 Hello everyone and thank you for attending the CPSC webinar requirements for clothing storage units. A couple of housekeeping notes before we get started. The webinar is being recorded and will be posted on CPSC's YouTube channel under the Business Guidance playlist. Questions can be submitted through the Questions tab using the GoToWebinar dashboard. A handout PDF of the slide deck will be distributed to all attendees. Hyperlinks within the PDFs will be clickable, so don't worry about trying to copy any kind of long hyperlinks. There are a couple of polling questions just to kind of gauge your baseline knowledge, so please feel free to participate in those. And finally, there will be a resource page at the end where we'll kind of reference a couple of the stuff that we refer to throughout the slides, so just kind of look out for that page at the end. Your speakers today will be myself, Stefan Lee, Program Specialist with the Small Business Ombudsman Team, Carolina Abraham, Compliance Officer with the Regulatory Enforcement Division, and Kristen Taka, Human Factors Engineer with the Division of Human Factors. Our email addresses are there for you to contact us. Today we'll be going over again the requirements for clothing storage units. We'll start with a background of how the rule came about, and then we'll go into the requirements and compliance for clothing storage units, which will cover CSU-specific requirements as well as other applicable requirements, and then some information about potential enforcement. We'll then be going over the test procedure for CSUs and the warning requirement, and then a Q&A session at the end. So the Implementation of Sturdy 15 USC Section 2056F that was enacted in December 2022, and it directed CPSC to promulgate rulemaking for CSUs. Following this, CPSC voted to accept ASTM F 2057-23 as the safety standard for clothing storage units without any edits. Note that this is version-specific to the dash 23 version. Adoption of this ASTM standard does supersede CPSC's previous rule, which is found at 87FR72598, and you can find this language at 88FR28403. The regulation will be codified at 16 CFR part 1261. Currently, the language for the CFR is only found in the FR notice, which is 88FR28403. The online version of CFR, which is ecfr.gov, will update after the effective date, and kind of related to that, the effective date is going to be September 1st, 2023, and it applies to products that are manufactured after this date. So what CSUs are subject to 16 CFR part 1261? Well, the definition of a CSU at ASTM F 2057-23 section 3.1.3 states that these are going to be furniture items with drawers and or hinge doors intended for the storage of clothing typical with bedroom furniture. The standard also does list out criteria for what would be considered a furniture item within scope. So that's going to be freestanding height of at least 27 inches, mass of at least 30 pounds, and an enclosed storage volume of at least 3.2 cubic feet. The CSU must meet all of these criteria in order to be considered within scope. If it fails to meet or doesn't meet any one of these criteria, it is not subject to the requirements. You'll also see here the consumer product definition at 15 USC section 2052-A32. So that's going to be the Consumer Product Safety Act. The definition states that a consumer product is a product that is intended for the personal use consumption or enjoyment of a consumer in or around a permanent or temporary household or residence, a school in recreation or otherwise. I wanted to point this out to you because the definition includes the phrase permanent or temporary household. Therefore, when we're talking about CSUs that could be within scope of this rule, you're talking about furniture that's intended for hospitals and hotels, they could be considered within scope if they meet the criteria listed here. Here are a couple of examples for what is in scope and out of scope. These examples are found in ASTM F2057-23. So the in scope examples we have are chests, drawers, armoires, bureaus and dressers. Things that are considered out of scope because they don't meet the criteria are going to be bookcases, office furniture, built-in units and chlorine storage chests as defined in ASTM F2598. Note specifically for built-in units, the tip-over kit that is required to be accompanying the CSU is not a consideration for built-in. We've come across our first polling question here. So the question is, are removable totes considered an extendable element? Alrighty, and let's see where everyone's at. Looks like most everyone has answered no. And that is correct. The definition for extendable element which is found at section 3.1.6 of ASTM F2057-23 specifically excludes bins. And so totes would be similarly excluded from this definition. Our next question here, can storage behind doors be considered an extendable element? Alright, and let's see where everyone's at. Looks like most people have answered yes. There's a significant number of people that have answered no. The answer here is actually going to be yes. They can be considered an extendable element. Examples of such will be pull-out or sliding shelves. These are considered extendable elements and they can be behind doors. Are CSUs with casters or