Bunk Beds; Advance Notice of Proposed Rulemaking; Request for Comments and Information

CONSUMER PRODUCT SAFETY COMMISSION

16 CFR Chapter II

Bunk Beds; Advance Notice of Proposed Rulemaking; Request for

Comments and Information

AGENCY: Consumer Product Safety Commission.

ACTION: Advance notice of proposed rulemaking.

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SUMMARY: The Commission has reason to believe that unreasonable risks

of injury and death may be associated with bunk beds constructed so

that children can become entrapped in the beds' structure or become

wedged between the bed and a wall.

This advance notice of proposed rulemaking (``ANPR'') initiates a

rulemaking proceeding that could result in a rule mandating bunk bed

performance requirements to reduce this hazard. This rule could be

issued under either the Federal Hazardous Substances Act (``FHSA'') or

the Consumer Product Safety Act (``CPSA''), or separate rules might be

issued under the FHSA and CPSA addressing bunk beds intended for use by

children or adults, respectively.

The Commission solicits written comments from interested persons

concerning the risks of injury and death associated with bunk beds, the

regulatory alternatives discussed in this ANPR, other possible ways to

address these risks, and the economic impacts of the various regulatory

alternatives. The Commission also invites interested persons to submit

an existing standard, or a statement of intent to modify or develop a

voluntary standard, to address the risks of injury and death described

in this ANPR.

DATES: Written comments and submissions in response to this ANPR must

be received by the Commission by April 7, 1998.

ADDRESSES: Comments should be mailed, preferably in five copies, to the

Office of the Secretary, Consumer Product Safety Commission,

Washington, D.C. 20207-0001, or delivered to the Office of the

Secretary, Consumer Product Safety Commission, Room 502, 4330 East-West

Highway, Bethesda, Maryland; telephone (301) 504-0800. Comments also

may be filed by telefacsimile to (301) 504-0127 or by email to cpsc-

[email protected]. Comments should be captioned ``ANPR for Bunk Beds.''

1

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\1\ This ANPR was approved by a 2-1 vote of the Commission.

Chairman Ann Brown and Commissioner Thomas H. Moore voted to approve

this ANPR; Commissioner Mary S. Gall voted not to publish the ANPR.

[[Page 3281]]

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FOR FURTHER INFORMATION CONTACT: John Preston, Directorate for

Engineering Sciences, Consumer Product Safety Commission, Washington,

D.C. 20207; telephone (301) 504-0494, ext. 1315.

SUPPLEMENTARY INFORMATION:

A. Background; History of Voluntary Standards Activities

Bunk beds have been long recognized as a potential source of

serious injury to children. In 1978, an Inter-Industry Bunk Bed Safety

Task Group developed a Bunk Bed Safety Guideline for voluntary use by

manufacturers and retailers of bunk beds intended for home use. Members

of this group included the National Association of Bedding

Manufacturers, the National Association of Furniture Manufacturers, the

Southern Furniture Manufacturers Association, and the National Home

Furnishings Association. The guideline became effective on January 1,

1979.

In February 1981, an American National Standard for Bedding

Products and Components (ANSI Z357.1) was published. For the most part,

this standard contained dimensional requirements for mattresses and

foundations for all beds. However, it also incorporated the

requirements of the January 1, 1979, industry safety guideline for bunk

beds. In May 1986, the American Furniture Manufacturer's Association

(``AFMA'') published Voluntary Bunk Bed Safety Guidelines developed by

the Inter-Industry Bunk Bed Committee (``IIBBC'').

On August 26, 1986, the Consumer Federation of America (``CFA'')

filed a petition with CPSC requesting the promulgation of a mandatory

safety regulation for bunk beds. In its petition, CFA cited three

different risks of injury posed by bunk beds: Inadequate mattress

supports that can allow the mattress to fall to the bunk below or to

the floor, entrapment in the space between the guardrails and the

mattress, and entrapment between the bed and the wall. CFA alleged that

the voluntary industry guidelines did not fully address the hazards

posed to consumers.

In July 1988, AFMA published Revised Voluntary Bunk Bed Safety

Guidelines, with an effective date of April 1989. A majority of the

revisions were made as a result of CPSC staff comments on the May 1986

guidelines, which included comments that the requirements addressing

entrapment in openings in guardrails were not adequate and that bunk

beds should be required to be sold with two guardrails. To prevent

entrapment, the 1989 revised guidelines did require two guardrails to

accompany a bunk bed, and required that any opening in the structure of

the upper bunk be less than 3\1/2\ inches.

