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14019pad.sun

Mr. Jeff Greger
Graco Children's Products Inc.
51 S. Pine St.
P.O. Box 100
Elverson, PA 19520

Dear Mr. Greger:

This responds to your January 30, 1997, letter concerning the head impact protection requirements of Standard No. 213, "Child Restraint Systems," as applied to a "canopy (sun visor)" on an infant restraint. You ask:

If a canopy, when folded into the "storage position," extends above the seatback surface, is it necessary for that canopy to "break away" in the event that the child's head or body strikes it during a collision? I am aware that this canopy would be required to be padded with a slow recovery energy absorbing material since protruding above the seatback would deem it a "contactable surface."

The canopy is not required to break away if struck by the dummy's head or body. If the canopy can be contacted by the dummy's head during Standard No. 213's dynamic testing, S5.2.3.2 of the standard requires it to be covered with slow recovery, energy absorbing materials with specified characteristics.

If you have any further questions, please contact Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:213
d:3/19/97