wheels subject to 16 CFR Part 1261? Alrighty, and it looks like most everyone has answered yes. And that is correct. Casters are not a criteria to determine whether the product is within scope. For the purposes of testing, casters can be chalked or otherwise locked to prevent movement during testing as long as it does not impact the actual testing. And now I will hand things over to Carolina. Thanks, Stefan. Hi, my name is Carolina Abraham. I am a compliance officer for the Regulatory Enforcement Division within CPSC's Office of Compliance. In my portion of the presentation, I will provide you with a high-level overview of the regulatory requirements for CSU, as well as other applicable requirements to include lead in paint, requirements specific to children's products, and certification. I will also take a moment to discuss key distinctions between general use products and children's products. There are several requirements to the mandatory safety standard for CSUs, or ASTM F2057-23. First, the standard requires that an anti-tip device must be included with each item of furniture covered under the scope of this safety specification for attachment by the consumer. The provided anti-tip device shall meet the requirement of specification F3096. My colleague, Kristen, will discuss the remaining regulatory requirements on this page in further detail after my presentation. This will include the test procedure to evaluate interlock system for units that have an interlock, the three stability tests to address CSUs tipping over, and the warning requirements. In addition to the mandatory standard requirements, CSUs must not contain a concentration of lead greater than 90 parts per million in lead or any similar surface coating. Metal furniture articles but not metal children's furniture bearing factory-applied lead coatings are exempt from the regulation and require no cautionary labeling. The applicable citation must be documented in the certificate and I will go over the requirements for the certificate in the coming slides. I will now take a moment to expand on children's product as there are additional requirements for this category. A children's product is a consumer product designed or intended primarily for children 12 years of age or younger. Products for children older than 12 are considered non-children's products or how we refer to as general use products. The following bullets are factors considered by CPSC to determine if a product is a children's product or a general use product. First, the stated intent by the manufacturer. This can include any labels on the products. Second, the marketing and promotion that is utilized. Third, common recognition of the product by consumer. And fourth, the age determination guideline issued by commissioned staff. A guideline PDF and additional details are available for your viewing in the link displayed. Please note that some products may be intended for use by consumer of all ages, including children 12 years or younger. Such items would be considered general use products. If the CSU is considered a children's product, the CSU must meet the lead content and tracking label requirement. Lead content levels for children's product are different from the level set for lead in paint or surface coatings. For lead content, the product must not contain more than 100 parts per million of total lead content in accessible parts. This does not apply to inaccessible or internal parts of children's products. Additionally, it does not apply to wood and engineered wood products if they are untreated. More information on these exemptions is available under 16 CFR part 1500 and 16 CFR part 1252. A tracking label shall be affixed to the product and its packaging and provide certain identifying information. Tracking labels must contain certain specific information, including the manufacturer or private labeler name, location and date of production of the product, detailed information on the manufacturing process such as the model and any other information to identify the specific source of the product. Every domestic manufacturer or importer of a CSU is responsible for issuing a certificate of compliance demonstrating that they meet the rule based on testing. General certificate of conformity or GCC is required for a general use product, children's product certificate or CPC is required for a children's product. The product certificates do not have to be in a specific template or format but must contain the seven elements for a CPC. These elements and illustrative examples of certificates for various products can be found in the links displayed. Now, this is important. Certificates must be made available to the CPSC within 24 hours upon its request. In general, all children's products must be tested at a CPSC accepted third-party laboratory. Again, the testing serves as a basis for a company to certify that a children's product is compliant to each applicable safety rule. You can find the complete list of labs using the link displayed in which you can narrow the listing by region or testing scope. Testing is required during the following events, the initial certification of the CSU upon a material change. Now, this retesting can be on the component material or finished product and thirdly periodic testing. For the most part, periodic testing is required annually for children's products. Lastly, if a CSU is subject to an investigation and it meets the mandatory requirements, no corrective action will be warranted. If a violation is determined, the corrective action will vary on a case-by-case basis. They may include a stop sale, reconditioning of inventory, and or destruction. The corrective action may warrant a recall, consumer notification, and a CPSC approved remedy is provided. So, this concludes my portion of the webinar. I will now hand it over to Stefan. All right. Here's another polling question for you guys. Is there a stockpiling provision for the new CSU rule? And let's see where everyone's at. Looks like we're pretty even here, but most people have voted yes. And the answer here is no. Neither sturdy nor CPSC's final rule at 16 CFR Part 1261 include any stockpiling provision for products manufactured on or prior to the effective date. However, in the interest of public safety, CPSC staff does encourage the sale of products to be compliant with the new rule as soon as possible. Products may still be subject to corrective actions if CPSC staff determines that they present a substantial product hazard, otherwise known as a defect, per 16 CFR Part 1115. The definition of a substantial product hazard does include the consideration of the number of products that are distributed in commerce, which would include any products in the firm's warehouse or retail shelves not just sold to consumers. The next question here can counterweights or other stability features be sold separately to consumers. Okay, looks like most everyone has responded no. They're correct. Preassembled CSUs must have the stability features already installed. Stability features for CSUs that are ready to assemble by the consumer must not be offered as a choice or option during purchase. So basically the invoice shouldn't list it as a separate item. It shouldn't be a separate item on a receipt or anything like that. However, it can be shipped in a separate package for transport purposes. Now I'm going to hand things over to Kristen. Thanks, Stefan. Hi, I'm Kristen Telcott and I'm an engineer in CPSC's Human Pactors Division and the project manager for a clothing storage unit rulemaking and clothing storage unit related voluntary standards work. Today, I'm going to provide you with a brief overview of the testing in the rule. This will be a high-level overview. I encourage you to refer to the ASTM of 2057-23 standard for details on how to conduct testing. First, I'm going to discuss the test to evaluate interlock system, which is in section 9.1 of the standard. An interlock is a component that restricts simultaneous opening of extendable elements, for example drawers and pull out shelves or doors. The goal of this test is to evaluate whether an interlock system is effective, but it's important to note that interlocks are not required in the standard. For the interlock test, the interlock is engaged by opening an extendable element or the number of elements necessary to engage the interlock. A 30-pound pull is applied on each interlocked element if the interlocked elements do not open or if they open or if they close the already opened element when they open and they meet the other interlock requirements in the standard, the unit can be stability tested with the interlock engaged. The picture in this slide shows the unit with an interlock on each column of drawers. The interlock is engaged when one of the drawers in the column is opened. The test is conducted on all possible combinations of extendable elements connected to the interlock. This picture shows a pull on the top drawer. You would also pull on the drawer below that then repeat testing with the other drawers opened. The standard includes three stability tests, the simulated clothing load test in section 9.2.1, the simulated horizontal dynamic force test in section 9.2.2 and the simulating a reaction on carpet with child weight test in section 9.3.3. To meet the stability requirements, the unit must not tip over or be supported by a non-support element when subjected to each of the tests. The simulated clothing load test is conducted with all doors open and all available extendable elements extended. If more than 50% of the storage volume is extended, the unit is filled with a clothing representative load. This load is based on the storage volume which is calculated in section 5.4 and includes extendable elements and non-extendable enclosed storage. The load calculations and distribution are detailed in section 8.3 of the standard. If less than 50% of the storage volume is extended, for example, for a unit with an interlock system that meets the interlock requirements, the unit is tested empty. The picture on the left shows testing of a unit that does not have interlocks. All the drawers are open, which is more than 50% of the storage volume extended. You can see the weight bags for the clothing representative load in the drawers. The picture on the right shows testing of a unit that has an interlock on each column of drawers. One drawer per column is open, which is less than 50% of the storage volume extended, so this unit is tested empty. The simulated horizontal dynamic force test