"To Pali, June 28 will not represent anything major since we have worked hard over the past eight months to prepare for the new regulations. In the last months we also effectively collaborated with our specialty store dealers in order to update the Pali products on their sales floors. This will enable everybody to be ready for the upcoming market requirements with total peace of mind." 

"JPMA continues to support practical decisions and application of standards so as not to unduly burden our members' retailer customers and consumers. As such, our biggest concern is the adoption of a reasonable enforcement policy by the CPSC once the new crib regulation becomes effective at the end of June.
As an example, JPMA is aware that many cribs have passed the ASTM F1169-09 standard, which included requirements eliminating traditional drop-sides and included a slat integrity test to the requirement of the European standard. These cribs may have no issue with passing the current CFR except for some locking screws and instructions. The issue is that many have been discontinued and are of a small quantity per style as to preclude doing additional testing. While locking washers can be sent to the retailers and these washers have been used on other cribs, with the same hardware, that have passed the new CFR, the actual crib would not have been tested by small retailers. These cribs have had their slats tested to the European standard of 56.2 lbs for 30 seconds. The new CFR test is 80 lbs for 10 seconds. Both of these tests are a robust test of a single slat or spindle. So, many manufacturers are confident a slat passing the 56.2 should be deemed a safe crib as a matter of enforcement discretion by the CPSC.
So far, we are not aware that any crib passing the '09 standard has been involved with any inherent slat breakage incident, unrelated to unreasonable misuse of the product. Both tests also have a mattress support test.
In conclusion, it is JPMA's position that a crib tested to the '09 standard is a robust safe crib that should not be deemed non-compliant, simply because it does not contain lock washers and has not been tested to the new standard. In addition there are many non-drop-side cribs that are of a substantial construction that are several years old that have slats of a very robust nature that have not been tested to the '09 standard that in all likelihood would easily pass the CFR standard except for warnings, instructions and lock washers.
Again, many of these have been discontinued by the manufacturers and are of a small quantity per style as to preclude testing due to the economics. All of these facts suggest that a reasonable enforcement policy by the CPSC that allows non-drop-side cribs that have been tested and found compliant with F1169-09 (or the later versions F1169-10 and F1169-10a) should be allowed to be sold through so as not to negatively impact the retail community and leave them with perfectly safe, yet unsellable cribs, in their inventory." 

"We have only one crib left on our floor to sell off, but we are still waiting for some of the manufactures to send us their compliance kit, such as the washers and new labels. We expect to have them by June 10, 2011.
I am not sure that I will be celebrating quite yet; this has been very costly for us.
We had to replace 70% of our floor; that meant discounting all of the floor samples and reordering new inventory. It was a challenge making sure that all new products being shipped are compliant and arrived on time so that our showrooms did not look bare. The other challenge was selling complaint product at regular price, while everyone is selling off their non-complaint product at a discount. I am looking forward to June 28.
I, as a business owner, am lucky to be part of Baby Furniture Plus Assn.; our administrator has kept us informed throughout this process. I feel that our store provides a safer product for our customer." 

"We are clearing out all cribs at a 40% discount hoping to sell all of them; if necessary we will go below cost just to unload. It has been an expensive change over.
We will mark the day with relief when the last crib sells! Our customers have been a bit confused and second guessing their crib purchases, so it has required our expertise and reassurance to put them at ease.
We are feeling it is still a grey area and being treated like a ‘running change.' The law is really up to interpretation and it has been unclear about whether you can retrofit or not." 

"We've already prepared all of our inventory in April, by shutting down our production to focus on opening any necessary boxes and retrofitting our cribs in house, and we've been shipping cribs meeting the new standards since May 1st. All necessary documentation for our retailers was sent out to them in April, so we feel pretty prepared for the June 28 date.
How will we mark the day? We will be looking forward to the next election day, when we can vote out everyone that has put this strain on the industry." 

