Interpretation ID: nht92-8.28

DATE: March 11, 1992

FROM: Mark A. Sedlack -- Product Design Manager, Century Products Company

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: Frank Rumpeltin; Rob Wise

TITLE: None

ATTACHMT: Attached to letter dated 4/22/92 from Paul J. Rice to Mark A. Sedlack (A39; Std. 213)

TEXT:

I am writing to request a written clarification of an issue involving FMVSS 213 compliance testing. I have spoken to both Mike Pine and Dee Fujita about this issue and was told that a decision was pending.

It has been Century's understanding that any child restraint which was labeled for use by a child over 20 pounds would be tested using three year old part 572 dummy. The procedure is readily apparent in the standard for forward-facing child restraints. However, it is not readily apparent how a rear-facing seat could be tested using the three-year old dummy, particularly in how the dummy is to be installed.

As a result of recommendations published by various consumer safety groups, telling people to (ignore the manufacturer-a instructions and) use using rear-facing child restraints up to 25 pounds, we have tested our existing convertible seats with a CAMI dummy modified to twenty-five pounds with satisfactory results.

We have not, however, changed our labels or instructions to reflect the higher weight because of the above stated understanding.

Our next step is to test these seats with the three-year old dummy, but we are not clear, nor is the testing facility, as to how this procedure is to be accomplished.

We have recently become aware of a child restraint available at retail which is labeled for use up to twenty-five pounds, and must assume that the procedure for testing has been clarified. If this is the case, could you provide us with a written clarification as to how rear-facing testing is to be done for a child restraint labeled for use up to twenty-five pounds.