is conducted with all doors open and all available extendable elements extended. A 10-pound pull is applied on the highest extendable element or door at or below 56 inches. The unit is empty for this test. There's a separate test method for force application on an extendable element and force application on the door with handle or pull. The picture on the top shows testing on the drawer. The pull is on the top edge of the drawer because it's higher than the pull area and both are below 56 inches. If the top edge of the drawer was above 56 inches and the pull area was at or below 56 inches, the force would be applied to the pull area instead. The picture on the bottom shows testing on the door handle. The door is in the position most likely to cause the unit to tip over and the pull is applied in the direction of initial outward motion. The simulating a reaction on carpet with child weight test is conducted with all doors open and all available extendable elements extended. The unit is angled to simulate the effective carpet by placing a test block under the rear legs. A 60-pound test apparatus is applied to the extendable element or door most likely to cause tip over. As with the simulated horizontal dynamic force test, this test is conducted with the unit empty. The standard includes specific dimensions and other features for the 60-pound test apparatus which are detailed in section 8.2.2 and the test block which are detailed in section 8.2.3. The picture on the left shows testing for a unit with an interlock on each column of drawers. The test apparatus is applied to an open top drawer because it's the extendable element most likely to cause tip over for this unit. The picture on the bottom left is a close up of the test block under the rear leg of the unit. The picture on the right shows testing for a unit without an interlock system. The test apparatus is applied to the top drawer because it's the extendable element most likely to cause tip over for this unit. The picture on the bottom right is a close up of the test block under the rear leg of the unit. I didn't include a picture here, but you can also apply the 60-pound test apparatus to a door if that's the component most likely to cause tip over. In that case, the test apparatus is applied so that the outer edge of the test weight is flushed with the outermost upper corner of the door. That concludes my overview of testing. I'll now hand it back to Stefan. Thanks, Kristen. We have a couple more polling questions here. Are fill weights used in all three stability tests? It looks like most everyone here has answered no. And that is correct. Only the simulated clothing load test at section 9.2.1, so that would be the first stability test, references fill weights. The other two stability tests are conducted without the use of fill weights. Is the test block used in all three stability tests? Looks like most people have answered no. And that is correct. Only the simulating a reaction on carpet with child weight, that would be the third stability test at section 9.2.3, uses the test block. The other two stability tests are conducted without this test block. I'll hand things back over to Kristen. Thanks. Now I'm going to discuss the warning requirements in the rule. The required warning has three main components, the single signal word panel, the warning message panel, and the safety symbol panel or panels. The signal word panel is shown at the top of the example label on the right. It includes the safety alert symbol, which is the triangle with the exclamation point, and the signal word warning. The warning message panel is the part with the warning message text. The specific text varies depending on the design of the unit. For example, there's a statement for units not designed to be used with TVs, which is shown in the example on the right. If a unit is designed to be used with a TV, that statement would be replaced with an alternate statement addressing TV use. The example also includes a statement that is specific to units with interlocking drawers. If the unit does not have interlocking drawers, the statement would be removed. There is also an additional required warning for certain units that have interlocks that can be disengaged, which is not included in this example. There are two potential safety symbol panels in the warning. All warnings are required to include a safety symbol panel with the child climbing prohibition symbol, which is the symbol shown on the top in the example. Units that are not designed to be used with TVs also need to include a second safety symbol panel with the TV prohibition symbol, which is the symbol shown on the bottom in this example. The ASTM F-257-23 standard has specific requirements for format of the warning, including font types, colors, and size, but there is flexibility in layout. You could, for example, make a shorter, wider label than the example here by putting the safety symbol side by side instead of stacked. The ASTM F-257-23 standard also includes additional examples of warnings. You should note that there are some minor differences between the examples provided in the standard and the required text. You should always follow the required text for your warning. In addition to what I just discussed, the ASTM F-257-23 