Section 104(b) of the Consumer Product Safety Improvement Act of 2008 (CPSIA) requires the Commission to promulgate consumer product safety standards for durable infant or toddler products. These standards are to be “substantially the same as” applicable voluntary standards or more stringent than the voluntary standards if the Commission concludes that more stringent requirements would further reduce the risk of injury associated with the product.

In the Notice of Proposed Rulemaking, the Commission proposes safety standards for carriages and strollers which are based on the voluntary standard developed by ASTM International, but with additions and modifications that strengthen the standard. Our comments support the strengthening additions and modifications and also include other changes to include in the standard.