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Comments in Response to the Direct Final Rule Proposed by the Consumer Product Safety Commission: Revisions to Safety Standard for Infant Bath Seats

Re: Revisions to Safety Standard for Infant Bath Seats, Docket Number CPSC-2009-0064

In NCLA’s view, the Proposed Rule continues an odious trend of incorporating private standards into the law only by reference, thereby hiding the binding law behind a paywall. The Proposed Rule is therefore unconstitutional and must not be enacted as written. This comment is intended to serve as a significant adverse commentary, which should require CPSC to withdraw the Proposed Rule. 

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October 21, 2019