sustain this 8.4 Each gate/expandable enclosure shall be labeled with
force for an additional 10 s. Make sure that the force is applied warning statements. The warning statements shall be in con-
perpendicular to the plane of the gate. If the gate contact trasting color(s), permanent, conspicuous, and in sans serif
surface loses contact with the test fixture before attaining 100 style font. The warnings shall appear in the English language at
lbf (445 N), record the force at which loss of contact occurred. a minimum.
All tensile force applications shall be made from the side of the 8.4.1 Letters burned in wood are considered contrasting.
gate opposite to the side normally occupied by the child (see 8.4.2 The letters of the word WARNING shall be at least 0.2
Fig. 8). in. (5 mm) high and the remainder of the text shall be in
7.7.2.6 Repeat at Locations 2 and 3. Note that at Location characters whose upper case shall be at least 0.1 in. (2.5 mm)
No. 2, the cord should be attached to the gate by looping it over high. Lettering style shall be sans serif.
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8.5 A warning statement shall be on each gate or enclosure 8.5.5 For gates that fail the test requirements of 5.10: To
containing the following minimum information: prevent falls, never use at top of stairs.
_! WARNING: 8.6 The retail package for gates shall state recommended
8.5.1 To prevent serious injury or death, securely install gate age of the user of the product, that the product is not to be used
or enclosure and use according to manufacturer’s instructions. with a child able to climb over or dislodge/open the gate, and
8.5.2 Never use with a child able to climb over or dislodge for gates that fail the test requirements of 5.10, the warning in
the gate or enclosure. 8.5.5.
8.5.3 Never leave child unattended.
8.5.4 For pressure-mounted gates that have locking mecha- 9. Instructional Literature
nisms on one side of the product: Install with locking mecha- 9.1 Instructions shall be provided with the gate/expandable
nism on side away from child. enclosure and shall be easy to read and understand. Assembly,
8.5.4.1 Double-action locking mechanisms located on the maintenance, cleaning, operating, folding instructions, and
top of the gates are not required to carry this warning. warnings, where applicable, shall be included.
8.5.4.2 For enclosures with locking/latching mechanisms: 9.2 Installation instructions shall include a statement of the
Use only with the locking/latching mechanism (or appropriate limitations regarding the use of any included mounting hard-
terminology) securely engaged. ware.
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APPENDIXES
(Nonmandatory Information)
X1. RATIONALE
X1.1 History of Consumer Safety Specification F 1004 X1.1.2 The history of this product category dates back to the
X1.1.1 Task group F15.22 formed in May 1982 to address end of the 1800s. Today, intense competition exists in this
fatalities and injuries involving young children as a result of industry.
the use of expansion gates and expandable enclosures. The task X1.1.3 The task group defined products on the market at the
group was similar to other F15 task groups developing con- time of its initial meeting (in 1982) as “gates” (mesh-type/
sumer product safety performance standards for juvenile prod- pressure-mounted gates and accordion-style gates). At that
ucts, having representatives from the Consumer Product Safety meeting, the group identified the hazards to be addressed as:
Commission, the Juvenile Products Manufacturers Associa- injuries or deaths as a result of head entrapment and strangu-
tion, manufacturers, consumers, the Consumers Union, ASTM lation of children when their heads or necks were entrapped in
staff, and interested parties from the academic community. The the V-shaped and diamond-shaped openings on accordion-style
group based this rationale on notes taken during its meetings, gates; and injuries or deaths as a result of the tendency of
as well as the minutes of those meetings. children to climb up and over gates. The task group based its
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identification of hazards of CPSC documents (a briefing stating “. . . up to 24 months” would better describe the intent
package to CPSC commissioners from the product identifica- to exclude the 24th month. The actual effect with respect to this
tion team of CPSC staff). The CPSC commissioners decided consumer safety specification is the same regardless of the
that if a safety standard were developed it should address these wording used. It was stated that anthropometric data are
hazards and not merely be a “hang-tag” and, that it should viewed in terms of a three-month range, for example, one that
address foreseeable misuse, as well as include a better system includes the 23rd through the 25th month.
of marking the product. The task group also decided to look at X1.2.3.4 The task group discussed whether corrals are play
known hazards in products being marketed currently, rather yards and whether they should be addressed in this consumer
than look at the hazards resulting from old products. safety specification or in Consumer Safety Specification F 406.
X1.1.4 The task group, thus approved unanimously the Because both products serve to confine the child, the task
following: that the task group develop a standard; that “corrals” group questioned whether corrals should therefore be consid-
(expandable enclosures) be addressed in this specification ered for exclusion from the play yard standard. The task group
rather than in Consumer Safety Specification F 406; and, that concluded that this was not necessary. While some manufac-
this product is meant for children and not for pets. turers refer to their products as “play fences” or similar names,
X1.1.5 The subject of corrals developed outside the task no manufacturer actually calls it a “play yard” or “playpen”,
group, namely on the basis of discussions between the manu- nor does any manufacturer recommend it as a play yard. There
facturers and the CPSC. This discussion resulted in a voluntary is a large degree of conflict in the design of a corral versus the
suspension of the manufacturing of corrals in September 1982. design of a play yard. Beyond the above considerations the
(Corrals, however, are addressed with this consumer safety definition if 3.1.4 is self-explanatory. All other definitions in
specification under the category of expandable enclosures.) the scope are considered self-explanatory.
X1.2.4 General Requirements:
X1.2 Discussion of Items in This Consumer Safety Speci-
fication: X1.2.4.1 The wording in 5.1 does reflect that major com-
ponents of this product are wood, rigid, or semirigid plastics,
X1.2.1 Title—The title of this consumer safety specification although all-metal gates also exist.
evolved from the original title and appears more descriptive of
X1.2.4.2 The requirements in 5.2 was suggested by the
the product as it now reads.
CPSC. It was based on information they obtained suggesting
X1.2.2 Introduction—The hazards itemized in the introduc-
that such locking or attaching devices, which shall be removed
tion to this consumer safety specification are based on data
during the product’s operation (or daily operation) could be
provided by CPSC. The scenarios of head and neck entrapment
encountered in the market place. The wording “daily opera-
were suggested as follows: the child may climb the gate and
tion” was thought to be a necessary statement to differentiate it
slip or manages otherwise to get the head at the neck or the
from the actual assembly or original mounting of the product.
neck into the V-shaped opening at the top of the gate or
The term “screws or of a similar nature” reflect the concern that
enclosure, and the child may get his or her head or neck into
use of “sheet metal screws,” for example, could be a substitute
the diamond-shaped opening of the body of the gate or
for wood screws should the specification be restrictive of wood
enclosure. Additional accidents result from design enabling
screws only. Refastening an important component of the
children to climb over or under the gate or enclosure or from
product with the same wood screws initially used is not
other interactions with the product.
recommended. Unless wood screws of a larger size are used,
X1.2.3 Scope:
the refastening may be inadequate. (This requirement origi-
X1.2.3.1 Young Children—The group felt it had to use the
nally was part of the performance requirements section and
adjective “young,” since the product is meant for the age group
was moved to this general requirements section.)
from 6 months to 24 months. (Whereas, by legal definition
other age groups are considered “children.” BS 41254 states the X1.2.4.3 The requirement in 5.6 aims to prevent finger and
adjective “young,” as well.) toe entrapment. This requirement addresses accessible holes,
X1.2.3.2 Six Months Age Group—Six months was chosen slots, or cracks in gates or expandable enclosures intended for
using as rationale information about motor skills and anthro- children 6–24 months of age. These dimensional requirements
pometric data. Children begin to sit unassisted at this age and are standard for many juvenile products. This subcommittee is
do not require this product at a younger age. The upper limit of not aware of incident data that would support a change to these
24 months is the same as stated in BS 4125. Consideration was dimensions.
given to anthropometric data for 24-month-old children as X1.2.4.4 Warnings are required to be permanent since they
well. Children over 24 months may be too tall, too heavy, and contain essential safety information, which should remain with
too strong to be effectively retained by these products. the product.
X1.2.3.3 The task group felt that the consumer could X1.2.4.5 Non paper labels fall with the scope of 16 CFR
misinterpret some labels that give the upper age limit. The 1501, therefore, they must not liberate small parts. Nonpaper
group felt that a label stating “ . . . through 24 months” or “. . labels that tear upon removal are considered labels that may
. to 24 months,” could be interpreted by the consumer as liberate a small part. Paper and fabric labels, other than paper
inclusive of the 24th month; whereas, it felt that wording and fabric warning labels, are not required to be permanent
since paper and fabric are exempt from the requirements of 16
CFR 1501. There is no choking incident data associated with
4
BS4125 paper and fabric labels.
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X1.2.5 Performance Requirements: test load in essence should stimulate the effects of the child’s
X1.2.5.1 For further explanation of 6.1, see Small Torso weight and the resultant forces that could dislodge a gate or
Template A in 7.3. enclosure.
X1.2.5.2 The height of 22 in. (560 mm) stated in 6.1.2 was X1.2.6.3 Small Torso Template A, referred to in 7.3, was
judged to be approximately the proper height to retain a child modified in 2000 to address incidents of children passing
of the specified age group. During the early stages of the through gate openings feet first and becoming entrapped by the
development of this consumer safety specification, the maxi- head.
mum child age of 30 months corresponding to a maximum X1.2.6.4 For all practical purposes, this template is two-
child height of 34 in. was considered. This was later changed dimensional, although the text accompanying the drawing
to a maximum child age of 24 months. According to a notes a minimum thickness of 1⁄8 in. (3.18 mm). This dimen-
statement by a member of Committee F15, the height of the sion merely provides adequate rigidity to the template.
sides of gate should be about 3⁄4 (or 80 %) of the height of the X1.2.6.5 The dimensions of Test Template B are supported
maximum age child. by the rationale contained in a CPSC memo drafted in 1985.
