Interpretation ID: nht80-3.28

DATE: 07/31/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Questor Juvenile Products Company

TITLE: FMVSS INTERPRETATION

TEXT:

JUL 31 1980

NOA-30

J. P. Koziatek, P.E. Director, Technical Services Questor Juvenile Products Company 771 N. Freedom Street Ravenna, Ohio 44266

Dear Mr. Koziatek:

This responds to the request for interpretation of Standard No. 213, Child Restraint Systems, made at your May 20, 1980, meeting with members of the agency's staff. At the meeting, you demonstrated a prototype of a Kantwet "One Step" Model 400 child restraint with an automatic movable restraining shield. You asked whether the agency will attach the crotch strap of that child restraint during the 20 mile per hour test specified in S6.1.2.1.2 of the standard for child restraints with movable restraining shields. The answer is yes, the agency will attach the crotch strap during that testing.

The child restraint system you demonstrated to the agency on May 20, 1980, has a movable shield attached by two arms to either side of the child restraint. The movable shield is spring loaded, so that the shield must be mechanically held down in front of the child or the spring will automatically raise the shield above the child's head. In the lower seating surface of the child restraint is a crotch strap that is intended to be manually attached to an anchorage point mounted on the movable shield. If the crotch strap is attached to the movable shield, the shield is held in place in front of the child.

The system is equipped with two upper torso belts that pass through the system's seat back and are attached to an adjustment and anchorage device that is permanently affixed to the movable shield. When the shield is lowered so that it is in front of the child, the two upper torso belts are brought over the shoulders of the child. Thus, with the possible exception of having to adjust the upper torso belts, attaching the crotch strap to the movable shield is the single step necessary to fully restrain a child.

Your specific question was whether the crotch strap used with this child restraint would be considered an integral part of the movable shield. On April 29, 1980, the agency responded to your prior request for interpretation about the crotch strap on the same child restraint with a movable shield that is not spring loaded. The agency said that the crotch strap was not an integral part of the movable shield. The presence of the spring-loaded shield does not change the nature of the crotch strap. It is still a separate device that must be manually connected to the shield every time the child restraint is used. Thus, under our prior interpretation, the crotch strap as used in the design shown us on May 20, 1980, is not an integral part of the shield.

The rationale for the integral belt requirement involves the principal misuse of child restraints which is the failure to attach buckles. This failure is often associated with child restraints having movable surfaces that can be positioned in front of the child. Parents mistakenly assume that such surfaces by themselves would provide sufficient protection and thus do not buckle the harness system in the restraint. To reduce that misuse, the agency established the requirement that belts may be attached during the testing of restraints equipped with movable shields only if they are integral parts of the shield. Attachment of belts that are integral parts is permitted since they remain attached to the restraining shield whether or not the restraint is in use and since the need to buckle those belts is more readily apparent than in the case of nonintegral belts. Thus, the integral belts are not subject to the type of misuse described above.

This rationale applies to belts on a child restraint having movable restraining shields that are not spring-loaded. It does not, however, apply to a nonintegral belt on a restraint having a spring-loaded movable restraining shield, if that shield can be held in place only by attaching the nonintegral belt so as to fully and properly restrain the child. The spring-loaded movable restraining shield in your system will not stay in place in front of the child unless the crotch strap is attached. If the crotch strap is not fastened, the movable restraining shield automatically rises above the child's head to signal that the buckle is unfastened and the child is unrestrained. When the movable restraining shield with its integral upper torso belts is positioned in front of the child and the crotch strap is fastened, the child is properly restrained. Requiring the crotch strap to be an integral part of the movable restraining shield is unnecessary in such a system. Our position would be otherwise if the spring-loaded movable restraining shield could be held in place in front of the child without fully and properly restraining the child, such as by only partially attaching nonintegral belts and thus only partially restraining the child.

Further, the agency did not have your type of spring-loaded restraining shield and belt system in mind during the rulemaking proceeding on child restraints. That type of shield and belt system were neither contemplated by the agency nor discussed by any of the comments on the proposal. Accordingly, we plan to issue an interpretive amendment providing that the integral belt requirement does not apply to a nonintegral belt or belts that attach to a spring-loaded movable restraining shield if the shield cannot be held in place in front of the child without the child being fully and properly restrained.

The agency is concerned, however, about the durability of a spring-loaded system such as yours. To properly perform its function the spring must have sufficient force to slowly, but repeatedly, raise the movable shield. Further, since child restraints are traditionally handed down from child to child and family to family, the spring must be able to withstand several years of repeated use. We urge you to design the spring so that it will have sufficient durability to perform satisfactorily over the foreseeable lifetime of the child restraint.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel