ID: nht74-3.25

DATE: 09/27/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Solomon; Religan & Blake

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of September 9, 1974, inquiring as to the compliance of the AADA-65 odometer disclosure form with the Federal odometer requirements.

Your letter suggests that this agency has "approved" the Form AADA-65 as complying with the provisions of the odometer regulation. We are, however, unaware of any past correspondence between this office and either the Arizona Automobile Dealers Association or Norwick Printers of Oklahoma concerning the validity of a disclosure statement.

The Form AADA-65 enclosed in your letter fails to comply with our regulation in several respects. The statement referring to the mileage indicated on the odometer at the time of the vehicle's transfer must be phrased to indicate that the disclosure document was executed at the time of the vehicle's transfer, not at some later time. In addition, the statement must be written in such a manner that it is clear it is to be completed by the transferor alone. To satisfy these criteria the statement should read

"I, , state that the odometer mileage indicated on the vehicle described above, at the time of transfer to , is as follows:"

The portion of the document provided for disclosure of the odometer mileage and a statement as to its accuracy is also deficient on the AADA-65 form. Instructions are necessary on this part of the form to ensure that it is completed in a consistent manner by all persons. The number of miles indicated on the odometer at the time of the vehicle's transfer must appear. Also, if the seller wishes he may indicate on the form that the actual mileage is over 100,000 miles. In addition, the statement concerning the accuracy of the vehicle's reflected mileage must be more complete than the one included in the AADA-65 form. Completion of the disclosure document in accordance with these directions may be accomplished as follows:

"(Complete line 1; and, where applicable, complete line 2 and check line 3:)

1. miles

2. total cumulative miles (if over 100,000).

3. [ ] I further state that the actual mileage differs from the odometer reading for reasons other than odometer calibration error and that the actual mileage is unknown."

You expressed some confusion concerning the circumstances under which a statement should be made that the actual odometer mileage is unknown. The intended purpose of the disclosure statement is to inform the purchaser of a vehicle as to the accuracy of the mileage registered on the odometer. In order to accomplish this purpose it has been determined that where the seller of a vehicle has good reason to believe that the mileage registered on the odometer differs from the vehicle's true mileage he must so inform the buyer in positive terms. In the situation where the transferor is uncertain whether the mileage is accurate, he must determine whether there is a credible basis for an assumption that the mileage is either correct or incorrect. If he has good reason to believe that the mileage is inaccurate, even though he is not positive, he should check the statement saying that the mileage indicated on the odometer is incorrect. A statement from a prior transferor that the odometer mileage is incorrect constitutes sufficient basis for a like statement upon subsequent transfer of the vehicle.

ID: nht74-3.26

DATE: 09/25/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: O'Bannon & Gonce

TITLE: FMVSS INTERPRETATION

TEXT: In response to your request I have enclosed a copy of Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires (49 CFR @ 571.109) as it appears in the current edition of the Code of Federal Regulations.

The table listing load and inflation values for the G78-15 tire size designation is Table I-J of Appendix A. Except for the addition of test loads at 16 and 18 psi, the load and inflation information for the G78-15 tire size designation has not changed since the first publication of the information on April 18, 1968 (33 FR 5949), a copy of which is also enclosed.

ID: nht74-3.27

DATE: 09/23/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyota Motor Sales Inc.

TITLE: TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 12, 1974, inquiring as to whether or not a vehicle with unitized construction, developed as a truck and converted to carry passengers may be classified as a multipurpose passenger vehicle.

Your description of the vehicle in question indicates that it does qualify as a multipurpose passenger vehicle. The reference to "truck chassis" in the MPV definition was intended to include vehicles that were designed and developed as trucks but have been produced in a version for carrying passengers. Since the delivery van referenced in your letter was developed as a truck, its modification to enable the carrying of passengers places it in the MPV category.

TOYOTA MOTOR SALES, U.S.A. INC.

August 12, 1974

James B. Gregory Administrator National Highway Traffic Safety Administration

We would like to request your interpretation of "multipurpose passenger vehicle" as defined in @ 571.3 Definitions of PART 571-FMVSS Subpart A.