On July 21, 1988, the Commission voted to deny the petition filed

by the CFA, but directed its staff to prepare a letter to AFMA and

IIBBC urging that AFMA reconsider the CPSC staff comments that had not

been included in the Revised Voluntary Bunk Bed Safety Guidelines. That

letter was sent in August 1988. It also requested (a) that AFMA

consider additional staff recommendations, (b) that AFMA submit the

revised guidelines to a voluntary standards organization such as ANSI

or ASTM for development as a voluntary safety standard, and (c) that

AFMA develop, and provide to the Commission, a plan and proposed

implementation date for a certification program to ensure that bunk

beds complied with the guidelines. AFMA responded that a certification

program would be established upon publication of an ASTM bunk bed

standard.

In October 1992, ASTM published the Standard Consumer Safety

Specification for Bunk Beds, ASTM F1427-92, in response to the

Commission's August 1988 request. The performance requirements in that

standard primarily addressed falls from the upper bunk, entrapment in

the upper bunk structure or between the upper bunk and a wall, and

security of the foundation support system. The standard also had a

requirement for a warning label and for instructions to accompany the

bed. In June 1994, the ASTM bunk bed standard was republished with

additional provisions (requested by CPSC staff) to address collapse of

tubular metal bunk beds. The most current version of the ASTM bunk bed

standard was published in September 1996 and contains additional

revisions suggested by CPSC staff. These address entrapment in lower

bunk end structures; mattress size information on the warning label and

carton; and the name and address of the manufacturer, distributor, or

seller on the bed.

Because of continued reports of deaths and other incidents

associated with bunk beds, and because of indications that there is

inadequate compliance with the voluntary ASTM standard, the CPSC staff

prepared a briefing package that summarized the available information.

Copies of this briefing package can be obtained from the Commission's

Office of the Secretary. After considering the available information,

the Commission decided to publish this advance notice of proposed

rulemaking to begin a rulemaking proceeding that could result in

performance or other standards to address the risk of entrapment

associated with bunk beds.

B. Incident Data

From January 1990 through September 1997, CPSC received reports of

85 bunk-bed-related deaths of children under age 15. As shown below, 54

(64 percent) were caused by entrapment. An additional 23 children died

when they were inadvertently hanged from the bed by such items as

belts, ropes, clothing, and bedding. Eight children died in falls from

bunk beds during this period. Almost all (96 percent) of the entrapment

victims were ages 3 and younger, whereas hanging and fall victims

tended to be older than 3 years. The Commission continues to receive

reports of incidents and other information concerning bunk bed

entrapment hazards.

Available data indicate that the number of bunk-bed-related deaths

has not decreased in recent years and that the majority of fatal

incidents continue to involve entrapment. To better evaluate the extent

of the entrapment problem, the Commission's staff also developed

national estimates of the total number of entrapment deaths that

occurred each year, using statistical methodology that examined the

extent of overlap between data-reporting sources. These estimates

projected that about 10 bunk bed entrapment deaths have occurred each

year in the United States since 1990.

Fatal Bunk Bed Incidents Reported to CPSC, by Year and Hazard Pattern

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Hazard pattern

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Year Total Entrap. Hanging Falls

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1990........................................................ 7 5 2 ...........

1991........................................................ 15 10 2 3

[[Page 3282]]

1992........................................................ 4 3 1 ...........

1993........................................................ 19 10 7 2

1994........................................................ 10 6 3 1

1995........................................................ 12 5 5 2

1996........................................................ 11 10 1 ...........

1997........................................................ 7 5 2 ...........

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Total................................................... 85 54 23 8

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Source: CPSC Data Files, January 1990-September 1997, U.S. Consumer Product Safety Commission/EHHA.

CPSC staff reviewed available information on entrapment-related

incidents, which accounted for the majority of deaths, to obtain

additional detail about the circumstances involved. In all, CPSC

received reports of 103 entrapment incidents from January 1990 through

September 1997, including 54 that involved deaths and 49 that involved

``near-misses'' (where a child was entrapped, but usually with no or

minor injury, often because another person intervened). Most reported

incidents involved wooden bunk beds, and entrapment occurred most often

on the top bunk. Common areas of entrapment were under the guardrail,

within the end structures of the bed, and between the bed and the wall.

