National SAFE KIDS Campaign
111 Michigan Avenue, N.W.
Washington, D.C. 20010-2970
Dear Dr. Mickalide:
Thank you for your letter asking about the child restraint registration form required by Federal Motor Vehicle Safety Standard No. 213, Child Restraint Systems. You ask whether a child restraint manufacturer could make certain modifications to the registration form to help SAFE KIDS obtain sociodemographic and other information about the families to whom SAFE KIDS will be distributing child seats. As explained below, Standard 213 does not permit the modifications, but does permit an alternative approach.
You explain in your letter that SAFE KIDS and its partners will be providing approximately 38,000 child seats to needy families through distribution sites. You would like to collect information about the recipient families' sociodemographic profile and other factors, by having the restraint manufacturer add questions to the child seat registration form. Distribution site coordinators would mail the completed forms to the manufacturer, who would then tabulate the data for SAFE KIDS' research purposes.
The registration form you ask about is part of an owner registration program that NHTSA established to improve the effectiveness of manufacturer recall campaigns. The form, required by S5.8 of Standard 213, is standardized in appearance, and may not contain other material such as questions concerning the sociodemographic characteristics of the child restraint owners. A particular problem with such questions is that their presence on the registration form might cause some consumers to resist providing the information, or to conclude that the form was for warranty purposes rather than for safety recalls. As a result, they might not return the card.
While we understand that you would like to modify the registration form only for the purposes of your distribution program, unfortunately we lack the authority to grant a special exemption for your situation.
However, Standard 213 does permit an alternative that you suggested. In a telephone conversation with Ms. Deirdre Fujita of my staff, you said that you are considering asking the manufacturer to place the questions on a separate form and to attach that form to the child seat. That approach is fine. The registration form has to be attached to the child seat to ensure that owners will notice the form. While we want manufacturers to limit what additional materials they attach to child seats (to ensure that attachments do not distract from the form), your supplemental form should not cause a problem since your coordinators will be involved with registering the owners. Thus, there is no risk that the registration form will go unnoticed and uncompleted.
I hope this information is helpful. If you have any further questions, please do not hesitate to call Ms. Fujita at (202) 366-2992.
Best wishes for success in your distribution program.
John Womack Acting Chief Counsel