Interpretation ID: aiam3247
Bartman
Braun and Halper
Suite 1015
1880 Century Park East
Los Angeles
CA 90067;
Dear Mr. Halper: This responds to your letter of March 13, 1980, on behalf of Californi Strolee, Inc., concerning Standard No. 213, *Child Restraint Systems*.; You asked whether a 'foam tray' marketed as an accessory for a chil restraint by Strolee is prohibited by section S5.2.2.2 of the standard. According to your description, the tray 'may be affixed to the car seat by straps and velcro fasteners' and is made of polyurethane foam and 'does not contain any metal or solid parts.' The purpose of the device is 'to give a child a surface on which to play or to put things during car rides.'; Section S5.2.2.2 prohibits any fixed or movable surfaces in front o the child except for surfaces that adequately restrain the test dummy in the 20 mph test. If the foam tray attaches to the child restraint so that it is the only surface in front of the child, the child restraint would have to be tested with just the tray as specified in Section S5.2.2.2. If the foam tray is attached to a surface that complies with S5.2.2.2, such as a padded shield, a separate test using the foam tray alone would not be required.; You also raised a question about section S6.1.2.1.2. You explained tha Strolee is considering the use of 'an impact shield designed to go across the front of the car seat to restrain the child.' The impact shield 'would be removable and it would be recommended that it not be used when the car seat is in the rearward facing mode.' When the restraint is used in a rear-facing position, the child is to be restrained by a five-point belt system. You asked if the Strolee seat would be required to be tested under Test Configuration II in a rear-facing position.; The answer is no. Section S6.1.2.3.2 provides that each fixed o movable surface is to be positioned in accordance with the manufacturer's instructions prior to the testing required by S6.1.2.1.2. Thus, if the instructions inform users that the removable shield is not to be used in a rear-facing position, then the restraint need not be tested at 20 mph in a rear-facing position. The restraint would be tested at 20 mph in the forward-facing position with the shield in place but with none of the restraint system belts fastened, unless they are an integral part of the shield.; You also asked about obtaining copies of interpretations issued by th agency. The agency's docket section maintains a file of the interpretations for each standard and can provide you with copies. The address is: Docket Section, Room 5108, 400 Seventh Street, S.W., Washington, D.C. 20590.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel