Altheimer & Gray
10 South Wacker Dr.
Chicago, IL 60606-7482
Dear Ms. Davik-Galbraith:
This responds to your letter asking whether any of the regulations administered by the National Highway Traffic Safety Administration (NHTSA) apply to children's safety belt adjusters. To answer your question, I have enclosed copies of two of the letters we have written on this subject. These two are our response to Angela Caron, dated March 16, 1994, and to Brett Higgins, April 26, 1993.
As explained in those letters, there is no safety standard that directly applies to safety belt adjusters. However, there are several provisions in NHTSA's statute that are relevant to those products, such as the responsibility borne by persons manufacturing safety belt adjusters to ensure that the products are free of safety-related defects.
I note also that the American Academy of Pediatrics (AAP) petitioned this agency in January 1996 to amend Safety Standard No. 213 to regulate safety belt adjusters for children. Enclosed is a copy of the petition. NHTSA expects to respond to the AAP petition shortly.
I hope this answers your questions. If you need further assistance, please contact Deirdre Fujita of my staff at (202) 366-2992.
Acting Chief Counsel