Interpretation ID: aiam1828
Director of Engineering
American Safety Equipment Corporation
500 Library Street
San Fernando
CA 91340;
Dear Mr. Henderson: This is in reply to your letter of January 22, 1975, which formall petitioned for a change to Federal Motor Vehicle Safety Standard No. 213, Child Seating Systems. Your petition requested an exception to the padding requirement for hardware which serves as a torso load distribution pad and which is attached only to the child seat belt system.; Based on a further review of your design, we have reconsidered th position stated in our December 20, 1974, letter to you. We now consider this device to be belt adjustment hardware, even though it is also used to distribute loads, and have determined that no padding is therefore required. We consider that the safety of your child seat would not be appreciably improved by padding this torso load distribution pad. This is further confirmed by the primate test films and data which you presented to us in our meeting of January 21, 1975. We would suggest that this item, nonetheless, provide a radius in accordance with S4.10.1(a).; We presume that this interpretation will eliminate the need for formal response to your petition. If that is the case we would appreciate a letter from you to that effect.; Sincerely, James C. Schultz, Chief Counsel