Interpretation ID: 1984-2.25

TYPE: INTERPRETATION-NHTSA

DATE: 07/10/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Collier-Keyworth Company

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Richard L. Batt Chief Engineer, Juvenile Division Collier-Keyworth Company Gardner, Massachusetts 01440

Dear Mr. Batt:

This responds to your letter of June 19, 1984, asking how the requirements of section 5.2(d) of Standard No. 209, Seat Belt Assemblies, apply to a sample child restraint belt buckle you provided the agency. You specifically asked whether the buckle would be considered a push button-release buckle or a lever-release buckle.

Your buckle would be considered a push button-release buckle since a person opens the buckle by pushing down on a specified surface. The lever-release buckle refers to a type of buckle which is opened by lifting a portion of the buckle. For example, the buckles found on airplane safety belts and some racing safety belts are lever-release buckles.

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

Sincerely,

Frank Berndt Chief Counsel

June 19, 1984

Office of Chief Counsel Mr. Steve Kratzke National Highway Traffic Safety Admin. 400 Seventh Street, S.W., Room 5219 Washington, D.C. 20950

RE: Sample Buckle

Dear Mr. Kratzke:

Thank you for taking the time to talk with me about a child restraint belt buckle.

Enclosed is a sample buckle that is only indicative of the design that we want to know about, and how it might be covered by the regulations imposed on child restraints. Please bear in mind that structural strength, corrosion resistance, and temperature resistance properties can all be addressed with alternatives to the materials that the sample buckle is made of.

What we really want to know is, does this design conform to the lever requirements of FMVSS 209? Will this design be considered to be a push button configuration, or will it be considered to be a lever configuration?

We need to know the proper designation in order to correctly design the physical shape of a newly proposed buckle.

I thank you.

Very truly yours,

COLLIER-KEYWORTH COMPANY

Richard L. Batt

Chief Engineer Juvenile Division RLB/dlc Enclosure