Summary: Consultation on Proposed Amendments to the Carriages and Strollers Regulations

Introduction

As part of ongoing efforts to review the existing suite of regulations under the Canada Consumer Product Safety Act, the Consumer and Hazardous Products Safety Directorate identified opportunities to strengthen the Carriages and Strollers Regulations (CSR) with proposed amendments to help improve health and safety, increase regulatory alignment with Canada's major trading partners, and address known stakeholder irritants.

This consultation document outlines a proposal to amend the CSR, and includes a questionnaire for stakeholders to provide feedback. Responses received by Health Canada on the proposal will help inform the direction that Health Canada will pursue to address the issues identified in this consultation.

Background

Canadian Legislation

Carriages and strollers are wheeled vehicles designed to transport infants and children. The Carriages and Strollers Regulations (CSR) were introduced in 1985 under Part II of Schedule I to the Hazardous Products Act (HPA) to help protect the health and safety of infants and children. The CSR include design, performance, and labelling requirements intended to minimize or eliminate hazards associated with carriages and strollers. On June 20, 2011, the Canada Consumer Product Safety Act (CCPSA) came into force and replaced Part I and Schedule I to the HPA. All regulations under the HPA were transferred under the CCPSA. In 2016, the CSR were amended to make administrative changes to remove any references to the HPA. The amendments also addressed several housekeeping revisions to reflect changes to legislative drafting practices, and to correct English and French inconsistencies. The requirements of the CSR were not changed substantively in 2016.

International Standards and Legislation

The United States Consumer Product Safety Commission (US CPSC) Direct Final Rule incorporates by reference ASTM F833-19 Standard Consumer Safety Performance Specification for Carriages and Strollers (ASTM F833-19) as the mandatory standard in the United States for carriages and strollers. This is codified in 16 CFR part 1227. The United States Consumer Product Safety Improvement Act allows US CPSC to adopt future editions of this ASTM standard after being published. Health Canada reviewed ASTM F833-19 and found that it addresses hazards related to the design of carriages and strollers that emerged since the CSR came into force in 1985.

ISO 31110:2020 Wheeled child conveyances — Pushchairs and prams - Requirements and test methods (ISO 31110:2020) was published in December 2020. The development of this international voluntary standard included the broadest range of jurisdictions as stakeholders of any standard for carriages and strollers and is largely based on the European standard EN 1888-1:2012, Child use and care articles - Wheeled child conveyances - Pushchairs and prams. Health Canada reviewed this ISO standard, and found that it addresses hazards related to the design of carriages and strollers that emerged since the CSR came into force in 1985.

Proposed amendments

Ambulatory incorporation by reference

In this proposal, Health Canada is proposing to incorporate documents by ambulatory reference.

An ambulatory reference refers to an incorporation by reference of a document into a regulation as it is changed over time. When a document is incorporated using the words "as amended from time to time", any change to that document becomes part of the regulation. As the document is changed, the new version would become part of the regulation without needing to amend the regulations.

Transition period

In this proposal, Health Canada is proposing a transition period of 6 months for documents incorporated by ambulatory reference.

Health Canada is proposing that ambulatory incorporation by reference would benefit stakeholders most by including a transition period to clarify when stakeholders must comply with new editions of the referenced documents.

For example, one type of transition period Health Canada is considering would set a time period during which products can comply with either the new edition of the document, or the previous edition. At the end of the transition period, all products offered for sale would have to comply with the new edition of the document.

Proposed Requirements

Proposed amendments to the CSR cover five types of requirements:

  1. Mechanical
  2. Surface coating materials
  3. Toxicological hazards
  4. Phthalates
  5. Information and warnings

The following sections outline the proposed requirements in detail.

1. Proposed amendments to mechanical requirements

Health Canada is proposing to address the mechanical hazards that emerged after 1985 by aligning Canadian requirements with international requirements, where appropriate. Health Canada proposes that alignment can be achieved by replacing the mechanical requirements of the CSR with one of the two following options:

  1. By requiring compliance to the mechanical requirements from ASTM F833-19, incorporated by ambulatory reference; or
  2. By requiring compliance with at least one of:
    1. the mechanical requirements from ASTM F833-19, incorporated by ambulatory reference; or
    2. the mechanical requirements from ISO 31110:2020, incorporated by ambulatory reference, and in addition, the entrapment requirements from ASTM F833-19 sections 6.8 and 6.10;

The proposed amendments to the mechanical requirements of the CSR, the hazards they address, and the relevant sections in the CSR, ASTM F833-19, and ISO 31110:2020 are described in an appendix at the end of this document.