With three exceptions, almost all of the incidents involving fatal

entrapment in the structure of bunk beds occurred in areas of the beds

that apparently did not conform to the entrapment provisions in the

current voluntary standard. Two of the three exceptions involved

entrapment on the upper bunk. These beds had guardrails that did not

run the entire length of the bed and, in each of the two incidents, a

child slipped through the space between the end of the guardrail and

the bed's end structure and became wedged between the bed and a wall.

(The current standard permits guardrails that terminate before reaching

the bed's end structure, provided there is no more than 15 inches

between either end of the guardrail and the bed's closest end

structure.)

The third death involving a conforming bunk bed occurred when a 22-

month-old child was playing with an older sibling on a bunk bed and

placed his head into a tapered opening between the underside of the

upper bunk foundation and a structural member. This child is believed

to have been standing on the lower bunk mattress, and, when his feet

slipped off the mattress, he was suspended by his head. (The current

standard only addresses openings in lower bunk end structures that are

within 9 inches above the sleeping surface of the mattress.)

C. Market Information

Industry sources estimate that about 500,000 bunk beds are sold

each year for residential use (excluding institutional sales), and that

sales have been relatively stable over time. The annual retail value of

sales has been estimated by AFMA at about $150 million. Industry

sources estimate the average retail price of bunk beds to be about

$300, but prices range from about $100 to $700. Bunk beds are marketed

in specialty stores, furniture stores, department stores, and by mail

order. There is also a market for used bunk beds in thrift shops,

garage sales, and classified advertising.

Trade sources estimate the expected useful life of bunk beds to be

13-17 years. Based on available information, there are about 7-9

million bunk beds available for use, including bunk beds that are not

currently used for sleeping, and those that are now used as two

separate beds.

CPSC staff is aware of at least 106 bunk bed manufacturers, which

are believed to produce the bulk of annual sales. Of the 106 identified

firms, 40 are either members of AFMA or are members of the ASTM

subcommittee that developed the existing voluntary standard for bunk

beds. According to AFMA, these 40 firms represent 75-80 percent of the

total annual shipments of bunk beds. While there are likely many other

small regional manufacturers or importers of bunk beds in addition to

the 106 identified firms, these are not likely to account for a

significant share of the U.S. market.

D. Compliance With the Existing Voluntary Standard

There has been a continuing pattern of nonconformance to the

voluntary standard. From June through August 1994, the Commission's

Office of Compliance (Compliance) identified and sent letters of

inquiry to 85 bunk bed manufacturers/importers, as part of a voluntary

standard conformance monitoring project. Responses to these letters

revealed that 17 companies were marketing bunk bed designs that

presented potential entrapment hazards. Based on these responses, as

well as on retail inspections, consumer complaints, and reported

incidents, 41 manufacturers have, since November 1994, recalled wooden

and metal bunk beds that did not conform to the entrapment requirements

in the ASTM standard. The recalls involve over one-half million bunk

beds.

In February 1997, Compliance assigned 45 inspections of bunk bed

retailers nationwide. Examination of 77 beds from 35 different

manufacturers by staff from CPSC's regional offices revealed that 12

bunk bed designs, each from a different manufacturer, did not conform

with the entrapment requirements of the ASTM voluntary standard.

Problems identified through these inspections resulted both in

voluntary recalls of already produced beds and in corrections of future

production. The most recent recall, in September 1997, involved five

companies and pertained to 16,500 beds. One of these beds was involved

in a fatal entrapment incident.

As noted above, CPSC's staff identified 106 manufacturers and

importers of wooden and metal bunk beds. The Commission believes that

the actual number of manufacturers and importers could be much higher.

Because of the relative ease of constructing bunk beds, many small

companies are formed each year. These may quickly go in and out of the

business of making bunk beds. These companies are normally not

associated with industry organizations, and are often unaware of the

voluntary standard or misinterpret its requirements. Accordingly, the

Commission preliminarily concludes that it is very likely that there

will continue to be serious conformance problems with the voluntary

standard.