standard allows customization of some of the warning statements to make them more applicable to the specific unit. For example, for the statement, never allow children to stand, climb, or hang on any drawers, doors, or shelves. It is permissible to exclude any feature that's not included on the unit. The standard also requires the warnings be in a conspicuous location when in use, as defined in section 10.1.1. This includes specific placement within the drawer or behind the door. And there's also an informative appendix X3 that contains best practices for warning location. Warnings also need to make permanency requirements. Section 9.3 provides specific tests for paper labels, non-paper labels, and warnings applied directly to the surface of a product. That concludes my overview of warnings. I'll now hand it back to Sethan. Thanks. So we have a couple more polling questions here. Is there a requirement for hang tag or other labeling? Okay. It looks like most have answered yes. The answer to this one is no. The new CSU rule pursuant to sturdy does not include a requirement for a hang tag or any labeling outside of what is prescribed in ASTM F2057-23. The old CSU rule, which is superseded with the adoption of this ASTM standard, did have a hang tag and additional labeling requirements. And then the last polling question here. Can my warning look different than the examples that are used in ASTM F2057-23? Looks like the votes are a little split here. Most people have answered yes. The answer is yes. There are some caveats to consider, however. Any formatting is acceptable as long as it follows the formatting outlined in the ANSI Z535.4 standard as well as whatever is prescribed in ASTM F2057-23. There are also minimum sizes for the icons, panels, and text, which are noted in section 10 of the ASTM standard. As Kristen pointed out earlier, there are some minor differences from the label example pictures and the prescribed text. So definitely pay close attention to the prescribed text in section 10. All right. So we're getting close to the end of our webinar here. Here's a couple of resources that you guys might find helpful. CPSC's CSU business guidance page is up. It contains kind of condensed information with hyperlinks to all of the additional information that may be applicable to CSUs. ASTM's reading room for any ASTM standard that is made mandatory, usually incorporated by reference, such as ASTM F2057-23 are available through ASTM's reading room through that link. And of course, we have our business education playlist on YouTube where a recording of this webinar will be posted along with any other webinars that CPSC has recorded and posted there. So after this webinar, if you'd still like to submit an inquiry or you find out you have a question after this webinar has closed, always feel free to contact a small business ombudsman. Our contact form is available online at cpsc.gov slash sbo contact. You can give us a call toll free at the number provided there. And you can also give an email us at sbo at cpsc.gov. If you'd like to receive any notices for future webinars that we might be doing, in addition to additional business education information, we do send out a monthly newsletter, roughly monthly. You can subscribe to this newsletter at cpsc.gov slash newsroom slash subscribe and click the box for business education. As I noted earlier in the webinar, please submit questions through the questions tab on your go to webinar dashboard here. We do have a couple of questions that have come in here. One here is, is there a warning file accessible for download? So unfortunately, we don't have one. Those warning examples are ASTM. So you can take a look at what the ASTM standard has in their standard. Again, go to that ASTM reading room for a read only view of those warnings. But be warned that the images that they're using do have slight differences and issues that differ from the prescribed text. Sometimes they even have filler text in there. So definitely take care to follow whatever text is in section 10. Here's a testing question here. Does the test apply to elements extending the furthest from a case, such as a case with hidden drawers behind doors? So I'm assuming this is talking about just any extendable elements that could be behind doors here. Christine, could you answer that one? Yeah, so the testing does include testing of extendable elements that are behind doors. The testing is generally conducted on the extendable element or other component that is most likely to cause tip over. And when I'm talking about testing here, I'm talking about the application of the 60 pound test apparatus. So if there is an extendable element behind the door that extends further than others or just an extendable element in general that extends further, you would generally test that component. Thanks. Here's a question about the label. Can we speak more in detail about the label being permanent, yet being able to rip and shred when trying to remove the label without a tool or solvent? The standard does say that the label must still be legible. So how can it be legible if the label rips? Christine, could you turn on that one? Sure. So the test methods for permanency of labels and warnings are in section 9.3 of the standard. And it