This post is in two parts. I drafted Part 1 a while ago after the Scottish government (quietly) released the full certification they hold for the box. I decided to hold off publishing it as I thought there was little else they were likely to concede. Today’s Guardian newspaper has further damaging information on the boxes so I have added a Part 2 about that.
My previous post on Are the Scottish government’s baby boxes safe? engendered a fair amount of debate on Twitter, in the middle of which two government ministers tweeted contributions:
The identical wording (including the error that the box complies with ‘BSEN11330’ – it’s actually ‘BS EN 1130’) was an eerie echo of the earlier coincidence noted at the beginning of the previous post, of an SNP MP and councillor tweeting identical praise for the pilot version of the box.
Ms Freeman bothers me not. She’s the minister for social security, has no responsibility for the baby box and blocked me a long time ago on Twitter. Her tweet was merely a copycat of Ms Todd’s.
Maree Todd is more interesting because she is the minister for childcare and early years. She attached some photos to her tweet (here) and in an exchange with someone else invited them to e-mail her if they had any further questions. On the back of that offer I decided to ask her if, as the still fairly new minister for the baby box scheme, she was able to make publicly available a copy of the BS EN certificate for the box together with the associated test results.
At this point, regular readers, not to mention the occasional nationalist who claims this blog is only ever about ‘SNP bad’, may wish to pause for breath because (a) she replied and (b) I give her unqualified praise for her openness.
This is the minister’s reply in full:
15 Jan at 2:45 p.m.
Thank you for your e-mail of 4 January 2018 regarding Scotland’s Baby Box’s safety certification.
We have previously been unable to release the BS EN Certification for Scotland’s Baby Box as our managing agent for the programme, APS Group (Scotland) had wished to protect the Intellectual Property (IP) of their box supplier who are a UK based SME.
We are now approaching the tender for year 2 baby boxes and contents and to avoid this situation arising again in year 2, I have asked that the accreditation be a mandatory part of the box specification. Accordingly, we have agreed with APS Group (Scotland) and their supplier to make the certification publicly available.
I have therefore attached the BS EN Certification for Scotland’s Baby Boxes. You will note that materials were not tested as part of this process due to the materials holding their own certification. For completeness I also attach the relevant paperwork for the materials, board and ink, used in the production of the current baby box.
I hope this reassures you that Scotland’s Baby Boxes have been awarded with British Safety Standard BS EN:1130 accreditation as a crib for domestic use.
Minister for Childcare and Early Years
A sceptic may say that Ms Todd could see which way the wind was blowing and, to mix my metaphors, was trying to lance the boil of criticism about the safety of the box. Never mind. It’s done and it’s something the civil servants wouldn’t do when responding to my previous three Freedom of Information (FOI) requests on the subject.
The government have now placed the documents concerned on their Parent Club web site (scroll down and open the section on ‘Does Scotland’s baby box meet industry safety standards?’). Parts of each document have been redacted but I’m as sure as I can be that they are of no significance in this context.
Inevitably, and I feel for Ms Todd here, the information that has been released raises further questions. For the sake of clarity in discussing them, I refer to the documents as:
- the test certificate (in relation to BS EN 1130-1:1997 Furniture. Cribs and cradles for domestic use)
- ink safety
- cardboard safety.
The second and third items refer to separate standards, not to BS EN 1130-1:1997.
It may be helpful at this point to remember the background to the question of safety raised in my previous post, the SNP’s claim on 3 August last year that the box
has British Safety accreditation as a crib
and that (in response to my previous FOIs), it:
meets all aspects of the standard applicable to it [BS EN 1130-1:1997].
Because the government then spelt out which aspects of the standard were ‘applicable’ it was possible to work out that it had not been tested for ‘materials.’ Now the test certificate confirms why it was not applicable. It was issued:
(Excluding clause 4.1 Materials at request of client).
The box could not comply with the materials requirement of the standard because that refers only to:
Despite, however, materials (the cardboard) not being tested, the test certificate then refers to two tests that were undertaken of the ‘Sides and Ends’ of the box and that it passed:
- 5.6 Strength of the structural members of the sides (bending test)
- 5.7 Strength of sides, structural members of the sides and corners (impact test)
- 5.8 Vertical static load test.
It then specifies the sort of detail that it takes a scientist to understand, for example:
The conundrum is how can you exclude testing of materials – cardboard – from the standard and then undertake, let alone pass, tests intended for wood or metal?
Perhaps to compensate for the fact that the cardboard was not tested as part of BS EN 1130-1:1997 the government have also released the documents on cardboard safety and ink safety, which state that those materials used in the box conform to ‘EN 71-3’ which the British Standards Institution describes as follows:
BS EN 71-3:2013+A1:2017 Safety of toys. Migration of certain elements.