[[Page 3283]]

E. The Potential Need for a Mandatory Standard

Although the voluntary standard improves the safety of bunk beds,

companies are not required to comply with it. Some manufacturers

contacted by Compliance did not see an urgency to comply with a

``voluntary'' standard, and they did not recognize the hazards

associated with noncompliance. As a result, entrapment hazards will

continue to exist on beds in use and for sale. Currently, all 106

manufacturers identified by CPSC staff appear to be producing beds that

conform to the entrapment requirements in the ASTM F1427 bunk bed

standard. However, small regional manufacturers that periodically enter

the marketplace may not be aware of the voluntary standard, or of the

hazards that are associated with bunk beds.

The Commission believes that a mandatory entrapment standard may be

needed for the following reasons:

1. The adoption of a mandatory standard could increase the

awareness and sense of urgency of manufacturers regarding compliance

with the entrapment provisions, thereby increasing the degree of

conformance to those provisions.

2. A mandatory standard would allow the Commission to seek

penalties for violations. Publicizing fines for noncompliance with a

mandatory standard would deter other manufacturers from making

noncomplying beds.

3. A mandatory standard would allow state and local officials to

assist CPSC staff in identifying noncomplying bunk beds and take action

to prevent the sale of these beds.

4. Under a mandatory standard, retailers, and distributors would

violate the law if they sold noncomplying bunk beds. Retailers and

retail associations would then insist that manufacturers and importers

provide complying bunk beds.

5. The bunk bed industry is extremely competitive. Manufacturers

who now conform with the ASTM standard have expressed concern about

those firms that do not. Nonconforming beds can undercut the cost of

conforming beds. A mandatory standard would establish a level playing

field and take away any competitive cost advantage for unsafe beds.

6. A mandatory standard would help prevent noncomplying beds made

by foreign manufacturers from entering the United States. CPSC could

use the resources of U.S. Customs to assist in stopping hazardous beds

at the docks.

7. The absence of manufacturer identification on many beds has

resulted in extremely low recall effectiveness rates. A mandatory

standard could require companies to include identification on the beds.

8. Although the Commission currently believes that the ASTM

voluntary standard for bunk beds adequately addresses the most common

entrapment hazards associated with these products, the Commission is

aware of three entrapment fatalities that occurred in conforming beds.

A mandatory standard could modify the provisions in the voluntary

standard so as to address the deaths that can occur on beds that comply

with the voluntary standard.

Therefore, the Commission decided to issue an ANPR to begin a

rulemaking proceeding and to seek public comment on all aspects of this

proceeding, including (a) the need for a mandatory standard and (b) any

additional requirements that may be needed to address fatalities known

to have occurred on bunk beds conforming to the current voluntary

standard.

However, the available information does not support a conclusion

that changes to currently produced bunk beds would significantly reduce

the number of fatalities due to falls and hangings. Thus, although

information on these hazards is welcome, the Commission does not at

this time intend to propose performance requirements to address falls

or hangings from bunk beds.

F. Cost/Benefit Considerations

To provide some preliminary information on additional costs to

conform to the entrapment requirements of the existing voluntary

standard, CPSC's Economics staff contacted four manufacturers who had

modified their production for that reason. The most expensive

modification was the addition of a second guardrail to the top bunk.

Two firms estimated that the additional guardrail would add $15-20 to

the retail price of these products. The other two manufacturers, who

market beds in the ``mid to upper'' price range, estimated a $30-40

increase in the retail price of their products. This increased cost

would be incurred only by those firms that do not now conform to the

voluntary standard.

CPSC estimates that the costs to society of bunk bed entrapment

deaths is about $174-346 per bed over its expected useful life. The

costs of bringing bunk beds into conformance with entrapment

requirements range from $15-40 per bed. If the measures taken to

address bunk-bed-related entrapment deaths were only about 4 to 23

percent effective in reducing these deaths, the costs and the benefits

of such an activity would be about equal. In fact, the Commission

expects that a mandatory standard would be substantially more effective

than this.

G. Statutory Authorities for This Proceeding

What statute is appropriate for regulating bunk beds? CPSA section

3(a)(1), 15 U.S.C. 2052(a)(1). The Federal Hazardous Substances Act

(``FHSA'') authorizes the regulation of unreasonable risks of injury

associated with articles intended for use by children that present

mechanical (or electrical or thermal) hazards. FHSA section 2(f)(D), 15

U.S.C. 1261(f)(D). The hazards associated with bunk beds that are

described above are mechanical. See FHSA section 2(s), 15 U.S.C.

