Interpretation ID: 1982-3.17

TYPE: INTERPRETATION-NHTSA

DATE: 11/01/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cosco -- Robert C. Craig, Quality Control Manager

TITLE: FMVSS INTERPRETATION

TEXT:

This responds to your letter of August 13, 1982, concerning the application of the belt buckle requirements of Standard No. 209, Seat Belt Assemblies, to child restraints meeting Standard No. 213, Child Restraint Systems. As explained in the enclosed letters of interpretation of May 12, 1981, and May 21, 1981, the only requirements of Standard No. 209 that apply to child restraint belt buckles are the corrosion resistance requirement of S4.3(a) and the temperature resistance requirement of S4.3(b). The buckle release requirements of S4.3(d) and the buckle latch requirements of S4.3(g) do not apply to child restraints.

Because of reports of problems relating to difficulty in operating child restraint buckles, the agency is considering issuance of a proposal to apply the requirements of S4.3(d)(2) and S4.3(g) to child restraint system belt buckles. Any such proposal would be published in the Federal Register to provide all interested parties with notice and opportunity to comment.

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

Sincerely,

Frank Berndt Chief Counsel

Enclosures

August 13, 1982

Mr. Steve Oesch Office of Chief Counsel National Highway Safety Administration 400 7th Street, S.W. Washington, D.C. 20590

Dear Mr. Oesch:

Cosco/Peterson has received notice from Richard Jasinski, Contract Technical Manager, that we had problems on three tests on the 78 Safe-T-Seat.

One was the corrosion resistance. On this portion we agree about the standard.

The other two we do not agree, and we would like for you to review and give us your judgment. One was the size of the push button, that it has to be greater in size than 0.7 sq. in. (Ref: Standard 209 S4.3d). The second was the engagement force of no more than 5 lbs. (Ref: Standard 209 S4.3g).

We feel that both of these refer to a Type 1 or Type 2 automo-bile belt and not to a child restraint system. Our reference is F.R. Vol 44 No. 241 December 13, 1979, N.H.T.S.A. 49 CFR, Part 571, Docket No. 749, Notice 6, page 72135, last paragraph: "Base on its review ... adopt this approach".

We have been tested many times by Cal-Span and the University of Michigan, and this was never a question on size or engagement.

We need your immediate attention to this. If we have made the wrong interpretation of the standard we want to rectify it immediately.

Sincerely,

Robert C. Craig Quality Control Manager

RCC:ch

c.c. Richard Jasinski Roy Schwartzkopf Don Moore