does prescribe specific testing for paper labels as well as non-paper labels and a separate test for warning supply directly to the surface of the product. I would follow these specific requirements within the standard and the test method. But if you have additional specific questions like about a very specific label or specific test results, I would definitely contact the SBO. Here's a question on tags. May hang tags be used in addition to applied tags in the specified locations per the ASTM standard? Technically, yes. We can't really prohibit or prescribe anything that's different from the ASTM standard. At minimum, as long as you have the warning and it meets all the other requirements of the ASTM standard, any additional things like a hang tag on it would be okay. Question here. Can we go over the 27-inch requirement and does a nightstand need to meet all three requirements? So this is going to go back to the criteria question here. So when we're talking about CSUs, we're talking about furniture items that meet all of the criteria. So 27 inches is going to be one of those criteria. If the nightstand in particular is shorter than 27 inches, then it doesn't meet one of the criteria. Therefore, it's already out of scope. If the nightstand is above 27 inches, you'll have to see if it meets the other criteria. So that's going to be right here. So does it have a mass of at least 30 pounds? Does it have an enclosed storage volume of at least 3.2 cubic feet? If it meets all these criteria, then it's subject to 16 CFR part 1261. Then it needs to be tested and ensure compliance to the ASTM standard. Question here says, ASTM has identified some labeling mistakes that won't be corrected until they update the standard. Will CPSC enforcement allow labels with the same mistakes? This is kind of a tricky question. If the labels are so bad that they look different, that definitely would be an issue. Compliant staff would probably handle this on a case by case basis, but definitely make sure that your labels are following the prescribed language as opposed to the warning label examples, the image examples in the ASTM standard. Question here says, Are retailers required to change over all stock on floor immediately to the new standard once goods are available? The answer to that is no. There's no stockpiling requirement. Technically, those are manufactured, likely those are manufactured prior to the effective date, so they are considered out of scope. Further stuff that's usually on the floor may not actually be sales units. So that's a whole different question there. But again, referring back to the polling question that we had earlier, CPSC staff do kind of want the companies to make sure that anything that they're selling, regardless of what the manufacturer date is, to be compliant with the new rule as soon as possible. Again, there may be a consideration that the product is considered a substantial product hazard because it doesn't meet ASTMF 2057. Question here, is the volume of a drawer being held closed by an interlock used in the calculation of total extendable volume? I think Kristin, can you handle that one? Sure. Yeah, so the volume calculations are conducted as a separate section in the section describing the testing. And I would follow the instructions there for calculating the volume of the drawer, but generally it doesn't really matter if during testing that drawer is closed or open, you're going to calculate the volume and that volume is going to apply towards a total storage volume, regardless of whether it's extended or not extended during the test. When you fill drawers for a unit with interlocks during that first stability test, you will fill drawers that are if more than 50% of the story volume is extended, the fill will be in drawers that are both extended and closed for that testing. Thanks. So the question here, how is this different from F2598? I'm not sure which standard that one is. We'll definitely get back to you on that one. Can we get a copy of this PowerPoint? Yes, the slide deck will be PDFed and distributed to all attendees after this webinar. The reason we didn't hand it out ahead of time was because there were these polling questions and they had the answers on those pages, so we just kind of wanted to hold that off, but all attendees will be provided a copy of these slides. Question here, I assume for built-in, do the straps screwed to the back of a chest count for meeting the test standards? That would depend on how the straps look, how they're functioning, how they're advertised, and things like that. Built-in units are kind of going to be unfortunately have to be evaluated on a case-by-case basis. There's a multitude of factors that will be considered for what's considered built-in and therefore permanently attached to the building. Again, tip-over kits are not considered built-in, so by straps you're talking about the tip-over kits. Those will not be considered built-in and they will be subject to the stability test. And as a reminder, the stability test must be conducted without the use of these tip-over kits. Is there a testing question? What should be done if a drawer glide breaks during testing? Kristen, could you handle that one? Sure, and I apologize. I'm not sure I can provide specific