Our concern is with the meaning of "truck chassis" and whether or not we can classify the following vehicle in the MPV category under the above-cited definition.

Among our car lines we have a delivery van, a diagram of which is attached. This van has a unitized body construction, but it was developed for cargo transportation. In other words, it could be classified as a truck. If we were to install enough seats in this van to enable it to carry ten passengers or less, could this vehicle as modified be classified in the MPV category?

Your interpretation of the above will be greatly appreciated.

THANK YOU.

K. Nakajima

Director/General Manager

Factory Representative Office

ATTACHMENT (Graphics omitted)

(Graphics omitted)

Wheelbase: 2200 mm

ID: nht74-3.28

DATE: 09/24/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: B.F. Goodrich Tire Company

TITLE: FMVSR INTERPRETATION

TEXT: This is to respond to the draft defect notification letter submitted by B. F. Goodrich at a meeting with NHTSA personnel on September 4, 1974. While we provided you with some preliminary comments at that time, our position regarding your notification is as stated in this letter.

We believe your letter fails to comply with 49 CFR, Part 577, "Defect Notification" in several respects. Some of our comments are also directed at what we view as a lack of clarity in your letter arising, it seems to us, from some disorganization in the text.

The first sentence in your second paragraph does not follow satisfactorily the requirements of @ 577.4(b)(1). This requirement should be met by simply stating, "The B. F. Goodrich Tire Company has determined that a defect which relates to motor vehicle safety exists in its Space Saver Spare tire."

Section 577.4(c) requires the notification to describe the defect by including specified information. We believe your letter confuses the items of information and presents them in an order which clouds an understanding of the safety problem. As we understand your presentation of the facts, the item of motor vehicle equipment affected (@ 577.4(c)(1)) is the tire; the malfunction that may occur (@ 577.4(c)(2)) is an explosion of the tire; and the operating or other conditions that may cause the malfunction to occur (@ 577.4(c)(3)) are damaged beads, excessive air pressure, and beads not seated properly on the rim. With respect to this letter requirement, we find the reference to the "combination" of factors in your second paragraph, and your fourth paragraph, in which you state that "some or all" of the causal conditions listed can produce the defect, to be inconsistent and too imprecise to conform to the requirement. In addition to describing factors which can singly cause an explosion, if certain combinations of factors must exist in order for the defect to occur these combinations should not be stated generally as you have done, but should be specifically described. Moreover, we indicated to you at the September 4 meeting that we disagree that broken beads and excessive pressure must exist in combination in order for an explosion to occur.

Most importantly, we cannot agree upon your characterization of the bolting of the tire to the wheel before inflation as a precaution the owner can take to reduce the chance that the malfunction will occur under @ 577.4(c)(4). Both literally and by implication your second and fourth paragraphs read that if the tire is bolted to the vehicle before inflation, an explosion will not occur. The malfunction, however, is an explosion of the tire, not only those explosions which cause injury. While we agree that bolting the tire to the vehicle before inflation can potentially reduce the chance of injury, it should be characterized only in this fashion. Therefore, both on page 1 of your letter and in the instructions which you begin on page 3 for persons who have need of the tire before its inspection by Goodrich, you must make it absolutely clear that bolting the tire to the vehicle has no effect whatever on whether the tire will explode, but that bolting will serve only to reduce the chance of injury if an explosion occurs.

We have the following points with respect to the remaining provisions of your letter. On page 2, in the first complete paragraph, beginning "In the majority of usage situations . . . etc" we find the use of the word "majority" confusing. The implication to us is that in a minority of situations the danger is not reduced at all. This should be clarified.

The third complete paragraph on page 2 is also confusing. There is no apparent connection between its first and second sentences. If you are attempting to say that despite what earlier labels may say that the instructions provided in this letter should be followed, then this can be stated more clearly.

The use of the word "solely" in the fourth paragraph on page 2 is a disclaimer, prohibited by section 577.6, and should be stricken.

