Below you will find an email from Vicki Reynolds of Reynolds Manufacturing with the latest information on the new crib regulations. For additional information on new crib safety standards you may visit their website here for a breakdown of the regulations form the Consumer Product Safety Commission.
In my last e-mail, I shared that I would try to find more information concerning medical grade cribs (such as Hard Mfg. cribs) in licensed childcare facilities here in Texas. I finally did get some information that I think will be helpful.
Last month, I sent an e-mail to Michelle Adams, the Assistant Commissioner of the Child Care Licensing Division in Texas. When I did not hear back from Ms. Adams, I phoned the licensing division and was given the name of Lee Roberts. I left a message for her, and she returned my call. Lee Roberts is a minimum standards program specialist with the Texas Department of Family and Protective Services (DFPS) Child Care Licensing Division (CCL). Ms. Roberts was well informed on the crib issue (although she has many other fish to fry), and very patient with all of my questions.
I sent a rough draft of this e-mail for Lee Roberts to review before sending and received her comments yesterday.
Ms. Roberts did concur that presently medical cribs are legal in childcare settings. The new federal regulations did not address cribs registered with the Food and Drug Administration (FDA) as medical devices, but only Consumer Product Safety Commission (CPSC) cribs. She also shared that this issue would be addressed as the Licensing Division makes changes to the minimum standards. Presently, it appears that Licensing is leaning towards only allowing medical cribs in centers where there is a child with medical orders for such a crib. Ms. Roberts was very open and listened to my “pro stance” on medical cribs. They have yet to make a decision concerning medical devices in licensed centers. The good news for those of you hoping not to have to replace these medical cribs is that you can have a voice in this matter.
The DFPS Council and the Health and Human Services Commission (HHSC) Commissioner will recommend rule changes to the minimum standards this summer. Child Care Licensing (CLC) is planning to present drafted revisions to the minimum standards regarding cribs at the July DFPS Council meeting. If the DFPS Council and HHSC Commissioner agree, then the proposed rules will be published in the Texas Register and any stakeholder may make comments regarding the proposed rules. New proposals will be posted from mid-August to mid-September. All registered child care providers will receive a copy of any new proposed rules by e-mail. Others interested in this process may also receive a copy by registering a http://www.dfps.state.tx.us/Child_Care/Child_Care_Standards_and_Regulations/default.asp.
On this web page, the DFPS symbol in the middle of the page indicates to “Sign up for E-mail updates”. Click the symbol to go to the sign up link.
After the public comment period, CCL will review the comments and then go back to the DFPS Council to request the proposed rules be adopted. Again, the HHSC Commissioner has the final say regarding the adoption of the proposed rules.
Just as you vote in the political arena for your voice to be heard, this is your opportunity to share why you think these cribs should be allowed in licensed facilities here in Texas. I feel confident that this matter of medical cribs registered with the FDA will be given the utmost scrutiny and thoughtful consideration in arriving at a decision that will work best in Texas licensed child care centers.
For those of you needing new cribs in your licensed facilities, I would definitely wait until the new standards for Texas become law before purchasing medical grade cribs. Of course, just because a crib is medical grade doesn’t mean that it can’t get old and worn out. If your cribs are older than 20 years, they probably do not meet current CCL standards anyway as the crib slat distance has changed in the past 20 years. Also, most companies do not sell replacement parts for cribs older than 10 – 12 years.
Please feel free to call or e-mail me with questions or concerns.
Reynolds Manufacturing Corp.
PO Box 6058
Abilene, Texas 79608