Response 445549698

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Introduction

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Consultation Paper questions 1-3

1. Do you agree with the definitions, exceptions and categorisation of Infant Sleep Products, Inclined Sleep Products and Inclined Non-Sleep Products? Please explain your answer.

I do, I think the key risk is that marketing can imply an item is safe for sleep and even if there is a disclaimer on the box or product iteself, people will still use it for sleep.

2. Do you have any additional comments on the risks associated with Infant Sleep Products? Please explain.

I believe they are not widely understood due to a lack of information about positional asphyxiation

3. Do you have any data about injuries or fatalities caused by Infant Sleep Products, Inclined Sleep Products or Inclined Non-Sleep Products? If so, please provide it to the ACCC.

No.

Consultation Paper questions 4-14

4. Which of the proposed options do you prefer and why?

I prefer "Interim or permanent ban, or both" on inclined sleep products. Voluntary standards will be ignored until there are fatalities (as with portacots currently) and while these products are available, people will continue to purchase and use them without understanding the serious risks of harm.

For inclined non sleep products I think information on the products is sufficient, but there needs to be very strict penalties for businesses who try to remarket inclined sleep products as non-inclined.

5. Do you think there any other options not included in this Consultation Paper the ACCC ought to consider and why?

Broader education campaign about the risks. Red Nose is not explicit about the 'why' behind its recommendations.

6. What are the likely costs to implement the requirements for each option for industry? Please outline how this would impact the price and availability of products for consumers.

N/A

7. How many units and product lines do you anticipate would be affected by each option?

N/A

8. Where possible, please provide further information about the likely costs or impacts for each of the proposed options.

N/A

14. Would you prefer a permanent ban on Inclined Sleep Products with an incline angle of greater than 7 degrees to continue once the proposed mandatory standards in Option 7 came into force, or that such products be incorporated into such mandatory standards and the ban revoked? Please explain.

Permanent ban per the recent USA decision. As long as these products are available, marketing will imply they are safe for sleep. Even if marketing is cracked down on, people will continue to use them for sleep.

Consultation Paper questions 15-19 (Mandatory safety standard - Household cots)

15. Which of the proposed options do you prefer and why?

Overall the household cot guidelines are good in that they are mandatory, but dropside cots should be banned ASAP (and reselling second hand also banned, with a clear/harsh media campaign about why).

Consultation Paper questions 20-25 (Mandatory safety standard - Folding cots)

20. Which of the proposed options do you prefer and why?

Mandatory requirements must be introduced ASAP and unsafe products recalled/banned etc. Portacots are widely misused and the risks misunderstood.