Interpretation ID: nht80-4.19

DATE: 11/07/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Questor Juvenile Products Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of September 4, 1980, concerning Standard No. 213, Child Restraint Systems. You asked whether instruction booklets provided with child restraints must meet the flammability requirement of Standard No. 302, Flammability of Interior Materials. The answer is no. They do not have to comply with Standard No. 302.

Section 5.7 of Standard No. 213 requires each material used in a child restraint to conform to performance requirements of Standard No. 302. You asked whether the installation instructions, which are required by section 5.6 to accompany the child restraint, must comply with the flammability requirements of section 5.7. Since the installation instructions, unlike an affixed label, are not a physical part of the child restraint system, they do not have to comply with section 5.7.

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

Questor Juvenile Products Company

September 4, 1980

Frank Berndt, Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Berndt:

Ref.: NOA-30

In your letter of April 22, 1980, to Mr. Don Gerken of Cosco Home Products, you indicated that Section 5.7, FMVSS 213, requires "each material used in a child restraint system" to conform to the performance requirements of Standard No. 302. You also indicated that because the label, installation diagram, and tag materials are affixed to the child restraint, they would have to comply with FMVSS 302. You further stated that if the label, diagram, and tag do not adhere at every point of contact, Section 4.2.1 requires them to meet the performance requirement of the standard when tested separately.

In previous discussion with NHTSA personnel, installation and use requirements of children's car seats indicated that an instruction booklet might be required to accompany each child restraint system in order to describe adequately the various methods of installation for multi-purpose child restraint systems. NHTSA personnel had suggested during these conversations that such an instruction booklet be provided with a pocket attached to the child restraint system for retention of the booklet. As a matter of interpretation, could you please advise if such an instruction booklet, which would normally be manufactured of paper stock, must meet the flammability requirements of FMVSS 302? To the best of my knowledge, owners' manuals furnished with automobiles are not required to meet FMVSS 302. In our attempt to provide a convenient and permanent storage location for child restraint system instructions booklets, I would hope that NHTSA would not require these booklets to meet FMVSS 302 because they would be included with the child restraint.

Since the effective date of FMVSS 213's revised requirements is fast approaching, your expeditious response to this matter would be greatly appreciated.

J. P. Koziatek, P. E. Director, Technical Services