On page 3, we believe the requirements of section 577.4(e)(1) call for more detail than you have provided in the third paragraph on page 3. We suggest you include a description of the inspection and test cycle. As we indicated to you on September 4, the second and third paragraphs could be combined for clarity. Finally, the second sentence in your second paragraph on page 3 should be reworded to indicate more clearly that the date you have inserted is the date by which repair facilities will have necessary parts and instructions. In its present wording the meaning of the sentence is unclear.

Apart from these deficiencies, we believe your letter conforms to 49 CFR Part 577. At the same time, we believe your letter unnecessarily obscures the safety problem, and hope that, apart from literal compliance with Part 577, this is eliminated in the letter sent to purchasers. You should note that our determination of the conformity of the letter to Part 577 does not in any way indicate our agreement with Goodrich's analysis of the safety defect. We will continue to look into this matter, as appropriate, in order to determine whether Goodrich's analysis of the defect, and its consequent remedy, are fair and accurate statements of the safety problem. You should be aware that if subsequent events do show that attributing the safety defect to a mounting problem does not adequately describe the defect, further notification may be required.

Yours Truly,

PROPOSED DRAFT

9/4/74

DEAR CUSTOMER:

This notice is sent to you in accordance with the requirements of the National Traffic and Motor Vehicle Safety Act.

The B.F. Goodrich Tire Company, a division of The B.F. Goodrich Company, has determined that a defect which relates to motor vehicle safety is caused when its Space Saver Spare tire is improperly mounted or subsequently remounted on the rim and is not properly seated on the rim. When the wheel is not securely bolted to the axle at the time the tire is inflated, the combination of broken tire beads and excessive air pressure can cause the tire to burst or erupt in which case serious personal injury or death can result.

Since the introduction of the Space Saver Spare in 1967, approximately 1,000,000 tires have been produced and provided to automobile manufacturers. During this period a total of nineteen injury cases, including two fatalities, have been reported.

Bursting or eruption of the Space Saver Spare tire assembly which has the potential of causing injury can only occur when some or all following three conditions are present:

1) A broken tire bead caused by improper mounting or remounting of the tire exists.

2) The tire is not securely bolted to the axle of the vehicle before inflation is started.

3) Excessive air pressure, from a high pressure air supply is forced into the tire.

In the majority of usage situations when the caution and warning labels are followed in a step by step fashion, the danger or potential of injury or serious accidents is greatly reduced. It is extremely important that at all times the Space Saver Spare tire is inflated with the approved canister (inflator) provided for road use of the tire.

Your Space Saver Spare tire was designed to be carried in a deflated condition, while being stored in the trunk of your vehicle. Its unique folding sidewall configuration permits the saving of considerable space in your trunk.

Many Space Saver Spare tires have been furnished with caution and/or warning labels. When the spare tire assembly is securely bolted to the axle of your vehicle before inflating with the canister bottle, and the tire is only inflated with the canister inflator, maximum safety will be achieved.

The above statements are made solely to comply with the notice procedures of the National Highway Traffic Safety Administration, 49 CFR, Part 577.4, and does not constitute an admission of liability or wrong doing on the part of the B.F. Goodrich Company, but is made to the public at large for the general purpose of improving highway safety.

Our review of the use of the Space Saver Spare has proven that unless specific instructions for installing and inflating the tire are followed, it could burst or erupt.

The B.F.Goodrich Tire Company is presently completing arrangements for conducting an inspection and inflate/deflate test cycle of your Space Saver Spare. Final details along with distribution of anticipated replacement components will be completed by

Date

Enclosed with this letter you will find a listing of all B.F.Goodrich Regional Service Departments. You are urged to contact the Service Department located most conveniently to your area, by collect phone call, and make arrangements to take your Space Saver Spare tire assembly to a designated service facility for inspection and test cycling. Inspection, test cycling and any necessary tire replacement will be provided at no charge to you. Since inspection and test cycling can take approximately one hour, we urge you to call the phone number listed above in order to make an appointment thereby avoiding long delays on your part.

If, prior to the time the inspection and test cycle have been completed you have need of your Space Saver Spare tire, it is important that follow these procedures:

1) Before inflating, bolt spare on car axle making sure that all lugs are securely fastened.

2) Rotate spare tire/wheel assembly so that the valve is down

3) Use only the canister inflator to inflate the tire. Inflate by holding canister bottle on tire valve approximately one minute after sound of gas flow stops.

