Interpretation ID: 1982-3.22

TYPE: INTERPRETATION-NHTSA

DATE: NOVEMBER 21, 1982

FROM: LINDA ANDERSON

TO: STEVEN OESCH-NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO MARCH 18, 1983 LETTER FROM BERNDT TO ANDERSON

TEXT: We have had two telephone conversations reviewing the regulations regarding child restraint seats as it pertains to the construction and testing of a play tray.

I have shared information with my partner, Laura Warren, and we have, of course, more questions in pursuing our goal of designing a safe play table for children secured in automobile restraint seats:

1. You have helpfully shared information regarding the individual from Strolee who pursued the same goal. What we are now questioning is whether Strolee, Inc., or Mr. Halper, did in fact have their play tray tested? Or did your letter to Mr. Halper end communication between Strolee and N.H.T.S.A.?

2. Would you have any other details considered public domain which might help us locate a patent on the Strolee tray?

3. One of our plans for a play tray would involve using velcro fasteners to be secured around the restraint belts covering the child's torso. Therefore, the restraint belts would have to be properly in place on the child before the play table could be fastened to it. Do you see any problem with this design in terms of the regulations, i.e., testing of the play tray? (We are, of course, assuming your discretion in investigating any of the above, since we are protecting our visionary unpatented plans while aiming at designing a safe product.)

4. Do the regulations ever change and what is the process? In my last meeting with my partner, we were looking at several restraint seats and noticed the label specifications glued to the seat explaining proper use of the seat.

Let's assume that a play tray was designed and sold by a source, such as ourselves, obviously unconnected with the large manufacturers of automobile restraint seats. A consumer would recognize that this product purchased separately from the seat was not an "armrest" or "shield" item as those sold by the seat manufacturer for use with the seat. In addition a label properly bonded to the play table could specify that the car seat restraint belts must function as the directions on the car seat itself specify before and during use of the play tray. Wouldn't we then be supporting the aim and goal of the regulations i.e., the proper use of car restraint seats? And in that case the present Regulation S 5.2.2.2., concerning the testing of the play tray or "contractible surface", would be unduly restrictive.

If a suitable regulation or variation applied to our proposed play tray, and similiar non-restraint accessory items, we might then produce a product which would support and enhance the use of the child restraint seat.

I'll be looking forward to your reply and I am grateful for your help so far. I would appreciate having a copy of any written reply sent to Laura Warren at the following address: 17 Byington Place Norwalk, CT C6850

The standards we discussed in our last phone conversation just arrived. Thank you very much.