This states that:
- if particular chemical elements in the cardboard and the ink used to print the outside of the box are present, they are only present at safe levels (and, I assume, will not ‘migrate’ to harm a child)
- cardboard is ‘paper and solid board grades intended for packaging’ (I don’t have access to the BS EN definition of packaging but a dictionary definition is ‘materials used to wrap or protect goods’, not a baby)
So in BS EN 71-3 etc. we have standards not for ‘Furniture. Cribs and cradles for domestic use’ but for toys and the packaging in which toys come. Whether this is sufficient for a box in which a baby is intended to sleep is at best a moot point.
Finally, two further potential safety issues about the boxes have become apparent to me.
First, in these photos you’ll see that like the commercial box from The Baby Box Co. on the left, the government’s box, on the right, has hand holds on the side:
Doubts were raised about the safety of the holds on the commercial version. Because there are slots/handle holds on the sides, the box was likely to be used as a carry cot which was not its intended or safe use. In particular, the edges of the handle holds could be sharp, there was a small risk of the laminate coating on the box being pulled off at the handle point which could represent a suffocation hazard, limbs could be trapped from the handle holds, and the box could be unstable. If you follow the link, you’ll see that the company both identified and resolved these problems. Whether or not any are relevant to the government’s boxes I don’t know. But it would be helpful to have a reassurance that they’re not.
Second, potential users of the box as a crib may be interested in the verdict about baby boxes of the Lullaby Trust, a charity that seeks to reduce the incidence of sudden infant death syndrome. They have produced guidance to parents who choose to use a baby box and are adamant that:
there is no safety standard in existence anywhere in the world that specifically applies to a baby box as a sleeping place for a baby. Be aware that some manufacturers state that their boxes meet European Union 1130 standard for cots, cribs and bassinets. While some elements of a cardboard box may comply with this standard, for example, wood material, structure and smooth edges, remember that EU 1130 is a furniture standard for traditional cots, cribs and bassinets.
Finally, and notwithstanding the new minister’s openness, I remain uneasy that the government began the scheme by claiming that the box meets safety standards and only under pressure conceded that it met ‘applicable’ standards. In effect, it meets those parts of the standard they’ve chosen to engage with. But the qualification is still not on the box itself and the Parent Club website (linked above) still states ‘the box meets all safety requirements including testing of construction, specification, load and stability … The box is marked with the European Standard on Cribs and Cradles for Domestic use BS EN 1130 accreditation’; marked with, but does not mention it excludes ‘clause 4.1 Materials at request of client.’
I had not written a conclusion to what is now Part 1 of this post when I decided to defer publishing it (see introduction). Today, the Guardian newspaper has an article entitled Cot death expert raises concerns over Scotland’s cardboard baby boxes. All credit to them for the new information they have unearthed. I’d urge you to read their article but meantime here is a summary of its key points that relate to the concerns I have previously expressed.
Dr Peter Blair has been revealed as another expert who expressed concern about the safety of the box. He is a reader in medical statistics at the University of Bristol, an expert in sudden infant death syndrome and involved with the Lullaby Trust (cited above). He is also a member of a panel of experts advising the government on the baby box programme and is quoted as telling them that:
there was no evidence they [baby boxes] were safe or reduced cot deaths, and urged them to stop claiming they are a safe sleeping space except in rare cases or emergencies.
The Guardian also claims that when he raised these concerns at a monitoring meeting, the minutes of the meeting did not accurately set out his concerns until he asked for them to be included. A cynic might say ‘The Scottish government and the minutes of meetings. Where have I heard about that before?’ He wants the guidance and information given with the boxes to be changed and concedes ‘I think [the government] are listening’. Mind you, this is fifteen months after the baby box pilot programme started so the listening can’t have been as assiduous as it might have been.
The Guardian also seems to have obtained a direct statement, for the first time, from the BSI about the subject that:
accreditation had not been available for the boxes in the UK. It was only now starting work on designing that accreditation. ‘At present there is no standard that covers baby boxes. There may be some clauses of the BS EN 1130 furniture, cribs and cradles for domestic use series that could be applicable to baby boxes, but BS EN 1130 is a furniture standard and not intended for cardboard baby boxes’.
This confirms the doubts I expressed in my previous post about the partial testing of the box, the granting of ‘accreditation’ on that basis, and the marking, literally, of the box with ‘BSEN1130-1:1997’.
These are the essential point from the Guardian article although, as I say, I’d urge you to read it to appreciate the full detail of what it claims.
I had thought, previously, that controversy surrounding the government’s baby boxes might fade away after the inept introduction (from a safety point of view) of the scheme. I’m not so sure now.
My thanks, as before, to various people who helped with information and comment for this post.
Following hostile comment on Twitter from people who had either not read or understood the previous post on the subject I will not be discussing this one there, but feel free to post comments here. Usual rules apply.