Interpretation ID: nht71-2.36

DATE: 04/30/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Hartman Mfg. Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 9, 1971 concerning certain provisions of Motor Vehicle Safety Standard No. 213, "Child Seating Systems." In your letter you ask whether S4.4 of the standard requires the child seating system itself to be restrained by the seat belt assembly. You state that S4.5.1 indicates to you that the vehicle seat belt assembly is employed to restrain both the child and the seating system, and request that this issue be clarified.

S4.4(a) of the standard requires each child seating system, when installed as the manufacturer directs, to be restrained by the vehicle seat belt assembly. The vehicle seat belt assembly may also be used to directly restrain the child, but it is not required to do so. When it is used for this purpose, however, it must distribute the restraint forces as specified by S4.5.1 of the standard.

The statement in the preamble of the notice of March 23, 1970 to which you refer describes the scope of the standard. This statement means that any device for seating children in a motor vehicle that is designed to utilize the vehicle restraint system or provides restraint by itself, or both, is a "child seating system" and must comply with all the requirements of the standard.

We are pleased to be of assistance.