2. Proposed amendments to surface coating materials requirements

The CSR currently refers to the requirements for surface coating materials set out in section 23 of the Toys Regulations.

Health Canada is proposing to amend the CSR to remove the reference to the Toys Regulations, and make the requirements directly in the text of the amended CSR consistent with the following:

A sticker, film or other similar material that can be removed, or a surface coating material, that is applied to an accessible part of a carriage or stroller must not contain, when it is tested in accordance with a method that conforms to good laboratory practices,

  1. more than 90 mg/kg total lead;
  2. any compound of antimony, arsenic, cadmium, selenium or barium if more than 1000 mg/kg of the compound migrates from the material; or
  3. more than 10 mg/kg total mercury.

3. Proposed amendments to toxicological requirements

The CSR currently refers to toxicological requirements set out in sections 22 and 25 of the Toys Regulations.

Health Canada is proposing to maintain these requirements by providing them directly into the text of the amended CSR.

4. Proposed amendments to phthalates requirements

The CSR do not currently include requirements for phthalates.

Health Canada is proposing to require that vinyl parts of a carriage or stroller must comply with the Phthalates Regulations.

5. Proposed amendments to information and warning requirements

Health Canada is proposing to remain flexible regarding the content of the information and warning requirements of the CSR to allow for potential alignment with ASTM F833-19 or ISO 31110:20. However, Health Canada will maintain the official language requirement for all information and warnings to be written in both English and French.

Questionnaire

Contact Information

Stakeholder Interest Information

Question 1

Health Canada is proposing to replace the mechanical requirements of the CSR with one of the two following options:

  1. By requiring compliance to the mechanical requirements from ASTM F833-19, incorporated by ambulatory reference; or
  2. By requiring compliance with the at least one of:
    1. the mechanical requirements from ASTM F833-19, incorporated by ambulatory reference; or
    2. the mechanical requirements from International Organization for Standardization, ISO 31110:2020, incorporated by ambulatory reference, and in addition the entrapment requirements from ASTM F833-19 sections 6.8 and 6.10;

Do you have a preference for one of the above options for mechanical requirements?

Question 2

Do you have any comments or concerns about mechanical requirements in either the ASTM F833-19 standard, or the ISO 31110:2020 standard? For example, "I don't think requirement X is protective, it should use a higher force".

Question 3

For mechanical requirements, Health Canada is proposing to use an ambulatory incorporation by reference of the standards. This means that the regulation would always require compliance to the latest edition of the standards, as amended from time to time.

Health Canada is proposing a 6-month transition period after the publication of a new edition of a standard. What do you think is an appropriate trigger to start the 6-month transition period?

Question 4

For the mechanical requirements, Health Canada is proposing a 6-month transition period after the publication of a new edition of a standard.

Do you think 6 months is an appropriate length for the transition period:

Question 5

Do you have any comments regarding the other proposed requirements for the amended regulations? Such as the requirements for surface coating materials, toxicological hazards, phthalates, or information and warnings.

Question 6

Please provide any additional information that you feel should be considered regarding the proposed amendment to the Carriages and Strollers Regulations?

Appendix A: Mechanical Requirements

The following list outlines Health Canada's proposed amendments to the mechanical requirements of the CSR, the hazards they address, and the relevant sections in the CSR, ASTM F833-19 and ISO 31110:2020. This list is set out in the order these sections appear in the ASTM F833-19 standard.