1261(s). The Consumer Product Safety Act (``CPSA'') authorizes the

regulation of unreasonable risks of injury associated with ``consumer

products,'' which include bunk beds--whether intended for the use of

children or adults. CPSA section 3(a)(1), 15 U.S.C. 2052(a)(1). Thus,

bunk beds intended for the use of adults can be regulated only under

the CPSA, while bunk beds intended for the use of children potentially

could be regulated under either the FHSA or the CPSA. Bunk beds

probably would be considered as intended for use by children only if

they have smaller than twin-size mattresses or incorporate styling or

other features especially intended for use or enjoyment by children.

Section 30(d) of the CPSA, however, provides that a risk associated

with a consumer product that can be reduced to a sufficient extent by

action under the FHSA can be regulated under the CPSA only if the

Commission, by rule, finds that it is in the public interest to do so.

15 U.S.C. 2079(d). Accordingly, children's bunk beds could be regulated

only under the FHSA, unless the Commission finds that it is in the

public interest to regulate them under the CPSA. Thus, assuming that

``adult'' and ``children's'' bunk beds each present an unreasonable

risk of injury, the Commission could:

1. Issue a rule for children's bunk beds under the FHSA and a rule

for adult bunk beds under the CPSA; or

2. Issue a rule under the CPSA for both adult and children's bunk

beds, and issue a rule under CPSA Sec. 30(d) that it is in the public

interest to do so.

A possible reason for finding that it is in the public interest to

regulate both adult and children's bunk beds under the CPSA would be to

avoid confusion as to which act applied to a particular bunk bed. The

Commission will make a decision on which act(s) should be used

[[Page 3284]]

if and when it decides to issue a proposed rule addressing the hazards

of bunk beds. As discussed below, the procedure and statutory findings

required to issue a rule for bunk beds are essentially identical under

either act. Accordingly, any final rule may be issued under the CPSA,

the FHSA, or a combination of the two acts.

What effect will the existence of the voluntary standard have on

the rulemaking? The Commission may not issue a standard under either

the CPSA or the FHSA if industry has adopted and implemented a

voluntary standard to address the risk, unless the Commission finds

that ``(i) compliance with such voluntary * * * standard is not likely

to result in the elimination or adequate reduction of such risk of

injury; or (ii) it is unlikely that there will be substantial

compliance with such voluntary * * * standard.'' In this case, it

appears that a high percentage of bunk beds comply with ASTM F1427-92.

Accordingly, the Commission has addressed the issue of whether the

relatively high degree of compliance with the ASTM standard (possibly

90 percent or more) constitutes ``substantial compliance'' that would

prevent the Commission from issuing a mandatory standard for bunk beds.

Neither statute defines the term ``substantial compliance.''

However, guidance is provided by the legislative history of the CPSA:

In determining whether or not it is likely that there will be

substantial compliance with such voluntary * * * standard, the

Commission should determine whether or not there will be sufficient

compliance to eliminate or adequately reduce an unreasonable risk of

injury in a timely fashion. Therefore, compliance generally should

be measured in terms of the number of complying products rather than

in terms of complying manufacturers.

H.R. Conf. Rep. No. 208, 97th Cong., 1st Sess. 873 (1981): ``Adequately

reduce'' means to reduce the risk ``to a sufficient extent that there

will no longer exist an unreasonable risk of injury.'' Id. This

legislative history suggests that substantial compliance means that

there will be sufficient compliance with the voluntary standard to

reduce the product's risk to the point that the risk is no longer

``unreasonable.''

Factors that are relevant both to a determination of unreasonable

risk and to whether there is substantial compliance are the severity of

the remaining injuries and the vulnerability of the injured population.

The CPSC staff's analysis shows that issuing a mandatory rule could

save a significant number of children's lives. Thus, the injuries are

severe, and the affected population is extremely vulnerable. The cost/

benefit information discussed above indicates a likelihood that the

benefits of a rule for bunk beds would bear a reasonable relationship

to its costs, and the remaining risks from bunk beds are thus

``unreasonable.'' See 15 U.S.C. 1262(i)(2)(B), 2058(f)(3)(E).

Accordingly, the Commission preliminarily concludes that there

currently is not substantial compliance with the ASTM standard.

