Interpretation ID: nht92-3.21

DATE: 10/09/92

FROM: ROBERT R. MCAUSLAND, P.E.

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 12-16-92 FROM PAUL J. RICE TO ROBERT R. MCAUSLAND (STD. 213)

TEXT: Paul Jasinski of your Enforcement Division suggested I write you for an interpretation of Federal Vehicle Safety Standard 213. I am a consulting engineer engaged in the design of a rear facing infant seat for use in automobiles and aircraft.

My question refers to section S5.2.4 which has to do with protrusions. With reference to the attached sketch it may be seen that the frame of my seat is made from 1/4 inch thick polyethylene sheet. All the edges of the frame are rounded to a radius of 1/8 of an inch, the maximum possible on a 1/4 inch thick sheet. The corners, looking flatwise at the sheet, are 3.0 inch radius.

Does my design comply with S5.2.4? Do you consider the edges of my frame as protrusions? Since side loading is not specified in S7 could I conclude that there is no way that the child's head or torso could contact the sides of the frame?

(DRAWING OMITTED)