answer for this at this time, but I believe the standard allows for securing a component that has failed during testing if it can't support the weight. But don't quote me on that because I am not positive that that is the exact wording that's provided in the standard. Thanks. Here's a question. What will CPSC's view be towards nightstands that are slightly shorter than 27 inches by manufacturers who may be trying to get around the standard? Can't really comment on the intent for these manufacturers of getting around the standard, but the criteria for CSUs is pretty clear. Again, here they are on the page, height of at least 27 inches. So if they're anything shorter than 27 inches, then they're considered out of scope. They're not subject to 16 CFR Part 1261. Here's a question about the label for a unit with an interlock drawer system, 10.2.3.10 states the warning label shall be added to each drawer in a location near the interlock hardware. For example, if I have a dresser with six drawers, it seems redundant to place six identical interlock warning labels on each drawer box next to the interlock tab. Can I use just one? So I believe you're referring to the specific warning label for units that have interlocks that can be disabled. And in that case, you want to be able to provide the warning on each of the drawers that that pertains to. So that might be all the drawers in the unit. So that's why that specific label for that specific type of unit with interlocks that can be disabled requires the use of the warning label in each drawer. I don't believe that provision applies the general warning label, which was the bulk of what I was discussing in the warning section. If we make custom furniture, do we need to keep a certificate on file for each individual CSU sold? This depends. If each of your furniture items are similar enough and the stability testing that was conducted on the one unit can be applied to show compliance to the other units, then you only need that one certificate. It would be up to the manufacturer or the responsible party to determine what's going to be adequate information to show that whatever testing they've done can apply to the other furniture items. Is it okay to apply a label to a unit that states sturdy compliant or ASTM F2057-23 compliant? Technically, I believe that would be acceptable. There's no prohibition to it, nor is there really a requirement to indicating compliance statements. You cannot, however, say anything like CPSC approved or something along those lines. Where can testing be performed? So this depends on whether your product is going to be a children's product or a general use product. Children's products have to be third-party tested. We discussed that previously, so you do have to use one of the testing laboratories that are on our website. If you go to... That's the wrong slide here. If you go to the link, cpsc.gov, slash lab search, you'll get a list of all the CPSC accepted laboratories that can conduct this testing. I can't say that there are laboratories that are accredited to conduct testing to 16 CFR 1261 already, so feel free to prove that. If it's a general use product or a product that's intended for all ages, then the testing can be conducted by the manufacturer, by the importer, or any non-CPSC accepted laboratory. They would just need to document the testing and the results and things of that nature. What does that look like? Well, that's going to depend on how much proof the firm thinks they need in order to show that it's being tested and compliant. Ultimately, it would be up to them to figure out how detailed they should be in their documentation. Are there any plans to extend this ruling to other furniture such as sideboards or credenzas? We can't speak to any future rulemaking at this time, but definitely keep an eye out on CPSC's federal register notices. That's where we'll post any kind of notices of proposed rulemaking where people can stay up to date on any rulemaking that is either being proposed or finalized. Are there guidelines around resale of returned CSUs manufactured prior to the deadline in a retailer's outlet? Again, the scope of the CSU rule is pretty clear. It's going to be products that are manufactured after September 1st, 2023. Resale is going to add a separate layer of consideration, so between the time period that the product was returned and resold, was there any changes made to the CSU or is it being just kind of resold as those would be considerations as to whether now the product is being just resold or is it being refurbished and then resold, which in the case of refurbishing, that probably would be considered newly manufactured so that it has a new manufactured date, which means it's going to be subject to the requirements. Is there a place to source the 60-pound testing apparatus without building it ourselves? I believe you're just going to have to build that yourself. The standard does provide dimensions for the testing apparatus. You may ask around to other sources, such as testing laboratories, see if they'll lend it out to you, but that's something that you can kind of ask around to see if it's available. Here's a question, who is liable for compliance? So all of our regulations, the responsible party is going to be the