Bathtub Incidents Guidelines

OMB Control Number 3041-0029

INVESTIGATION GUIDELINE
Appendix 111
April 19,1995
BATHTUB INCIDENTS INVOLVING CHILDREN LESS THAN 18 MONTHS OLD

I. Introduction
A. Background Information
CPSC staff will study incident scenarios involving drownings, near
drownings, scaldings, and other serious injuries associated with
bathing.
Over fifty infants a year drown in bathtubs. In its attempt to decrease
this number, the CPSC is conducting a study to learn the
circumstances surrounding drowning deaths of children aged 18
months or younger. Of particular interest are drownings associated
with bath rings and bath seats. In these cases, the drowning deaths
appear to be caused by:
Tip over - The suction cups unexpectedly
releasing, allowing the device AND baby to
tip over in the water.
Entrapment - Babies slipping between the
legs of the bath ring and becoming trapped
under water.
Climbing out - Babies over 8 months
climbing out of the product and drowning.
In addition, the study will include incidents involving scaldings
occurring when the temperature of tap water is set too high (above
120 degrees F.) and serious injuries occurring when infants fall in the
tub and receive head or trunk injuries leading to impairment.

INVESTIGATION GUIDELINE
B. Product Description
Specific products of concern are bath rings, seats, and
infant bath tubs. Bath rings and seats are intended for
babies over 6 months and are used to help support
babies during bath time. These devices usually have
three or four legs with suction cups that attach to the
bottom of bathtubs. Infant bath tubs are used for babies
younger than 6 months. Some bath aids have
restraining belts while others contain sponge seats.
C. Specific Items of Interest
Determine the general condition of the bath aid and
determine if any product feature or failure contributed to
the incident.
Identify any labeling including location of labels.
Specifically, on bath rings or seats, note missing suction
cups and/or suction cups which do not stick to bath tub
surfaces or adhere to the base of the ring or seat.
Additionally, describe the restraining belt on the bath
aid, whether it was used properly during the incident,
and describe any problems with the restraint system.
Determine if the bath aid remained upright or turned
over during the incident. Describe in detail the position
of the infant (and other children) in relation to the bath
seat, bath ring, or infant tub.

D. Headquarters Contacts
Leonard Schachter, EPHA, 301-504-0470 ext. 1273
Renae Rauchschwalbe, CECA, 301-504-0608 ext. 1362
Kate Sedney, EPHF, 301-504-0468 ext. 1282

INVESTIGATION GUIDELINE
II. Instructions for Collecting Specific Information
A. Synopsis
Describe in the synopsis the sequence of events which
occurred in the incident, indicating if any product
component failed. Also indicate if the infant was left
unattended by a parent or care giver prior to the injury,
the reason for leaving the infant unattended, and the
time elapsed if the infant was alone in the bathtub. Note
if a sibling or caregiver was involved.
B. Description of the Incident Environment
Determine if the incident occurred in the child's home, a
daycare center, the daycare provider's home, or some
other location. Describe the incident environment as a
single family home, a townhouse, an apartment building,
a school, or some other location.
Characterize the parent's/care giver's socio-economic
stratum by determining the educational level and total
annual income level. If this information is unavailable,
please indicate the lack of information in your report.
C. Description of the Injured Person(s) and Product Interaction
Determine the infant's age, sex, height, and weight at
the time of the incident. Indicate if the infant was of
Hispanic origin; white (non-Hispanic); Black; American
Indian, Eskimo, or Aleut; or and Asian or Pacific
Islander. Determine the infant's health status at time of
the incident.
Indicate if the infant was unusually active for his/her
age. Indicate if the infant was able to remain upright in
the bath aid without assistance, if a bath aid was used.
Determine child's ability to stand alone.
-3-

INVESTIGATION GUIDELINE
Determine the relationship of the care giver to the
injured infant. Determine if the care giver was within
arm's reach when the incident occurred, was in the
same room, or had left the room. Determine if anyone
was a witness to the incident.
Determine if any other child was placed in the tub with
the injured child and describe their age, sex, height,
weight, and activity during the incident.
Determine the orientation of the child or children in the
tub in relation to the tub faucets and describe faucets.
Indicate the depth of water in the tub and temperature, if
a scalding occurred. Determine if there were any
problems with the tub prior to the incident such as a
leaking faucet or problems with the stopper.
If the parent or care giver left the room or was
distracted, indicate the reason for leaving or being
distracted. Determine what event occurred to alert the
parent or care giver to return to the bathroom, i.e., did
the infant stop making noise or began screaming?
D. Description of the Product
Determine the tub dimensions (length, width, and depth)
in inches. Indicate if the tub had a smooth or nonsmooth (slip-resistant) surface. Indicate if the tub used
appliques to prevent slippage.
Determine if any modifications were made to the bathtub
or bath aid and describe these modifications.
If a bath aid was involved, describe it completely
including overall dimensions. Determine the bath aid's
brand name and model number. Determine if it was
purchased new, received as a gift, or purchased used.
Determine place of purchase.

INVESTIGATION GUIDELINE
Describe the general condition of the bath aid and the
wording and location of any product labeling.
Determine if any restraining devices, suction cups, or
sponge inserts were on the bath aid and in use at the
time of the incident.
Determine if bubble bath, bath salts, or bath oil were
used to bathe infant. If in use, did these affect the
incident in any way?
E. Product Safety Standards
There is an ASTM voluntary standard under
development for infant bath rings and bath seats.
Information derived in these investigations will be used
in development of the standard.

III. Instructions for Photographing and/or Diagraming Factors Related
to the Investigation
For on site investigations, if possible, reenact the
positions of the bath aid and child using a doll and
photograph reenactment. If photographs cannot be
taken, please diagram these positions. For telephone
investigations, obtain verbally the positions of the child,
the bath aid, and faucet location in the bath tub.
IV. Instructions for Obtaining Samples and Documents Related to the Investigation
Collect any reports from attending officials including
police investigations, paramedic reports, fire department
reports, emergency room reports, and social worker
reports.
For fatal incidents, collect medical examiner's or
coroner's investigations and copy of death certificate.

INVESTIGATION GUIDELINE
From investigating officials, determine if the parent or
care giver had left the infant alone and, if so, for what
length of time? Determine if the parent or care giver
had left the infant alone previously in the bathtub and
what, if any, incident had occurred when the infant was
left alone? Determine the circumstances and products
involved.
Determine if parent or care giver attempted cardiorespiratory resuscitation (CPR) or other first aid and
indicate if the parent or care giver was certified to
administer CPR or was guided by emergency response
officials. Indicate the elapsed time in minutes from
when the parent or care giver summoned assistance
until their arrival. Indicate the time interval from the
incident until emergency room treatment was
administered. Indicate the time interval the infant was
hospitalized. Indicate the time interval from the incident
until the infant was pronounced dead by medical
officials.
From investigating officials, determine if there was any
indication of child abuse. If so, indicate the source of
this finding and provide documentation.
If the bath aid is available for collection as an official
sample, and there was an indication of a component
failure, contact Renae Rauchschwalbe, CECA, 301-5040608 ext.1362, for instructions in obtaining the bath aid.

-6-