"We as an organization have been very active both in trying to keep our members informed and in expressing our frustration with the CPSC on enforcement issues.
NINFRA has sent me to the last two ASTM/JPMA meetings regarding crib regulations, and I have taken that knowledge and brought it back to our membership.
Spearheaded by Jim Vieira of Baby Boudoir in New Bedford, Mass., we started a letter-writing campaign to senators, congressmen and the CPSC to explain the position we have as independent retailers with the same deadline for compliance as our suppliers, which gives us no opportunity to sell through. We also explained that there is so much ambiguity that no one is really sure what the rules are. And with the tremendous effect that this will have on independent retailers economically, we've asked for a 180-day extension of enforcement for retailers to let them sell through the product.
We've also been working with Neal Cohen, the CPSC small business ombudsman, who told us that the CPSC would like input from specialty retailers. We came up with a survey that we shared with the other buying groups, and sent the results to Neal Cohen to show him through the data just how much ambiguity there is.
Jim Viera has been instrumental in this - we're lucky he's a NINFRA retailer." 

"At Baby Furniture Plus Assn., we have been diligently working towards the June 28 date since last October. I have been in constant contact with Mike Dwyer at JPMA, who has been a beneficial partner in steering us in the right direction as things developed and changed.
Our goal was for our membership to not be panicking at the last minute. We worked as a group to share and provide information to each other. Our members understood the severity of this change and most of them began transitioning their floors and working with their manufacturers months ago. Although there are some who have procrastinated on this issue, I believe most stores in our group have been on top of this for some time.
There are still some outstanding issues and questions, most seem to be stores waiting for labels, some retrofit kits and compliance certificates. I would say most feel they have done everything they can do at this point and are working to make sure they have converted cribs that can be retrofitted (this is a very time consuming process).
It has been a challenging and costly period for both manufacturers and retailers. Now, stores who have transitioned and are at regular price with compliant product are feeling the pain of lost business due to retailers across the United States discounting soon to be non-compliant product (especially on the internet) to move through it prior to the cutoff date. In this already tough economy, this last month till we get to the June 28 date is crushing many of these stores. We look forward to getting over the June 28 hurdle, so business in the furniture category can possibly stabilize.
My guess is there will be no celebrations and not even a sigh of relief. Stores are all questioning if after the date the CPSC will pay them a visit, and what will they be asking for if they do come knocking? Just one more thing for them to worry about in this already unstable retail environment." 

"We have for the months of April and May been asking our vendors not to ship any cribs to us that are not compliant with the stipulations of the June 28 deadline. We have for many months been selling off inventory that is not compliant, and have requested from our vendors compliance kits and letters of conformity for the floor samples we have yet to sell off.
What will actually happen on June 29 as far as enforcement of the new standards is anybody's guess. I have been very proactive in making my store compliant, so when June 29 comes around I will be prepared. I figure, if I made it through ‘May 21', I can make through June 28. Of course there is still the Mayan doomsday of 2012, but I'll concentrate on one thing at a time." 

"We are upfitting on-hand inventory, labeling new production and upfitted inventory with special ‘OK to sell' stickers, separating stock as we go, answering questions from retailers and demonstrating our compliance, offering support to retailers who are clearly stressed, and cringing at news reports that seemed designed to panic rather than educate consumers.
     How will we mark the day? It doesn't seem worthy of a celebration or a promotion. Maybe a quick email to our sales reps/office with some history to remember what all the fuss is about. Infant fatalities/injuries are uncomfortable to talk about but the whole reason behind the CPSC changes.
     I don't have questions about what the changes mean for us as a company. But I do wonder what happens to all the cribs in consumers' homes (and retail stock) that isn't compliant June 29. The resellers won't be able to take used cribs any longer. Do they all end up in landfills? Even new ones currently in boxes that are legal to sell today?! Are they donated June 27 to non-profits? There hasn't been much chatter about this issue."