Bunk Bed Certification Now Required by Law.

AS OF JUNE 19, 2000, all bunk beds manufactured in the United States or imported for sale in the United States must be certified in accordance with a standard developed by the the Consumer Product Safety Commission.

Among other things, the standard -- referenced as 16 CFR 1213 -- requires bunk beds to meet performance standards and to bear cautionary labeling. The purpose of the performance standard is to prevent the unreasonable risk of injury and death from children becoming entrapped in the bed's structure or wedged between the bed and the wall.

The impetus for the standard was the alarming statistics involving children being injured or inadvertently entrapped or hung in bunk bed-related incidents. For example, from 1973 through 1990, the CPSC received reports of more than 70 deaths of children under 15 years of age involving bunk beds. Seventeen deaths involved children who became entrapped between the mattress and the guardrail, five involved children who became entrapped either between the mattress and bed structure or in the bed-end structure, and 16 deaths involved young children who reportedly became entrapped between the bed and wall. Falls from upper bunk beds accounted for 19 deaths, mattress support failure caused four deaths and 10 were due to other or unknown causes.

More recent data compiled by the CPSC concludes that between 1990 and 1999 there were 91 bunk bed-related fatalities, 59 of which resulted from entrapment. It is estimated that 10 bunk bed entrapment deaths have occurred in the United States every year since 1990.

Performance Testing

In addition to CPSC's standard, there is a voluntary standard, ASTM F 1427-96, that addresses additional hazards such as foundation and guardrail structural integrity. The CPSC has indicated that it will consider the ASTM standard when investigating whether a bunk bed represents a substantial risk of injury to children that may require some type of corrective action.

Performance testing can be done by several testing laboratories. However, as a government agency, the CPSC does not endorse, certify or approve testing laboratories or specific product designs. However, the CPSC does maintain a list of laboratories on its Web site, www.cpsc.gov, which have advised CPSC that they can perform testing.

One such laboratory is Detroit Testing Laboratory Inc. This article details the procedures DTL uses in its Bunk Bed Certification Program, which is open to all bunk bed manufacturers and to firms that market private-brand models.

The purpose of Detroit Testing Laboratory's Bunk Bed Certification Program is to assure consumers, by the presence of a certification seal and listing in a directory, that the product bearing the seal is in compliance with the requirements of the current ASTM F 1427-96 standard, 16 CFR Part 1213 and Detroit Testing Laboratory's Bunk Bed Certification Program Procedural Guide.

Under terms of DTL's program, manufacturers are required to perform tests for compliance to the three standards on a periodic basis and report the results to Detroit Testing Laboratory for review.

ASTM's Standard

The ASTM voluntary safety standard addresses many of the entrapment issues by requiring that bunk beds have a guardrail on each side of the upper bunk. The guardrail openings should not allow the passage of a 3 1/2-inch x 6.2-inch edge block, representing a child's torso, when a load of 33 pounds is applied for one minute.

Bed ends of the upper bunk should have no openings that are greater than 3 1/2 inches and that allow passage of the wedge block in any and all configurations.

The spacing of slats in the mattress support system should be either less than 3 1/2 inches or greater than 9 inches.

The ASTM standard also addresses other issues, such as attachment methods of the side rails, guardrails and ladder, as well as height requirements for guardrails and bed-end structures of the upper bunk.

Labeling and instructions literature is also a safety standard inclusion, as are loading requirements of the mattress support system and side rails.

Additional revisions to the ASTM standard in 1994 and 1996 include requirements to address collapse of metal tube bunk beds and requirements for openings in the bed ends of the lower bunk.

Despite voluntary efforts, CPSC has recalled more than 500,000 bunk beds in the past four years that did not meet the entrapment requirements in the ASTM standard. These recalls helped reinforce the need for a mandatory standard.

The CPSC's Standard

The entrapment requirements of the CPSC's mandatory bunk bed safety standard are identical to the ASTM standard, with the following exceptions:

* The definition of a bunk bed was changed to include beds in which the underside of the foundation is more than 30 inches, as opposed to 35 inches.

* At least one of the required guardrails must be continuous between bed ends. The other guardrail may terminate before reaching either bed end, provided there is not more than 15 inches between either end of the guardrail and the nearest bed-end structure.

* Openings in the entire lower bunk-end structures must now be less than 3 1/2 inches or greater than 9 inches. Openings greater than 9 inches are also subject to neck entrapment requirements utilizing a neck entrapment probe.

The Consumer Product Safety Council's standard is contained in the Code of Federal Regulations, 16 CFR Part 1213, and Parts 1500 and 1513. The standard can be downloaded from the CPSC's Web site at www.cpsc.gov.

Mandated Marking, Labeling and Instructions for Bunk Beds

AS REQUIRED by the Consumer Product Safety Commission's Safety Standard for Entrapment Hazards in Bunk Beds, the following instructions, markings and labels are now required, effective June 19, 2000, on all bunk beds sold in the United States.

Marking. There must be a permanent label or marking on each bed stating the name and address (city, state and zip code) of the manufacturer, distributor or retailer; model number and the month and year of manufacture.

Labeling. A warning label, similar to the one seen here, must be permanently attached to the inside of an upper bed-end structure in a location that cannot be covered by the bedding, but that may be covered by the placement of a pillow.

Instructions. Instructions must accompany each bunk bed set and must include the following information:

Size of mattress and foundation. The length and width of the intended mattress and foundation shall be clearly stated, either numerically or in conventional terms, such as twin size, twin extra-long, etc. In addition, the maximum thickness of the mattress and foundation required for compliance with the standard must be stated.

Safety warnings. The instruction must provide the following safety warnings:

* Do not allow children under six years of age to use the upper bunk.

* Use guardrails on both sides of the upper bunk.

* Prohibit horseplay on or under the beds.

* Prohibit more than one person on upper bunk.

* Use a ladder for entering or leaving upper bunk.

* If the bunk bed will be placed next to a wall, the guardrail that runs the full length of the bed should be placed against the wall to prevent entrapment between the bed and the wall. (This applies only to bunk beds without two full-length guardrails.)

WARNING

To help prevent serious or fatal injuries from entrapment or falls:

* Never allow a child under 6 years on upper bunk

* Use only a mattress that is __ inches long and __ inches wide on upper bunk

* Ensure thickness of mattress and foundation combined does not exceed __ inches and that mattress surface is at least 5 inches below upper edge of guardrails.

DO NOT REMOVE THIS LABEL