Rulemaking procedure. Before adopting a CPSA standard or FHSA rule,

the Commission first must issue an ANPR as provided in section 3(f) of

the FHSA or section 9(a) of the CPSA. 15 U.S.C. 1262(f), 2058(a). If

the Commission decides to continue the rulemaking proceeding after

considering responses to the ANPR, the Commission must then publish the

text of the proposed rule, along with a preliminary regulatory

analysis, in accordance with section 3(h) of the FHSA or section 9(c)

of the CPSA. 15 U.S.C. 1262(h), 2058(c). If the Commission then wishes

to issue a final rule, it must publish the text of the final rule and a

final regulatory analysis that includes the elements stated in 3(i)(1)

of the FHSA or section 9(f)(2) of the CPSA. 15 U.S.C. 1262(i)(1),

2058(f)(2). And before issuing a final regulation, the Commission must

make certain statutory findings concerning voluntary standards, the

relationship of the costs and benefits of the rule, and the burden

imposed by the regulation. FHSA section 3(i)(2), CPSC section 9(f)(3),

15 U.S.C. 2058(f)(3).

H. Regulatory Alternatives Under Consideration

The Commission is considering alternatives to reduce the number of

injuries and deaths associated with bunk beds. In addition to possible

performance standards similar to the current ASTM standard, additional

performance standards may be developed to supplement the entrapment

provisions of the ASTM standard. Further, the potential for labeling or

instructions requirements and information and education campaigns to

reduce the risk will be considered, either instead of or in addition to

a mandatory standard.

It is also possible that a voluntary standard could be developed

that would adequately reduce the risks of entrapment, falls, and

hanging. The Commission is not aware of any voluntary standard in

effect that applies to the identified risks of bunk beds other than

ASTM F1427-96. As noted above, the Commission has preliminarily

concluded that the degree of compliance with this ASTM standard may be

insufficient and some fatalities have occurred that are not adequately

addressed by that standard. However, if improved voluntary standards

are developed and implemented, the Commission would take that into

account in deciding whether a mandatory standard is necessary.

I. Solicitation of Information and Comments

This ANPR is the first step of a proceeding which could result in a

mandatory performance, labeling, or instructions standard for bunk beds

to address the risk of entrapment. All interested persons are invited

to submit to the Commission their comments on any aspect of the

alternatives discussed above. In particular, CPSC solicits the

following additional information:

1. The models and numbers of bunk beds produced for sale in the

U.S. each year from 1990 to the present;

2. The names and addresses of manufacturers and distributors of

bunk beds;

3. The number of persons injured or killed by the hazards

associated with bunk beds;

4. The circumstances under which these injuries and deaths occur,

including the ages of the victims;

5. An explanation of designs that could be adapted to bunk beds to

reduce the risk of entrapment;

6. Characteristics of the product that could or should not be used

to define which products might be subject to the requested rule, and

which products, if any, are intended for use by children, and which for

adults;

7. Other information on the potential costs and benefits of

potential rules;

8. Steps that have been taken by industry or others to reduce the

risk of injuries from the product;

9. The likelihood and nature of any significant economic impact of

a rule on small entities;

10. The costs and benefits of mandating a labeling or instructions

requirement.

Also, in accordance with section 3(f) of the FHSA and section 9(a)

of the CPSA, the Commission solicits:

1. Written comments with respect to the risk of injury identified

by the Commission, the regulatory alternatives being considered, and

other possible alternatives for addressing the risk.

2. Any existing standard or portion of a standard which could be

issued as a proposed regulation.

3. A statement of intention to modify or develop a voluntary

standard to address the risk of injury discussed in this notice, along

with a description of a plan (including a schedule) to do so.

[[Page 3285]]

Comments should be mailed, preferably in five copies, to the Office

of the Secretary, Consumer Product Safety Commission, Washington, D.C.

20207-0001, or delivered to the Office of the Secretary, Consumer

Product Safety Commission, Room 502, 4330 East-West Highway, Bethesda,

Maryland 20814; telephone (301) 504-0800. Comments also may be filed by

telefacsimile to (301) 504-0127 or by email to [email protected].

Comments should be captioned ``ANPR for Bunk Beds.'' All comments and

submissions should be received no later than April 7, 1998.

Dated: January 15, 1998.

Sadye E. Dunn,

Secretary, Consumer Product Safety Commission.

[FR Doc. 98-1457 Filed 1-21-98; 8:45 am]

BILLING CODE 6355-01-P