X1.2.5.3 The explanation of 6.1.5 as stated in 3.1.9 defines This template has evolved from earlier templates of similar
the term “partially-bounded opening.” The dimensions for the shapes and dimensions. As it now measures, it should address
templates and the procedure were suggested by the CPSC, and head/neck entrapment in V-shaped or diamond-shaped open-
Fig. 3 shows the use of the template with respect to its ings as its primary function. Appendix X2 is the text of that
orientation when applied to the product. memo.
X1.2.6 Test Methods: X1.2.6.6 Push-out testing of pressure-gates has been added
X1.2.6.1 The 45-lbf (200-N) static vertical force in 7.1.1 to the specification to address incidents of gates pushing out of
represents a minimum force requirement. This force was openings. Installation force is specified, and readings are
considered by the task group to be somewhat greater than a averaged to achieve consistency in test results. The test method
force or load that can be applied by a child of maximum user was evaluated in round robin testing. The 30-lb limit was
age. determined based on European standards, and limited child
X1.2.6.2 The basic intent of 7.1.1 and 7.1.2 is to test for strength data. It is also consistent with CPSC
safety from possible dislodgment of the gate or enclosure. The recommendations.
This memorandum responds to your request for assistance in voluntary standard (September 19, 1984) states that these
developing recommendations for a new template to address products are intended to restrain children from 6 to 24 months
head entrapment in “V” shapes along the top edges of the of age. There have been 43 head entrapment incidents in both
subject products. gates and enclosures which involved children between 9
In order to design a new template, the ages of the intended months and 31 months of age (see Fig. X2.1 and Fig. X2.2).
users of the product must first be identified. The latest draft The five victims, 24 months of age and over, were reported to
11
F 1004 – 02a
be: a child approximately 1-1⁄2 to 2 years of age;5 a 24-month- generally can be trusted alone on stairs;11 thus, we believe that
old;6 a 25-month-old;7 a 27-month-old child who stopped the 6– to 24-month intended age, as proposed by the voluntary
using an enclosure at 18 months of age but who was attempting standard, is adequate.
to climb over the product to visit an infant inside the enclo- In order for a template to address head/neck entrapment in
sure;8 and a 31-month-old child with Down’s Syndrome,9 a “V” shapes, it must screen out nonhazardous openings with
type of mental retardation;10 therefore, all the victims, 24 angles that are either too narrow to admit the smallest user’s
months of age and over, for whom the product was being used, neck, or too wide to entrap the largest user’s head.
were close to 24 months of age, except the child with impaired The neck breadth of the smallest user (a 5th percentile
capabilities. In addition, the products in question are not 6-month-old) is 2.0 in.12 Approximately 25 % of this figure
needed much beyond 24 months of age since a 24-month-old should be subtracted to allow for tissue compression; therefore,
openings less than 1.5 in. in width would not admit a child’s
neck.
5
In-depth Investigation (IDI) #800507CEP0807; Consumer Complaint
The head size of the largest user (a 95th percentile 24-month
#CC40496. old) has several components including head height, which is
6
IDI #821206HIA2061.
7
Death Certificate #541003882.
8 11
IDI #811006SF00001. Caplan, Frank, The Second Twelve Months of Life, p. 300.
9 12
IDI #840327CBC3136. Data Cell 4–6 Months, December 4, 1984, University of Michigan, “Prelimi-
10
Dorland’s Illustrated Medical Dictionary, 24th Edition, pp. 447 and 938. nary Report on Manual Measurement Results.”
12
F 1004 – 02a
7.0 in., head breadth, which is 5.6 in., and angle under chin and angle.15 The marks left on the back of each jaw indicates that
jaw, a dimension which is unavailable at this time;13 however, the child’s arm was not a factor in this case. This incident
the angles of the “V”s and diamonds in which head entrapment supports our original recommendation that openings with
occurred are known for some incidents. Two of these incidents angles less than approximately 75° may entrap a child’s head.
occurred in openings having angles greater than 70°, the angle Therefore, a template to address head entrapment in “V”
referred in the latest draft voluntary standard. One of the shapes should combine the smallest user’s neck breadth with
incidents occurred in a diamond shaped opening with a 77° the largest user’s head height, head breadth, and with an angle
angle when the child was reaching for a toy on the other side larger than the largest angle of a “V” or diamond which has
of the gate.14 While the information in the in-depth investiga-
entrapped a child’s head. Fig. X2.3 is our recommended
tion is unclear, we believe that the child may have had his head,
template for addressing head entrapment in “V”s which com-
neck, and arm through the opening. The other incident was a
bines the dimensions stated above. Fig. X2.4 illustrates some
death that occurred in a diamond shaped opening with a 71°
examples of “passes” and “failures” using the template.
13
Data Cell 19–24 Months, December 4, 1984, University of Michigan,
“Preliminary Report on Manual Measurement Results.”
14 15
IDI #790516CEP0817. IDI #841017WES0012.
13
F 1004 – 02a
FIG. X2.4 Examples of Passes and Failures to the Suggested Requirement for Configuration of Uppermost Edge Using Test Template B
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14