After years of back-and-forth debate, a tipover stability rule for clothing storage units is set to go into effect on Sept. 1, 2023. That is, “unless the Commission receives a significant adverse comment by June 5, 2023.”

The rule, which is based on the industry-backed ASTM F2057-23 voluntary standard, was approved on April 19 by a 3-1 vote by the Consumer Product Safety Commission. The CPSC commissioners found that the standard met the requirements of the STURDY legislation signed into law by President Biden in December 2022. 

The May 4 Federal Register stays the implementation of a CPSC rule that was set to go into effect on May 24.

The ASTM F2057–23 rule applies to “free-standing clothing storage units, including but not limited to chests, chests of drawers, drawer chests, armoires, [chifforobes], bureaus, door chests, and dressers, which are 27 in. (686 mm) or greater in height, 30 lb (13.6 kg) or greater in mass, and contain 3.2 ft 3 (90.6 dm3 ) or greater of enclosed storage volume.” ASTM F2057–23 sec. 1.1.

The standard “does not cover shelving units, such as bookcases or entertainment furniture, office furniture, dining room furniture, jewelry armoires, underbed drawer storage units, occasional/accent furniture not intended for bedroom use, laundry storage/sorting units, or built-in units intended to be permanently attached to the building, nor does it cover `Clothing Storage Chests' as defined in Consumer Safety Specification F2598.” ASTM F2057–23 sec. 1.2.

Testing requirements

STURDY requires tests that simulate the weight of children up to 60 pounds, and ASTM F2057–23 has a set of three stability tests to simulate the capability of a child weighing up to 60 pounds interacting with a CSU. The first stability test, Section 9.2.1 Simulated Clothing Load, loads drawers with simulated clothing loads. The CSU must not tip over with all doors and extendible elements (movable load-bearing storage components including, but not limited to, drawers and pullout shelves) open. Staff assessed that it would be reasonable to conclude that a child weighing up to 60 pounds would be able to open loaded drawers and that the Commission could conclude that this is a test that simulates the weight of children up to 60 pounds.

The second stability test, Section 9.2.2 Simulated Horizontal Dynamic Force, applies a 10-pound horizontal force over a period of at least 5 seconds at a “hand-hold” not to exceed a 56-inch height, and then holds the force for at least 10 seconds. The Staff Briefing Package cites a study that found the elbow pull strength of children 2 to 5 years old to be in the range of 6.14 to 26.0 pounds. Staff assessed that the Commission could conclude that this second stability test simulates the pull force of children up to 60 pounds.

The third stability test, Section 9.2.3 Simulating a Reaction on Carpet with Child Weight, uses 60 pounds of weight placed on the edge of an open drawer or pull-out shelf, while the CSU is tilted forward using a 0.43 inch test block to simulate placement on a carpeted surface, with all doors and extendible elements open. Based on the requirements of STURDY, staff assessed that the Commission could conclude that this is a test that simulates the static weight of children up to 60 pounds.

STURDY also requires “objective, repeatable, reproducible, and measurable tests or series of tests that simulate real-world use and account for impacts on clothing storage unit stability that may result from placement on carpeted surfaces, drawers with items in them, multiple open drawers, and dynamic force.” STURDY sec. 201(c)(2)(B). Staff noted that the ASTM F2057–23 test methods describe the steps to take, specifications for test apparatus, load, dimension, and tolerances for dimensions and loads, all of which are consistent with accepted practices. Because all of these test methods are specified in the ASTM standard, staff assessed that the Commission could conclude that the tests in ASTM F2057–23 are objective, repeatable, reproducible, and measurable.

The CPSC staff assessed that the ASTM stability tests utilize tests or a series of tests that represent real-world conditions. For example, section 9.2.1 Simulated Clothing Load tests the CSU with multiple open and loaded drawers on a flat surface. Section 9.2.3 of ASTM 2057–23, described above, is a stability test that simulates placement on a carpeted surface with open drawers. The use of a 0.43-inch thick test block (as specified in section 8.2.3) is consistent with the carpet simulation in CPSC's final CSU rule. See 87 FR 72636. Staff assessed that the Commission could, therefore, conclude that ASTM F2057–23 includes a stability test that simulates interaction with a CSU on a carpeted surface, which is a real-world condition.

Section 9.2.1 of the ASTM standard, Simulated Clothing Load, is a test conducted on a hard, level, and flat test surface with extendible elements and doors open and, if 50 percent or more of the storage volume is extended, the unit is to be filled with a “simulated clothing load.” The fill weight in extendible elements is calculated using a density of 8.5 pounds per cubic foot of volume, which is the same density used by the Commission in its November 2022 rule. 

See87 FR 72610–11. All extendible elements are opened and must remain open for 30 seconds without tip over. Based on this test, staff assessed that the Commission could conclude that ASTM F2057–23 includes a test that simulates drawers with items in them and multiple open drawers, which is another scenario reflecting real-world use.