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AHFA, Product Safety

Proposed Rule Presents Testing Challenges

Members of AHFA’s Furniture Safety Task Group shipped multiple clothing storage units to the GTCC Conference Center near High Point, N.C., in September for a live demonstration of a new testing protocol proposed by the U.S. Consumer Product Safety Commission (CPSC).

The demonstration was a key feature of the 2021 Sustainability & Regulatory Summit program held September 1-2.

AHFA and members of the Task Group have conducted painstaking analysis of CPSC’s Notice of Proposed Rulemaking for Clothing Storage Units since the document was released in July. Issues identified by the work – and demonstrated during the September Summit – include:

  • The two test methods prescribed by the rule can produce different results on the same unit.

  • The test methods require extremely precise measurements, in particular identifying the “tip-over moment,” yet this calculation relies on the perception of the person doing the testing.

  • This variability could result in a manufacturer certifying that a unit is compliant and the CPSC asserting the product is non-compliant. In short, AHFA has concluded, the proposed testing protocol may be unenforceable.

A video of the testing demonstration is posted on the Education page of AHFA’s website, under 2021 Summit. A member log-in is required to access the Summit presentations, including the testing demonstration video.

AHFA’s Furniture Safety Task Group also has created an interactive workbook to assist members in calculating the “tip-over moment” of units covered by the proposed rule. The workbook outlines the necessary measurements, then automatically calculates the “tip-over moment” and the unit’s resulting “stability rating.” The workbook, like the demonstration video, is available only to AHFA member companies.