Brodey & Price
9777 Wilshire Blvd.
Beverly Hills, CA 90212
Dear Mr. Price:
This responds to your letter asking several questions about Federal Motor Vehicle Safety Standard No. 213, "Child Restraint Systems," as it applies to a child restraint harness. I apologize for the delay in responding.
You wish to know whether the design of a particular harness is in compliance with Standard 213. Please note that NHTSA does not issue interpretations about the conformance of a specific vehicle or item of equipment with the standards. Those determinations are usually made in the context of an administrative proceeding when a full examination of the issues is possible, such as an enforcement action.
The "All Our Kids Travel Vest, Model TV600," was tested in 1994 by Calspan Advanced Technology Center (Calspan) for NHTSA as part of the agency's compliance test program of child restraint systems. Calspan found that the restraint appeared to comply with all the requirements of Standard 213 except for certain requirements on labeling and installation instructions. A copy of the test report (213-CAL-94-048) is enclosed for your information.
Your first question concerns S184.108.40.206(a) of Standard 213, which requires that "The system surface provided for the support of the child's back shall be flat or concave and have a continuous surface area of not less than 85 square inches."
You ask whether the restraint meets the requirement of S220.127.116.11(a) of Standard 213. You describe certain "reinforcing ribs" on a metal plate of a harness provided for support of the child occupant's back. You state that the ribs are 0.62 inches in width, raised approximately 0.25 inches above the surface of the metal plate. In addition, there are "corrugations (grooved in the front, ribbed in the rear)" that are 0.5 inches in width and 0.25 inches below the surface of the metal plate. As you describe the metal plate, it is essentially flat in orientation and thus would meet the requirement.
Your second question asks about S5.2.4 of Standard 213, which states, in pertinent part:
Any portion of a rigid structural component within or underlying a contactable surface...shall, with any padding or other flexible overlay material removed, have a height above any immediately adjacent restraint system surface of not more than 3/8 inch and no exposed edge with a radius of less than 1/4 inch. (Emphasis added.)
You ask whether the determination that an edge is exposed is made before or after the removal of any padding or flexible overlay material. The answer is that NHTSA first removes padding or flexible overlay material, then measures the height of protrusions and the radius of exposed edges. (See underlined language above.) You also ask whether S5.2.4 specifies a minimum thickness of 1/2 inch for the metal plate. The intent of S5.2.4 is to ensure that edges that might be contacted through any overlay or padding must be rounded. However, the edges of this particular plate, as opposed to the essentially flat surface, would not be contacted by the dummy.
Your third question pertains to S18.104.22.168 of Standard 213, which sets performance requirements for "Any buckle in a child restraint system belt assembly design to restrain a child using the system...." You ask if S22.214.171.124 or any other paragraph in the standard would prohibit a "'hook and loop' or 'Velcro' closure, designed to fasten around a ring attached to the opposite side of the waist belt...solely because it is not actually a 'buckle'?"
The answer is Standard 213 does not prohibit the "hook and loop" assembly you describe. S126.96.36.199 sets requirements for push button buckles when provided but does not require the buckles types to be standardized. However, in a preamble to a December 13, 1979 final rule adopting upgraded requirements in Standard 213, the agency encouraged child restraint manufacturers to use push button buckles, "so that people unfamiliar with child restraints can readily unbuckle them in emergencies." 44 FR 72131, 72136. Our position on this has not changed.
If you have further questions, please contact us at (202) 366-2992.
Acting Chief Counsel