4) This tire is designed for emergency use only. Return it to the spare tire position in the trunk of your vehicle as soon as possible.

5) When the Space Saver Spare is in use, do not exceed 50 MPH.

6) Do not remove Space Saver Spare tire from the wheel. Tire is not remountable. Do not use wheel cover on Space Saver Spare wheel as it may not be retained.

NOTE: If the canister inflator has been used, a replacement canister should be obtained.

Present this letter and enclosed form "Authorization for Space Saver Spare Inspection - Test Cycle" as authority for no charge inspection, test cycle and replacement of any malfunctioning compon

This is an important safety matter to you. We urge that you take action as described in this letter.

(Signed)

ID: nht74-3.29

DATE: 09/17/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: The Weatherland Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 14, 1974, pointing out a discrepancy in the constriction test requirements for hydraulic brake hose found in Federal Motor Vehicle Safety Standard No. 106-74.

We are considering a change in our next notice concerning Standard 106-74, so that S6.7.2(c) will conform with S5.3.1 as that paragraph was amended by Notice 11 (39 F.R. 24012).

Yours Truly,

The Weatherhead Company

August 15, 1974

Reference: MUE 486

Richard B. Dyson Assistant Chief Counsel -- NHTSA

Subject: FMVSS 571.106-74 Reference Notice 11 Docket 1-5

Your timely personal response to our request for clarification of the labeling of 1/8 inch O.D. SAE J844c nylon air brake tubing is sincerely appreciated. The NHTSA's determination to exempt this small sized tubing is reasonable, without adverse effect on vehicle safety, and sustains the usage of an economic product.

While preparing our corporate documentation to support product compliance with 571.106-74 a troublesome inconsistency was noted. Perhaps NHTSA can incorporate a minor change in the wording of Para. S6.7.2(c) in the next publication released concerning The Brake Hose Standard.

Paragraph S6.7.2(c) retains the Constriction Test requirement for the complete brake hose assembly stating: "Drain the brake hose assembly, immediately determine that every inside diameter of any section of the hose assembly is not less than 64% of the nominal inside diameter of the hose, and conduct the test specified in S6.2."

As you may recall Notice 11 excluded end fittings, distribution blocks and residual valves by amending constriction requirements to be applicable to only ". . . that part of the fitting in which hose is inserted".

Realizing this inconsistency in Para. S6.7.2(c) is an oversight and that it would not cause an unnecessary compliance variance, a repetitive petition is withheld pending correction.

Thank you once again for responding so promptly to our requests for clarification concerning this Standard.

John H.Mueller

Manager, Engineering Standards

cc: D. Delve

W. Redler

ID: nht74-3.3

DATE: 03/26/74

FROM: LAWRENCE R. SCHNEIDER -- NHTSA CHIEF COUNSEL

TO: BRIAN GILL -- AMERICAN HONDA MOTOR COMPANY, INC.

COPYEE: SCHWARTZ

TITLE: N40-30 [FWS]

TEXT: Dear Mr. Gill:

This is in response to your letter of February 22, 1974, requesting an official interpretation concerning the proposed amendment to Standard 108 (Docket No. 69-19, Notice 3). You wish to know whether a steady burning lamp which is combined with a turn signal lamp shall be deactivated when the turn signal is flashing as part of the hazard warning system. It is our view that a steady burning lamp must always be deactivated when the turn signal lamp is flashing, whether in the turning phase or the hazard warning phase.

Sincerely,

ID: nht74-3.30

DATE: 08/15/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: We confirm your interpretation of S5.3.2 of Motor Vehicle Safety Standard No. 105-75, expressed in your letter of August 2, 1974, to Dr. Gregory, that the engine "start" position may be used as a check position for indicator lamp function.

The phrase in S5.3.2 "when the ignition (start) switch is in a position between 'on' ('run') and 'start'" is intended to include both "on" and "start" as well as any position between.

Application of the parking brake as an indicator check will no longer be permitted for vehicles manufactured after the effective date of Standard 105-75.

