The discussion paper is aimed at raising the standard of the Consumer Protection Notice No 1 of 2003 which references the Australia Standard AS/NZS 4220:1994. The Consumer Protection Notice is based on the 1994 Australian Standard, and the ACCC paper proposes to adopt certain essential safety elements of the most recent 2010 version of AS/NZS 4220 (refer to  page 4 of the ACCC discussion paper). AS/NZS 4220 was first introduced in 1994, was updated in 2003 and again, more recently, in 2010.

Though the ACCC discussion paper does refer to a death in a caravan in 2002 (on page 10), it is noted on page 6 that, "In March 2003 the standard was revised to exclude bunks in caravans, bunks in other vehicles and bunks used for camping purposes, as injury did not appear to warrant their inclusion". Therefore, following the death in 2002, the regulators did not see fit to introduce the requirement into caravans and the like. It is also noted on page 10 of the ACCC paper that, "After the Standard was introduced in 2003 there was a noticeable drop in the rate (per 100 injury related Emergency Department presentations) of injuries in the 4-9 year age group from 2004 - 2006". We note that the discussion paper does not recommend any changes specifically relating to the caravan industry. 

As a requirement of RVMAP, the Code of Practice (section 6.1) states that, "Bunk beds shall be designed and constructed to prevent injury to users (especially children) and, for this purpose, should comply with at least the intent of, and preferably with the requirements of, Australia Standard AS/NZS 4220". It is recommended that manufacturers are fully informed of the requirements of  this Australian Standard to ensure that they are meeting the Standard.