Excerpts
Incorporation by Reference
Comments:
The Commission received comments from Otteroo regarding the agency's incorporation by reference of existing standards. Otteroo stated that referencing non-toy standards contradicts the toy determination. Otteroo questioned why the Commission did not adopt EN 13138-1:2021, requested further clarification on how ANSI/CAN/UL 12402-9:2022 or ANSI/APSP/ICC-16 2017 was determined to be relevant to neck floats, and urged the Commission to reassess the applicability of the standards that are incorporated by reference. Consumer