domestic manufacturer or the importer record as far as compliance to the testing and certification requirements. Consumer Product Safety Act does state that the introduction into commerce for a non-compliant product is a prohibited act. So distributors and retailers do have some obligation to ensure that the product that they're receiving is going to be compliant. That's usually making sure that any products they receive come with a certificate if it's necessary, making sure that they're maintaining copies of such certificates for their own record-keeping purposes. And obviously, all firms have a reporting obligation under Section 15b of the Consumer Product Safety Act, where if they find information or if they come across information that their products, whether manufactured or imported, doesn't meet the applicable requirements, then they have to report to the CPSC. That report can be made at saferproducts.gov and we always encourage companies to register. Here's a question, will a vanity need to be tested? Again, this is going to depend on whether the vanity specifically meets the criteria for a clothing storage unit. So run down that list, run down that criteria, and if it checks off all the boxes, then yes, it's a CSU that is subject to 16 CFR 1261. Here's a question, are units attached to walls with an L bracket considered freestanding units? As discussed previously, freestanding or built-in, that terminology is typically going to be have to be evaluated on a case-by-case basis. You can always contact the SBO separately and we'll kind of be able to go into a little more detail with that one. But ultimately, it would be up to the firm to be able to defend why they believe the product is either freestanding or built-in and be able to kind of defend it. Should there be a question, we at the SBO are always going to advise firms to kind of err on the side of caution. If there's a chance that the product would be considered freestanding and subject to these requirements, go ahead and test it that way you're covered no matter what. Here's a question, if a product has glass doors with drawers underneath and the drawers meet the cubic storage and the item meets the other criteria to be a CSU, would this item be a CSU even though glass doors are present? So the consideration for glass doors is only going to be for closed storage. So basically anything behind a glass door would not be considered closed storage, but because there are drawers underneath and if then that causes the storage volume or the closed storage volume to be above 3.2 cubic feet, it would meet that particular criteria. You would then assess whether the other criteria are being met and if they're all being met, then yes, it is a CSU that would need to be tested. What are the requirements or tests for the anti-tip kit? The ASTM F2057, oh okay, Kristen, you can speak to that one. Sorry, I think Stefan was on his way answering it already. The requirements for the anti-tip kit included with the CSU are in a separate standard that's ASTM F3096 and I believe that is available for viewing. I apologize, it's not available for viewing, but it does have separate test requirements specific to the tip restraint. The current version of that standard includes a 60-pound pole on the restraint, but there are other requirements in there as well. Thanks. We build using six different types of hardwood. Can one GCC cover all the wood types for the same piece? This is going to be a tricky question to answer. The short answer is yes, one GCC can cover all those wood types. However, one test may not be enough. So depending on what types of hardwood you're using, they may have different densities and therefore different weights, which means now the stability tests can be impacted because of the different types of wood. So you will at minimum would need to cover to test either all six different types of hardwoods or show why one hardwood is compliant from testing off a different hardwood. Maybe show that the weights are exactly the same or something along those lines. Can you clarify the metal furniture exemption for lead in paint? This is actually written in the CFR, so the citation 16 CFR section, 1303.3C is where you would go for this one. So metal furniture articles which excludes children's products, so any children's furniture is not afforded this exemption. Metal furniture articles bearing factory applied lead coatings are exempt from the regulation and require no cautionary labeling. The cautionary labeling is referenced here because there are some exemptions to the lead in paint requirement. If it has this cautionary labeling, but this particular exemption for metal furniture articles would not require that cautionary labeling and they would not be subject to 1303. All right, well we're running short on time here, so we're going to wrap things up a little bit. If don't worry if we didn't answer your question, we'll go over all the questions and make sure we'll respond back to you and be able to reach back out to you. Again, here's our contact information with our online contact form, our phone number, and our email address. And again, you can subscribe to our business education newsletter using that link there. I hope this was informative and thank you guys for attending.