Interpretation ID: nht91-1.5

DATE: January 3, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Tom Wiatrak -- Century Products Co.

TITLE: None

ATTACHMT: Attached to letter dated 10-19-90 from Tom Wiatrak to Deidre Fujita (OCC 5360)

TEXT:

This responds to your October 19, 1990 letter asking about the application of the labeling requirements of Safety Standard 213, Child Restraint Systems, to a seat pad you plan to produce for new child safety seats. You state that the pad would cover information that Standard 213 requires to be labeled on a child safety seat. You ask whether the labeling requirements of the standard could be met by directly labeling the seat and by permanently labeling a durable tag (made of "tyvek" material) that would be sewn to the pad.

The answer is yes. Paragraph S5.5 of Standard 213 required each add-on child restraint system to be permanently labeled with specified information. Paragraph S5.5.3 requires a portion of the required information to be located on the add-on child restraint system so that it is visible when the system is installed..." Your suggested tag would satisfy paragraph S5.5.3 if it bears the required information and if that information is visible when the seat is installed in the vehicle.

You should be aware that paragraph S5.7 of standard 213 requires "each material used in a child restraint system" to conform to the flammability resistance requirements of Standard 302, Flammability of Interior Materials. Since the tag would be affixed to the child restraint, the tag would have to comply with 302.

I hope this information is helpful.