Danger to human health or safety assessment for high chairs

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 the 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

High chairs

Includes:

• Free-standing children's high chairs

Excludes:

• Hook-on chairs
• Booster seats

Hazards of concern

High chairs with insufficient structural integrity, stability, or tray performance may pose a fall hazard to the occupant.

Completely bounded openings created by the tray table, sides and bottom of the seat may pose an entrapment hazard.

Incidents^{Footnote 1}

Health Canada is aware of 43 reports of incidents that occurred between June 20, 2011 and December 31, 2022 involving high chairs in Canada. Of those 43 reports, 20 involved an injury and one reported a death. This reported death was related to an entrapment hazard.

Health Canada is aware of 210 reports of incidents that occurred between April 1, 2011 and December 31, 2022 involving children 0 to 3 years old and high chairs. Of the 210 reports, 124 involved an injury and 1 involved a death. The US data is from the Consumer Product Safety Commission's publicly available database: https://www.saferproducts.gov/PublicSearch

Health Canada is aware of 4,080 reports in the United States National Electronic Injury Surveillance System (NEISS) of incidents that occurred between January 2011 and December 2019 involving children 0 to 3 years old and high chairs. Some of these reports might involve booster seats, as there is not enough information to distinguish between the two product categories.

Danger to human health or safety assessment

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:

1. Unreasonable hazard
2. Existing or potential hazard
3. Normal or foreseeable use
4. May reasonably be expected to cause
   1. Death
   2. Adverse effect on health

1. Unreasonable hazard

The consideration of unreasonable hazard includes the following components.

a. Inherent hazard

Placing a child in an elevated position is required for the product to function as intended, which presents an inherent fall hazard associated with its use. It is also foreseeable that a portion of caregivers may use the tray as a restraint system in order to prevent forward movement of the occupant without engaging the actual restraint system provided with the product. In such a scenario, a tray detachment from the high chair presents a fall hazard to the occupant.

Additionally, completely bounded openings created by the tray table, sides and bottom of the seat inherently pose an entrapment hazard.

b. Severity of hazard

Unstable high chairs may pose fall hazards. High chairs with completely bounded openings may pose entrapment hazards. The severity of the injury can range from a minor bruise to a serious head injury from a fall, or asphyxiation or death from entrapment.

c. Intended and foreseeable users

The intended users of high chairs are children 0 to 3 years of age. Children may be particularly vulnerable to a fall or entrapment hazard because they may not understand the hazard. Although it is recommended for a caregiver to supervise a child during high chair use, it is reasonably foreseeable that a child may be left unsupervised in the high chair from time to time.

d. Obviousness of hazard

The main users of high chairs are children that are unable to recognize the hazards associated with high chairs. Caregivers may be able to recognize an unstable high chair. However, the entrapment hazard from completely bounded openings and the fall hazard from tray detachment may not be obvious to caregivers.

e. Social utility

High chairs are free-standing products designed to elevate a child to the height of a dining table. Since the purpose of a high chair is to elevate a child, the inherent fall hazard cannot be eliminated without removing the social utility of the product.

High chairs often have a tray that is used for eating or playing. On some high chairs, completely bounded openings created by the tray table, sides and bottom of the seat may pose an entrapment hazard. Since the tray provides a practical function for high chairs, the hazard cannot be eliminated without reducing the social utility of the product.

f. Available alternatives

Available alternatives to high chairs include hook-on chairs and booster seats. These products also pose a fall hazard, and may pose an entrapment hazard.

g. Consensus-based safety standards or government regulations

Based on the information currently available, multiple international consensus-based safety standards set out criteria that may be sufficient to mitigate the risk of an entrapment or fall. The following criteria may be sufficient to address each concern:

• Entrapment
• ASTM F404-14a – section 6.9; or
• EN 14988-1: 2006+A1:2012 – subclause 5.6.3
• Tray detachment
• ASTM F404-14a – section 6.3;
• EN 14988-1:2006+A1:2012 – subclause 5.12, and the associated tests in subclauses 6.18.1 and 6.18.2 of EN 14988-2:2006+A1:2012; or
• ISO 9221-1:1992 – subclauses 5.2.5 and 5.2.9, and the associated test in subclause 5.6.7 of ISO 9221-2:1992
• Structural integrity with occupant in seat
• ASTM F404-14a – section 6.4;
• EN 14988-1:2006+A1:2012 – subclause 5.12, and the associated test in subclause 6.11 of EN 14988-2:2006+A1:2012; or
• ISO 9221-1:1992 – subclauses 5.2.5 and 5.2.9, and the associated test in subclause 5.6.2 of ISO 9221-2:1992
• Stability
• ASTM F404-14a – section 6.5;
• AS 4684-2009 – section 7 and Appendix C sections (e) to (r);
• EN 14988-1:2006+A1:2012 – subclauses 6.1, 6.2, 6.3, 6.4, 6.5, and 6.6; or
• ISO 9221-1:1992 – subclause 5.2.8, and the associated tests in subclauses 5.10.2, 5.10.3, 5.10.4, and 5.10.5 in ISO 9221-2:1992

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 fall or entrapment hazard. High chairs with insufficient structural integrity, stability, or tray performance may pose a fall hazard. In addition, it is foreseeable that a poorly made high chair poses an entrapment hazard that may cause a serious injury or even death.

3. Normal or foreseeable use (including foreseeable misuse)

Although it is recommended for a caregiver to supervise a child during high chair use, it is reasonably foreseeable that a child may be left unsupervised in the high chair from time to time.

Normal or foreseeable use of an unstable high chair can lead into the product tipping over with the child in it. Normal or foreseeable use of a high chair with inadequate structural integrity can lead to the product collapsing with the child in it causing potential injuries that range from a minor scratch to a serious head injury. Also, in the foreseeable event that a caregiver uses a tray to secure the child in the product without using the high chair straps, a poorly secured tray can also pose a fall hazard.

Normal or foreseeable use may result in a child's body sliding through the completely bounded opening formed by the tray table, sides and bottom of the seat if the active or passive crotch restraints are not used, not present, or fail. The child's head or neck could become entrapped in the completely bounded opening and may result in asphyxiation or death.

4. May reasonably be expected to cause

a. Death

If the active or passive crotch restraints are not used, are not present, or fail, a child's body may slide through the completely bounded opening formed by the tray table, sides and bottom of the high chair seat. As a result, the child's head or neck could become entrapped in the completely bounded opening and may cause death by asphyxiation.
Health Canada is aware of one Canadian report of death associated with an entrapment hazard in high chairs.
It is therefore reasonable to expect that high chairs that do not conform to the applicable criteria outlined above to address the entrapment hazard may cause death.

b. Adverse effect on health

An entrapment hazard of a high chair may also reasonably be expected to cause adverse effects on health. Additionally, a high chair with insufficient structural integrity, stability, or tray performance may pose a fall hazard leading to injuries. Collectively, these adverse effects may include:

• Concussion
• Contusions, Abrasions
• Fracture
• Hematoma
• Internal organ injury
• Laceration

Health Canada is aware of reports in the United States Publicly Available Consumer Product Safety Information Database of adverse effects on health associated with high chairs.

It is therefore reasonable to expect that high chairs that do not conform to the applicable criteria outlined above to address the fall and entrapment hazards 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).