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Monday May 11, 2020

Comments on Folding Chairs Are Unlikely to Derail CPSC Rule

Comments on CPSC's Section 104 rulemaking on children's folding chairs were mostly mixed, short, and vague. There were just five. It is doubtful that any would be considered significantly adverse. Thus, this direct final rule likely will become effective July 6 (PSL, 3/30/20).


The lengthiest input came from the New Civil Liberties Alliance, a group that now regularly protests rules that incorporate voluntary standards, saying the practice raises a paywall in front of information needed to comply.


The rest were anonymous and curt, but all were on topic:

  • One agreed with the action, worrying about harm "if [the chairs] aren't built with the proper safety precautions."

  • Another doubted if much danger exists but nonetheless commented, "If this regulation will prove to somehow remove a risk or danger that already exists, I am all for it. Better safe than sorry I guess."

  • A third agreed with the rulemaking but added, "I…would like to voice my concern over the safety of a folding chair with rocking capabilities."

  • The final commenter stated simply, "If you need a policy on folding chairs you are mental."

In this action, CPSC would update its rules at 16 CFR 1232 with recent revisions in ASTM F2613-19 on children's folding chairs. The substantive changes would address adequate clearance to avoid crushing/laceration/pinch risks in products without latching or locking devices. Gaps would need to be either smaller than 3/16 inches or larger than 1/2.


This is a direct final rule because CPSC already had incorporated the standard. The current rule dates to 2017.