  1. Product and accessory definitions: Introduce and update terminology to account for new designs of carriages, strollers, and accessories and to align with other jurisdictions, where appropriate. This change relates to section 1 of the Regulations, section 3 of ASTM F833-19, and clause 3 of ISO 31110:2020.
  2. Sharp parts and surfaces: Amend the requirements and test method for sharp edges, corners, points, projections, burrs, and cracks and for smooth finish. This change relates to section 10 of the Regulations, sections 5.1, 5.4, and 5.10 of ASTM F833-19, and clause 8.7 of ISO 31110:2020.
  3. Small parts choking hazard: Amend the requirements and test method for small parts by adding the torque test method to test for the removal of protective components. This change relates to section 11 of the Regulations, sections 5.2, 5.10 and 5.14 of ASTM F833-19, and subclause 8.5 of ISO 31110:2020.
  4. Latching system integrity: Amend the requirements and test method to evaluate the structural integrity of the latching mechanisms. This change relates to section 7 of the Regulations, section 5.5 of ASTM F833-19, and subclause 8.3.6 of ISO 31110:2020.
  5. Open holes: Amend the requirements and test method for open holes (holes or slots). This change relates to section 12 of the Regulations, section 5.6 of ASTM F833-19, and subclause 8.2 of ISO 31110:2020.
  6. Scissoring, shearing and pinching: Amend the dimensions specified in the requirements and introduce requirements and a test method to address the hazards in various designs of folding strollers. Specifying parts of carriages and strollers that are excluded from the requirements such as the adjustment of accessories. Also introduce requirements and a test method to address the hazard in saddle or canopy hinges. This change relates to section 3 of the Regulations, section 5.7 of ASTM F833-19, and subclause 8.3 of ISO 31110:2020.
  7. Exposed coil springs: Introduce a more specific requirement and test method to address exposed coil springs accessible to the occupant. This change relates to section 12 of the Regulations, section 5.8 of ASTM F833-19, and subclause 8.2.1 of ISO 31110:2020.
  8. Information permanency: Amend the requirements and test method to evaluate permanency of safety information and warnings. This change relates to section 14 of the Regulations, section 5.9 of ASTM F833-19, and clause 9 of ISO 31110:2020.
  9. Strangulation and entanglement: Introduce a length requirement to address the strangulation hazard from cords and straps. This change relates to section 5.13 of ASTM F833-19 and subclause 8.4 of ISO 31110:2020.
  10. Parking brake: Amend the performance requirements and test method for evaluating the parking brake system. This change relates to section 5 of the Regulations, section 6.1 of ASTM F833-19, and subclause 8.8 of ISO 31110:2020.
  11. Structural integrity: Amend the performance requirements and test method to evaluate structural integrity. Car seat accessories that comply with the requirements of the Motor Vehicle Restraint Systems and Booster Seats Safety Regulations will be excluded. This section relates to sections 8 and 13 of the Regulations, section 6.2 of ASTM F833-19, and subclause 8.10 of ISO 31110:2020.
  12. Stability: Amend the requirements and test method to evaluate stability for strollers with an adjustable back rest to test them in the most reclined position in addition to the most upright position. Also adding requirements and a test method for the stability of carriages and strollers with accessories. This change relates to section 4 of the Regulations, section 6.3 of ASTM F833-19, and subclause 8.9 of ISO 31110:2020.
  13. Restraining system integrity: Amend the requirements and test method and introduce requirements and a test method for buckle release and carriage accessories. This change relates to section 6 of the Regulations, section 6.4 of ASTM F833-19, and subclause 8.1.3 of ISO 31110:2020.
  14. Occupant retention: Introduce requirements and a test method to evaluate the ability of a carriage or stroller to retain the occupant. This change relates to section 6.5 of ASTM F833-19 and clause 8.1.1 and 8.1.2 of ISO 31110:2020.
  15. Car seats and other accessories: Introduce requirements and a test method to evaluate the attachment of accessories to the frame of carriages and strollers. Amend various requirements to account for designs with accessories. This change relates to section 6.6 of ASTM F833-19 and subclause 8.10 of ISO 31110:2020.
  16. Impact: Introduce requirements and a test method to evaluate the continuing performance of carriages and strollers following an impact. This change relates to section 6.7 of ASTM F833-19 and subclause 8.10.4 of ISO 31110:2020.
  17. Entrapment: Introduce performance requirements and a test method to evaluate head entrapment beneath a tray or a grab bar, and entrapment in openings such as the foot opening. This change relates to sections 6.8 and 6.10 of ASTM F833-19.
  18. Wheel integrity: Introduce requirements and a test method to assess the attachment of the wheels to the axle. Also introducing requirements and a test method for a secondary retention device for removable wheel fork assembly designs. This change relates to section 6.9 of ASTM F833-19 and subclause 8.10.5 of ISO 31110:2020.
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