Interpretation ID: nht92-6.35

DATE: May 27, 1992

FROM: Mark W. Russo

TO: Charles Gauthier -- Director, Defects Investigation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/13/92 from Paul J. Rice to Mark W. Russo (A39; Std. 222)

TEXT:

I want to thank you for taking the time and interest to discuss the "R-BAR" subject with me in the past.

The purpose of this letter is to request from NHTSA an official "review and comment" on the topics outlined below. I have enclosed a coy of the "Test Data" booklet I received from Micho a few weeks ago as it contains information not included in the original package sent to me in October '91.

I am mainly interested in addressing the following:

A. The "applicability" of FMVSS 222 to be used as a "test" or "certification" criteria for the "R-BAR restraining system".

B. The use of "alternate testing methods" to comply with FMVSS 571: S 222-2. "S5.1.4 Seat performance rearward". as appears to be the case in the last three pages of section "3" in Micho's booklet.

C. Background of NHTSA's contacts with Micho Ind. regarding the above subjects and copies of correspondence (if permissible).

D. Any other general comments or technical concerns which might be important, for any school districts to consider, regarding the installation of such a device.

Your attention to this matter would be greatly appreciated by all concerned for the safety of our children.