Interpretation ID: Takata_lrd_5014

Mr. Kazuo Higuchi
TK Holdings, Inc.
601 13^th Street, NW, Suite 350 South
Washington, DC 20005

Dear Mr. Higuchi:

This responds to your letter seeking confirmation that under the low risk deployment test procedures for the 12-month-old child specified in Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant crash protection, the compliance test is performed with the passenger seat in the full forward position only. As explained below, your understanding is correct.

On May 12, 2000, we established the advanced air bag requirements in FMVSS No. 208 to reduce the risk of serious air bag-induced injuries, particularly for children and small adults (65 FR 30680; May 12, 2000). Under S19 of FMVSS No. 208, vehicles certified to the advanced air bag requirements must comply with one of two options in order to provide protection for infants in rear facing child restraint systems: (1) air bag suppression, or (2) low risk deployment.

In a response to petitions for reconsideration of the advanced air bag requirements we specifically addressed and clarified the test procedure for the low risk deployment option. We explained that testing with a rear facing child restraint system under S20.4.1 is only conducted with the vehicle seat in the full forward position (see 68 FR 65179, 65182; November 19, 2003). We also noted that the associated indicant testing specified in S20.4.9 is conducted with the passenger seat in the full forward, middle, and full rearward position.

We recognize that the test procedure data sheet (Data sheet 22, TP-208-12) for the low risk deployment test has entries under S20.4.1 for all three seat positions. However, it is the regulatory text in FMVSS No. 208 that is controlling, not the test data sheet.

If you have any additional questions, please contact Mr. Chris Calamita of my staff at (202) 366-2992.

Sincerely,
Jacqueline Glassman

Chief Counsel
ref:208
d.7/27/05