Mr. David Baret
Baby Comfort Inc.
5553 Ravenswood Rd., Suite 103-104
Ft. Lauderdale, FL 33312

Dear Mr. Baret:

This responds to your March 6, 1996, letter asking about our requirements for child restraint systems.

You explain that your company would like to sell child restraints manufactured abroad in the United States. During a dynamic test you had conducted on one of the restraints, the seat failed to meet the performance requirements of Standard 213, AChild Restraint Systems,@ when secured to the test seat assembly with only a lap belt. You ask if Standard 213 would permit the child seat to meet performance requirements when secured with a lap and shoulder belt, rather than just a lap belt.

The answer is no. Under S6.1.2 of Standard 213, child restraint systems such as yours must meet performance requirements when secured with only a lap belt. Certain types of child restraints are excepted from the lap belt only requirement, but your restraint is not among these. Among the excluded restraints are Abelt- positioning@ child seats, which are defined in S4 of the standard as:

[A] child restraint system that positions a child on a vehicle seat to improve the fit of a vehicle Type II [lap and shoulder] belt system on the child and that lacks any component, such as a belt system or a structural element, designed to restrain forward movement of the child=s torso in a forward impact. (Emphasis added.)

As Ms. Fujita of my staff discussed with you in a March 25, 1996, telephone conversation, your child seat has an internal belt system harness and thus is not a belt- positioning seat. Accordingly, your child restraint system would be tested secured with only a lap belt. The National Highway Traffic Safety Administration (NHTSA) tests most child restraint systems with only a lap belt because lap belts are provided in the rear seats of many older model vehicles still on the road, and in the center seating position in the rear seat of many newer model vehicles as well. If your seat cannot meet Standard 213's requirements with only a lap belt, you could not in good faith certify your product as complying with Standard 213.

I have enclosed an information sheet for your information, which briefly outlines NHTSA=s standards for new manufacturers. If you have any further questions, please do not hesitate to contact Ms. Fujita at (202) 366-2992.


Samuel J. Dubbin Chief Counsel


ref:213 d:4/16/96