Danger to human health or safety assessment for free-standing clothing storage units
Last updated: July 4, 2023
Table 3 was first published in July 2020 to consolidate information for regulated parties in an effort to increase openness and transparency regarding Health Canada's evaluation of products that pose a danger to human health or safety. While this entry was added to Table 3 upon initial posting of the table in July 2020, the danger to human health or safety was previously communicated by Health Canada to regulated parties. This assessment does not present new decisions, and is being published for clarity on the decisions made previously.
Legislative background
The purpose of Canada Consumer Product Safety Act (CCPSA) is to protect the public by addressing or preventing dangers to human health or safety that are posed by consumer products in Canada, including those that circulate within Canada and those that are imported. Any person who manufactures, imports, advertises, sells or tests a consumer product must comply with all applicable requirements of the CCPSA and its regulations. Paragraphs 7(a) and 8(a) of the CCPSA prohibit the manufacture, importation, advertisement or sale of any consumer product that is a "danger to human health or safety". The CCPSA defines the term as follows:
Danger to human health or safety means any unreasonable hazard — existing or potential — that is posed by a consumer product during or as a result of its normal or foreseeable use and that may reasonably be expected to cause the death of an individual exposed to it or have an adverse effect on that individual's health — including an injury — whether or not the death or adverse effect occurs immediately after the exposure to the hazard, and includes any exposure to a consumer product that may reasonably be expected to have a chronic adverse effect on human health.
Scope of affected products
Free-standing clothing storage units
Includes, but is not limited to:
- Chests of drawers, door chests, dressers, and armoires
- Units that are not built into a wall and are not permanently attached to a structure
- Units greater than 686 mm (27 inches) in height
Excludes:
- Non-clothing storage units such as bookcases, shelving units, entertainment furniture, office furniture, display cabinets, and other accent furniture not intended for bedroom use
- Units equal to or less than 686 mm (27 inches) in height
- Built-in clothing storage units that are built into a wall or are permanently attached to a structure
- Nightstands and single-compartment chests
Hazards of concern
Free-standing clothing storage units greater than 686 mm (27 inches) in height may pose a tip-over hazard to children. The unit tipping over could pin down the child resulting in suffocation injuries or death, or the impact could result in serious crushing injuries such as internal organ damage, concussion, or death.
IncidentsFootnote 1
Health Canada is aware of 87 reports of incidents that occurred between June 20, 2011, and December 31, 2022, involving tip-over of furniture in Canada. Of the 87 reports, nine reported a death and 41 reported an injury.
Health Canada is aware of 20,900 reports of emergency room visits that occurred between 2014 and 2018 involving tip-over of furniture in the United States. Of those emergency room visits, 89 reported a death as of October 2018. According to the United States Consumer Product Safety Commission (CPSC), a majority of these deaths involved chests, bureaus, or dressers toppling over and killing small children. The US data is from the CPSC's publicly available database: https://www.saferproducts.gov/PublicSearch.
Danger to human health or safety assessment
Based on the danger to human health or safety considerations and details discussed in the following sections, Health Canada believes that free-standing clothing storage units that do not conform to the applicable criteria set out in ASTM F2057-19 – Standard Safety Specification for Clothing Storage Units, or the equivalent, likely pose a danger to human health or safety.
Health Canada recognizes that there may be other possible health or safety concerns with the use of these or similar products. Industry should review their products for all potential hazards and respond appropriately to make sure they are safe for consumers. The Consumer Product Safety Program of Health Canada operates as a post-market regulatory regime, meaning that there is no pre-market review or approval of consumer products by Health Canada.
Health Canada may update this assessment as warranted.
Danger to human health or safety considerations
Considerations for a product to pose a potential danger to human health or safety are outlined in Health Canada's Industry Guidance - "Danger to Human Health or Safety" Posed by Consumer Products. The main considerations assessed are:
- Unreasonable hazard
- Existing or potential hazard
- Normal or foreseeable use
- May reasonably be expected to cause
- Death
- Adverse effect on health
1. Unreasonable hazard
The consideration of unreasonable hazard includes the following components.
a. Inherent hazard
The primary purpose of free-standing clothing storage units is to store and organize clothing. Being free-standing permits the product to be moved but creates an inherent tip-over hazard to children. The unit tipping over could pin down the child resulting in suffocation injuries or death, or the impact could result in serious crushing injuries such as internal organ damage, concussion, or death. The risk of a tip-over is proportional to the stability of the free-standing clothing storage unit. As stability is dependent upon the centre of gravity, the greater the height of the centre of gravity, the greater likelihood for it to become unstable and tip over. Tip-over is not a necessary or intended use or feature of free-standing clothing storage units.
