We've been looking into the drop-side crib ban ASTM put on the table a couple of days ago. Although not a legal restriction per se, the move would effectively eliminate drop-side cribs - those designed to allow one side of a crib to slide down to provide easier access - from the U.S. market.

While it's hard not to defer to the collective wisdom of a body as representative and broad-based as ASTM, it's also hard not to think there's some strange politicking going on here.

ASTM is the key voluntary standard-making body for consumer products, and that's just one slice of what their standards encompass - most of their standard-making is done at the materials level (paint, adhesives, pipes), by hundreds of technical committees and a total membership of more than 30,000. Their consumer products division, F15, includes some consumer and trade group representatives, but is mostly comprised of retailers and manufacturers.

ASTM has a better mix of people and agendas than an organization like the JPMA (Juvenile Products Manufacturing Association) which takes anti-regulatory positions you can spot from a mile off; ASTM standards generally arise after some healthy debate among competing interests, and even the Consumer Product Safety Commission (CPSC) has seats on these committees.

Those debates, however, can be interminable, and that's what appears to have happened within F15.18, the Subcommittee on Cribs, Toddler Beds, Play Yards, Bassinets, Cradles and Changing Tables. The CPSC has done some in-depth investigation and tracking of crib-related injuries and deaths in the last several years, and the agency has been pushing this subcommittee to improve crib standards since at least 2002, specifically in two areas: Crib slat strength and drop side designs. As late as October 2007, the CPSC was urging the subcommittee to expedite the process of revising these standards.

In a letter from the CPSC to its chair, Child Craft Industries' William Suvak, on October 11, 2007, the CPSC wrote:

CPSC continues to receive incident reports relating to crib hardware. Many of these incidents pertain to drop side hardware. Based on the structural design differences between a crib with a drop side and one without it, incident reports and evaluation of incident samples indicate that drop sided cribs are more prone to hardware problems that may lead to potential hazards. Compounding the issue is that many consumers do not realize the potentially deadly hazards associated with a crib with broken or missing hardware.

Improving the ASTM standard to address hardware issues would be a significant effort towards the goal of reducing crib-related deaths and incidents. The subcommittee should consider looking at avenues that would eliminate the use of plastic hardware on any movable component of a crib (drop sides and mattress support systems). Additionally, CPSC staff encourages the subcommittee to explore ways to amend the standard in order to significantly reduce the number of movable components of a crib.

To summarize, what the CPSC appears to have asked for repeatedly during this period was:

• Stricter requirements for the strength of wood used in cribs;


• better instructions, labeling, and/or design changes to prevent improper assembly; and


• the elimination of plastic drop side crib hardware in favor of all-metal parts.

In late 2008, the CPSC issued an Advanced Notice of Proposed Rulemaking, which is a shot across the bow as far as industry is concerned. So the new offering from ASTM should be understood for what it is - a counter-offer to the CPSC's threat of imposing new regulations from their own offices.

But the proposal of an outright elimination of drop-side cribs from ASTM standards - essentially saying that no drop-side crib design can meet a reputable safety standard - has us scratching our heads. There seem to be some unanswered questions in the dance ASTM and the CPSC are doing on this issue.

Is the problem some inherent flaw in drop side designs generally, as the ASTM's move implies, or cheap drop sides with plastic hardware, as the CPSC's letters suggest?

If the issue is one of quality, what does it say about the members of the ASTM F15.18 committee - which likely includes representatives from every company with an interest in infant cribs, i.e. everyone who makes them - that they would prefer an outright ban on the design than mandated quality improvements?

What sort of benefits might accrue to manufacturers who rely on the low end of the market to ban designs that can only be produced well at a higher cost? In other words, if higher standards for drop sides required more expensive parts and better design, would manufacturers who relied on a high volume of cheap cribs be put at a competitive disadvantage? Could these manufacturers, voting as a bloc, make a tactical decision to eliminate this portion of the market rather than abandon it to their higher-quality competitors?

One more thing: The current climate of fear surrounding the CPSC's ability to bring the hammer down on thrift stores and resellers for selling products they "should know" are unsafe means that the new ASTM standard's passage will result in the majority of U.S. cribs suddenly, without recall or even demonstrated hazard, becoming non-reusable commodities.

All of this would be less frustrating if it weren't for the fact that a lot of people rely on drop-side cribs' convenience - namely, short parents, older parents, and anyone with a bad back. Hinged sides are being floated as a viable alternative. But given the benefits of drop-side cribs and the clear suggestions the CPSC had previously provided for improving the safety of these cribs, it seems likely that there is some maneuvering going on here that is not simply about providing consumers the widest variety of safe products possible.

We've always loved the look of P'kolino's line of children's furniture, but never their prices. Their Book Buggee, a cute toy and book wagon for toddlers, is on sale on Amazon for almost 40% off the standard retail - selling on Amazon for $24.14, down from the $38.50 P'kolino charges when they sell direct. (Don't be fooled by the "$44.90" list price on Amazon.) So we're looking again, and thinking about how cute it is, and trying to overlook the fact that it's made of fiberboard with a wood veneer. And then we notice that this thing is about the size of a piece of paper, with a 7.5" x 13.5" bellyprint, and standing 7.5" tall. Is that small?

It has been a while since we had a two-year-old, and Z has always been big. So I ask you - have any of you purchased this cute thing, and can you tell us if it is a reasonable size for a one-year-old, two-year-old, three-year-old child?

If your child has a different toy cart, do me a favor - grab a standard piece of paper and tell me if theirs is bigger or smaller than said paper, and if you think it's a good size for your child.

As for the deal, though, it's a hard one to beat. $24.14 means you can throw a book in there and get free shipping. And we all know how cheap great kids' books can be. (Need some suggestions? Browse the comments of our ongoing LeapFrog Tag giveaway - we've had several dozen great suggestions so far, and have them all linked up to Amazon.)


P'kolino's gorgeous (and cleverly compact) Klick Desk is also on sale: ~$142 if you like the orange, or ~$148 if you'd rather red. The handsome green option is still selling at full list price, $198.50.