“It’s our polite nudge in the ribs to help you and your team stay organised and on task.”
This week’s subject is Wellbeing and comfort: Safe sleep and rest.
Element 2.1.1: Each child’s wellbeing and comfort is provided for, including appropriate opportunities to meet each child’s need for sleep, rest and relaxation.
Have you updated your sleep and rest risk assessment, policy and procedures to ensure compliance with the two new mandatory standards that now apply?
The transitional period for the application of the Australian Competition and Consumer Commission’s (ACCC) new mandatory standards has ended and Service’s must now comply (from January 19, 2026).
In July 2024 the Australian Competition and Consumer Commission (ACCC) introduced two new mandatory standards:
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- The Consumer Goods (Infant Sleep Products) Safety Standard 2024 details the requirements for products marketed for infant sleep, and focuses on design, construction, performance, and testing requirements. Products must meet strict design and performance criteria to reduce risks of suffocation, entrapment, and sudden unexpected death in infancy (SUDI). The key safety requirements under this standard include:
- Sleep surface must be flat (not curved) with an incline of no more than 7° from horizontal.
- Sides must be firm, breathable (mesh or fabric), and resistant to collapse.
- No sharp edges, points, or gaps that could trap a baby’s head, neck, limbs, or fingers.
- Products with wheels/castors must have at least two with brakes; locking mechanisms must clearly indicate when engaged.
- For household and folding cots: additional requirements reference recognised standards (e.g., AS/NZS 2172, ASTM F1169-19, BS EN 716-1:2017).
Implications for ECEC services: Since full enforcement began on 19 January 2026, all new or replacement infant sleep products (especially cots and porta cots) purchased or in use must comply. Non-compliant equipment risks safety incidents, potential recalls, fines, or liability. Services should prioritise flat, firm surfaces and eliminate any items exceeding the 7° incline limit for sleep use.
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- The Consumer Goods (Infant Products) Information Standard 2024 focuses on warnings, instructions, labelling, and safety information and applies to all infant sleep products and products that are not sleep products but have inclined surfaces on which an infant may lie and may reasonably fall asleep (even if not marketed for sleep). Key requirements include:
- Clear warnings and safety instructions supplied with the product, covering correct assembly, mattress size/fit, safe sleep positioning, keeping away from blind cords/straps, and no added objects (e.g., pillows, toys).
- Manufacturer markings on the product (e.g., origin, model).
- For inclined non-sleep products; explicit markings such as “not for infant sleep” or requirements for constant supervision.
Implications for ECEC services: Many settling/soothing products previously used in ECEC (e.g., inclined bouncers or rockers) may now require these warnings. Services must avoid using such products for unsupervised sleep or prolonged rest periods. Any compliant inclined items should only be used under direct supervision.
While the standards primarily impact suppliers, manufacturers, and retailers, ECEC services, as consumers and users face direct implications for safety and liability, reinforcing the need to align your practices with the new consumer product standards and the existing legislative requirements under the Education and Care Services National Law and Regulations.
What Services need to do to ensure compliance:
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- Audit current equipment: Check all cots, porta cots, mattresses, and any inclined items. Confirm compliance with the Safety Standard (e.g., under 7° incline, firm sides) and presence of required warnings/labelling in accordance with the Information Standard. Remove or replace non-compliant items.
- Review and update Sleep and Rest Risk Assessment (R84C) to explicitly address:
- Compliance with both standards’ requirements.
- Hazards from inclines above 7°, gaps, or collapse risks.
- Supervision practices for any inclined items (if used only for settling under supervision).
- Review and update your sleep and rest policy and procedure (R84B) to:
- Reference the new standards’ requirements and warnings.
- Prohibit unsupervised use of inclined non-sleep products for rest/sleep and procedures for when children do fall asleep in these products.
- Outline equipment and safety checks, maintenance, and documentation practices.
- Reinforce Red Nose best practice guidelines (back sleeping, firm flat surface, no soft objects).
- Staff Training and Documentation: Train all staff and educators on the standards, updated policies, procedures and safety practices. Maintain records of audits, training and safety checks.
- Keep families informed: Share information with families about the standards, updates to your sleep and rest policy and procedures and safe sleep information from Red Nose.
Resources:
Guide to the NQF: Section 4: Operational Requirements: Quality Area 2: Children’s Health and safety
ACECQA- Sleep and rest legislative requirements
Guide to the NQF- Element 2.1.1: Wellbeing and comfort
Within System7 go to Quality Area 2/ Modules 1 & 35 to submit self-assessment notes and if required, open a QIP issue if you identify any areas of improvement.
The Childcare Centre Desktop has a range of resources to assist services with safe sleep. These include Sleep and Rest Policy and Procedure, Safe Sleep Practices Risk Assessment and Action Plan, Safe Sleep and Rest Audit, Safe Sleep Record templates and much more.
Resources, NQS Element, Regulation and System7 links:
Childcare Centre Desktop – Childcare Centre Desktop
National Quality Standard – QA 2/ 2.1.1- Wellbeing and comfort
National Regulations – Division 1A-Sleep and rest, 155, 168 (2)(a)(v), 170
System7 Module – QA2/ Modules 1 & 35
If you have any questions send us a note via the Contact page here!