b. Severity of hazard
A free-standing clothing storage unit may pose a tip-over hazard to children. The unit tipping over could pin down the child resulting in suffocation injuries or death, or the impact could result in serious crushing injuries such as internal organ damage, concussion, or death.
c. Intended and foreseeable users
The intended and reasonably foreseeable users of free-standing clothing storage units are adults and children. Young children may be particularly vulnerable to the tip-over hazard posed by a free-standing clothing storage unit because they are more likely to climb furniture or apply downward force to an open drawer while trying to access the higher parts of the unit.
d. Obviousness of hazard
It may not be obvious to young children or their caregivers that climbing a free-standing clothing storage unit may pose a tip-over hazard. The product tipping over could pin down the child resulting in suffocation injuries or death, or the impact could result in serious crushing injuries such as internal organ damage, concussion, or death. The observation that free-standing clothing storage units may commonly be found in a young child's room is a reason to believe that caregivers may not be aware of this hazard. Adults and caregivers are expected to be more aware of this hazard than young children.
e. Social utility
Free-standing clothing storage units could be more easily moved than built-in clothing storage units when rearranging a room. A free-standing clothing storage unit greater than 686 mm (27 inches) in height may be able to store more clothing than a shorter unit.
f. Available alternatives
Built-in clothing storage units, closets, shelves, detached wardrobe racks, underbed drawer storage units, are clothing storage options that are some of the available alternatives to free-standing clothing storage units.
g. Consensus-based safety standards or government regulations
One available international consensus-based safety standard for free-standing clothing storage units is ASTM F2057-19 – Standard Safety Specification for Clothing Storage Units. This standard sets out criteria that address the tip-over hazard, including:
- Performance requirements – section 4
This is currently the only identified safety standard for furniture that addresses the risk of tip-over hazard. There are products available in the Canadian marketplace that appear to conform to the applicable criteria outlined above.
2. Existing or potential hazard
Incident reports from Canada and the United States indicate the presence of an existing or potential tip-over hazard.
3. Normal or foreseeable use (including foreseeable misuse)
Normal or foreseeable use of free-standing clothing storage units may pose a tip-over hazard. A child may foreseeably empty a drawer of a free-standing clothing storage unit of its contents and climb or lean into the empty drawer or apply downward force to an open drawer while trying to access the higher parts of the unit, resulting in a tip-over. The unit tipping over could pin down the child resulting in suffocation injuries or death, or the impact could result in serious crushing injuries such as internal organ damage, concussion, or death.
4. May reasonably be expected to cause
a. Death
Normal or foreseeable use of free-standing clothing storage units may pose a tip-over hazard. A child may foreseeably empty a drawer of a free-standing clothing storage unit of its contents and climb or lean into the empty drawer or apply downward force to an open drawer while trying to access the higher parts of the unit, resulting in a tip-over. The unit tipping over could pin down the child resulting in suffocation injuries or death, or the impact could result in serious crushing injuries such as internal organ damage, concussion, or death.
Health Canada is aware of reports of deaths from Canada and the United States that were associated with the tip-over of free-standing clothing storage units.
It is therefore reasonable to expect that free-standing clothing storage units that do not conform to the applicable criteria outlined above to address the tip-over hazard may cause death.
b. Adverse effect on health
The circumstances that may reasonably be expected to cause death may also reasonably be expected to cause adverse effects on health, including:
- Suffocation injuries
- Crushing injuries such as internal organ damage
- Concussion
Health Canada is aware of reports of adverse effects on health from Canada and the United States that were associated with the tip-over of free-standing clothing storage units.
It is therefore reasonable to expect that free-standing clothing storage units that do not conform to the applicable criteria outlined above to address the tip-over hazard may cause an adverse effect on human health.
If you require additional information regarding this Danger to Human Health or Safety Assessment, please contact a Health Canada Consumer Product Safety Office via email (hc.ccpsa-lcspc.sc@canada.ca) or telephone at 1-866-662-0666 (toll-free within Canada and the United States).
Footnotes
- Footnote 1
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Health Canada receives reports on an ongoing basis and does not validate details of every report it receives. Incident report numbers are based on the data available at the time of publication.
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