Interpretation ID: nht91-1.6

DATE: January 3, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Jeffrey P. Henderson -- ACTS Testing Labs, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7-10-90 from Jeffrey P. Henderson to Paul Jackson Rice (OCC 4976)

TEXT:

This responds to your letter about paragraph S5.7 of Safety Standard 213, Child Restraint Systems, which specifies that each material used in a child restraint system must meet the flammability resistance requirements of Standard 302 (Flammability of Interior Materials). You asked whether a "plastic pouch" that contains the installation instructions for the seat is required to meet the requirements.

The answer to your question is yes. A pouch that is provided to store the seat's installation instructions during the life of the seat is required by Standard 213 (S5.6.1.6; S5.6.6) to be located on the seat. Thus, by definition, the pouch would be a physical part of the seat. If a component is made a physical part of the seat (e.g., by affixing the component to the seat), the component is subject to Standard 302. The agency referred to the term "physical part" in a November 7, 1980 letter to J. P. Koziatek. In that letter, the agency determined that installation instructions, which are not a "physical part" of the child seat, need not comply with the flammability requirements.

I hope this information is helpful. Please contact us if you have further questions.