National Center for Health Research’s Comment on Safety Gates and Enclosures for the Consumer Product Safety Commission

Dec 14, 2022

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We are writing to express our views on the Consumer Product Safety Commission’s (CPSC) adoption of a mandatory safety standard for gates and enclosures for children.

The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.

We support CPSC’s plan to revise section ASTM F1004-22 of the mandatory standards for safety gates and enclosures to include a specific warning about the installation of wall cups. We agree this should go into effect January 2023. Gates and enclosures serve a vital purpose to improve safety for children, but without proper installation they can be harmful. For example, gates and enclosures that use wall cups for mounting can break or unlatch if not installed properly. ¹ Faulty gates and enclosures can “give children access to restricted areas, such as stairs, resulting in fall hazards”. Gate-related injuries, such as falls, choking, and strangulations, cause one death in the US every year, and in 2016 caused 2,900 visits to the ER.¹

Improperly installed gates and enclosures present the greatest danger for children under the age two. At that age, children are more likely to be victims of these gates and enclosures collapsing, resulting in possibly life-threatening falls, compared to children over the age of two. ²

A mandatory warning label that specifically addresses these concerns will alert parents to the need for proper installation of these gates and enclosures to prevent injury and death of their children. We urge CPSC to go a step further by making this mandatory label also present on the outside packaging of gates and enclosures, rather than just warning in the instruction manual. A label on the external packaging is more likely to alert buyers to the possible dangers of improper gate and enclosure installation.

References:

1. Kids in Danger. Product Hazards- Baby Gates and Enclosures. https://kidsindanger.org/product-hazards/gates/#:~:text=At%20least%20nine%20children%20have,which%20were%20manufactured%20before%201985
2. Cheng YW, Fletcher EN, Roberts KJ, McKenzie LB. Baby gate-related injuries among children in the United States, 1990-2010. Acad Pediatr. 2014;14(3):256-261. doi:10.1016/j.acap.2013.12.006

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