Bumbo Baby Seat: An example of an ineffective Corrective Action Plan

The effectiveness of consumer product recalls continues to raise concerns among product safety professionals.  While it is important to announce these recalls to the public, that is really only the tip of the iceberg as a response to addressing the safety issue itself.  In addition to posting recall posters in retail stores, issuing press releases and advising consumers via phone, email or postal service, companies involved in a recall are required to prepare a Corrective Action Plan (CAP).  This CAP is intended to get defective products off the shelves and out of consumers’ hands as quickly and effectively as possible.  Any good CAP includes a resolution that addresses how the company will make sure that the safety hazard is completely resolved and results in a safer product for consumer use.

Here’s the problem – not every CAP is effective.  It’s true that the nation’s foremost safety authority, the Consumer Product Safety Commission (CPSC), is responsible for “approving” these action plans.  It is also true that not every approved plan results in safe products.  The CPSC must work within the confines of the law; so unless the product violates some rule, ban, standard or other regulation enforced by CPSC, a poorly designed product that has the potential to create injury through consumer misuse may continue to be marketed.

This is the case in a childcare product known as the “Bumbo Baby Seat.” Manufactured in South Africa, the seat is molded with dense foam that snuggles the infant into place without the use of seat belts or safety restraints.  The manufacturer intends for the product to be suitable for children 3 to 14 months of age, and to be used on a flat floor surface only.  They also clearly identify the safety concerns right on the product packaging:

“May not prevent release of your baby in the event of vigorous movement.”

"WARNING - Prevent Falls; Never use on any elevated surface." 

This is an example of a moment that any product designer and manufacturer should stop and think BEFORE placing such an item on the market. What is the health/safety risk(s) to the child if the consumer does not use the product as intended?  How likely is it that the consumer using the seat will use it incorrectly? Can incorporating a design or material change mitigate this safety risk?

When a manufacturer decides to use a product label to eliminate a safety risk, the result is almost always poor, and the safety of the consumer can still be at risk. 

The lack of a restraint-system in the Bumbo Baby Seat clearly creates a potential safety concern. Infants as young as 3 months of age can fall out of the seat by arching their backs, leaning and rocking back and forth or side to side. The force of these actions only increases with age. These are all perfectly normal and foreseeable actions of a developing infant.  While the manufacturer may feel the lack of a restraint system is a selling feature, a product safety professional would say is a lack of effective risk assessment, as well as a lack in understanding their customers' foreseeable habits of product use.

Today, for the second time, the Bumbo Seat is in the CPSC hot seat. In their November 22, 2011 safety alert, CPSC and Bumbo International issued an advisory, warning parents and caregivers to never use the Bumbo Baby Seats on tables, countertops, chairs or any other raised surfaces.  In 2007, over 1 million Bumbo Baby Seats were recalled due to incidents of falls from the seats. New warning labeling was mandated by CPSC before the seat could be placed back on the market.  Since that 2007 recall, at least forty-five additional fall incidents involving infants 3 to 10 months of age have been reported.  Each of these were falls from a raised surface.  The results of those falls - 14 skull fractures, two concussions and one incident of a broken limb.

Photo:www.gizmo-central.com

According to the CPSC announcement, about 3.85 million of the Bumbo Baby Seats have been sold in the United States since 2003.

A BASIC RISK ASSESSMENT Q & A for the Bumba Baby Seat:

1.  What is the health/safety risk(s) to the child if the consumer does not use the product on a flat, floor surface as intended?  HIGH RISK 

2.  How likely is it that the consumer using the seat will use it incorrectly? HIGHLY LIKELY

3.  Can incorporating a design or material change mitigate this safety risk? YES, consider a  wider, sturdier diameter base, a weighted base, a higher back, a higher front support,  and/or a retraining system – one or more of these design adjustments could help mitigate the problem.  

4.   Does labeling the product with a warning help reduce the safety risk? NOT LIKELY

Simply adding a warning label but neglecting to design-out the safety concern is an unsatisfactory resolution. The CPSC-approved Corrective Action Plan, to simply add a warning, was an example of an ineffective plan.  This second alert, aimed at reminding consumers to read the warning, is just as ineffective.

Smart consumers of children’s products MUST be proactive when purchasing goods, no matter how “cute and cuddly” the product appears.  Safety should always be the main concern. 

CONSIDER & COMMENT:

• How often & how carefully do you read the safety warnings on a product?
• Do you think ALL parents & caregivers read the warnings as completely as you do?
• How likely do think you would be to place this lightweight infant seat on a tabletop or countertop?