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Increasing the height of guardrails may help prevent children from falling from the bed. Toddler bed producers must compete with producers of twin (or possibly larger) beds that can be used with portable guardrails, while convertible cribs must compete with these same products for larger children and with standard cribs for smaller children. The remaining requirements, entrapment and strangulation warnings, are expected to have only a minimal impact on current suppliers of toddler beds or convertible cribs. To the extent that some of these firms may actually comply with the current voluntary standard or one or more of the new/modified requirements in the proposed standard, the impact of the proposed rule would be lower. At least some of these firms should not need to make any product modifications (other than labeling) to meet the proposed standard. Therefore, we believe that some products will need to be modified to meet the slat/spindle requirement, which is likely to affect at least a few firms.

Therefore, the Commission invites comments from small businesses affected by this proposal explaining the economic impact it will impose on them. For the most part, the impact of the proposed rule on importers should be smaller than that on manufacturers. Other Federal Rules. CPSC staff has not identified any federal or state rule that either overlaps or conflicts with the staff's draft proposed rule. The smallest state is Rhode Island and the largest state is Alaska. Hence, the use of the term Cell Delay Variation tolerance (CDVt) for this parameter in ATM. Use what you need and, if and when you want, learn the rest. And, one of the best places to find affordable leggings and yoga pants is Amazon - you can even find super affordable styles for spring that match the ever-popular lululemon! You may mix and match styles HLW001, tote bags Dubai HLW002 and HLW004. There are many styles available that vary by fit, material and extra features. For wooden toddler beds and convertible cribs, switching to a stronger material is unlikely to exceed more than a few dollars per unit.

Metal toddler beds/convertible cribs are less common than products made from wood or plastic, but material changes should not be substantially more expensive than for wooden products. CPSC staff has identified many cases where products not certified by JPMA actually comply with the relevant ASTM standard; however, there is insufficient evidence of this for toddler beds and convertible cribs to quantify this impact. It is also possible, however, that they may be able to select a potentially less expensive option to address some of the recommended requirements. However, it would be unreasonable to assume that all of the firms whose products may require modifications can or will take this approach. However, there is insufficient information to quantify this effect. Additionally, the effect of the new and modified requirements may be less substantial than outlined above to the extent that some products may already comply with foreign standards with some more rigorous requirements. The scenario described above assumes that only those firms that are JPMA-certified or claim ASTM compliance will pass the voluntary standard's requirements. These firms would likely have to undergo product redevelopment.

Producing toddler beds and convertible cribs that have greater structural integrity, stronger slats/spindles, and higher guardrails may require additional raw materials or possibly heavier materials. There are 73 firms currently known to be marketing toddler beds and/or convertible cribs in the United States. As discussed above, the proposed rule would not require guardrails to be included with toddler beds or convertible cribs, so firms with noncompliant products have the option of eliminating guardrails entirely if their products will comply with the other requirements of the proposed standard with the guardrails removed. It is possible for firms to eliminate guardrails from their products entirely as a way to address the proposed guardrails requirements if they can comply with the other requirements of the proposed standard without the guardrail in place (guardrails themselves are not required). The remaining firms may opt to redesign their products as well, which, again, would result in some one-time costs and a possible increase in production costs. Suppliers may also need to make product modifications to meet the revised structural integrity requirement and new height requirement for guardrails.