ID: nht74-3.31

DATE: 09/06/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of August 14, 1974, requesting an interpretation of Motor Vehicle Safety Standard No. 106-74, Brake Hoses (Docket 1-5, Notice 11, published on June 28, 1974), regarding its applicability to specific hydraulic brake booster hoses used on General Motors products.

As indicated in Notice 11, it is the National Highway Traffic Safety Administration's (NHTSA) intention to exempt from the requirements of the standard hydraulic booster lines subject to a different working environment than brake hose, pending development of special performance requirements for such lines. General Motors' interpretation that the hydraulic booster hoses used in the systems described in your August 14 letter are exerpted from the standard requirements is correct. The system described in your Attachment A is considered to incorporate an accumulator integral with the brake booster assembly. Hence all of the hoses run between the power steering pump and the accumulator (either directly or via the power steering gear) and are accordingly exempted per the Notice 11 preamble. The hoses used in the system described in your Attachment B are exempted by virtue of the provision of redundant booster power by the independent electrohydraulic pump.

A future amendment to FMVSS 106 to eliminate ambiguity in respect to the standard's applicability to hydraulic booster hoses is currently under consideration. Any such amendment will be consistent with the present interpretation.

ID: nht74-3.32

DATE: 08/30/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Private Truck Council of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of July 25 and August 26, 1974, requesting information on NHTSA regulations applicable to regrooved tires.

You ask whether companies leasing trucks to other companies may equip the trucks with regrooved tires, and what tire standards apply.

The recent court decision regarding regrooved tires (NAMBO v. Volpe 483 F. 2d 1294 (D.C. Cir. 1973), Cert. denied, -- U.S. -- (1974)) held that under the National Traffic and Motor Vehicle Safety Act the NHTSA could permit only the sale of regrooved tires. Consequently, the leasing of regrooved tires is now prohibited, as is any other introduction of them into interstate commerce other than by a sale. The NHTSA recently amended its regrooved tire regulations to conform to this Court opinion.

We do not construe the opinion to prohibit the leasing of trucks equipped with regrooved tires. The regulation applies only to the manner in which the tires themselves are obtained.

The standards applicable to regrooved tires are found in the Regrooved Tire regulations (49 CFR Part 569). Regroovable tires manufactured after March 1, 1975, must also conform to Motor Vehicle Safety Standard No. 119.

ID: nht74-3.33

DATE: 09/04/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Bolt, Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 25, 1974, asking whether a new model Bunny Bear child seat ("Sweetheart Seat II") must meet the requirements of Standard No. 213 when the seat is used as an infant carrier. We received from Mr. Samuel Linden of Bunny Bear the tentative instruction sheet which will be furnished with this device. According to these instructions, the device is to be installed laterally across the vehicle seat when used as an infant carrier ("for children weighing 15 lbs. or less and unable to sit up alone") and in the traditional forward-facing mode when used as a child seating system ("by children capable of sitting upright by themselves, and weighing between 15 lbs. and 40 lbs., and whose height is between 24 inches and 40 inches"). The vehicle lap belt is installed differently in each mode, and an adjustment must also be made to the frame when converting from one mode to another.

We would not consider the device, when used as an infant carrier, to be a child seating system under Standard No. 213. It would consequently not be required to meet the standard's requirements when installed in that mode. Although S4.11.1 of Standard No. 213 does require that a child seating system in which the attitude of the child is adjustable meet the standard's requirements at each designed adjustment position, we believe the differences in installation for this Bunny Bear device are sufficiently extensive that the modification to an infant carrier is bona fide, and not merely a different adjustment position.

We are concerned, however, about the possibility that users may attempt to recline the device (by loosening and adjusting the wing nuts in the base) when the device is attached to the vehicle in the forward-facing position. Although this adjustment position is not mentioned in the instruction sheet, it seems from the sheet that such an adjustment is possible. The instruction on page 1 of the sheet reading, "[a]lways loosen the lap belt attached to the child seat when changing from one position to another," adds some further ambiguity on this point. Consequently, we believe that the seat must meet the requirements of Standard No. 213 when reclined in the forward-facing position unless the instruction sheet is changed to clearly indicate that the device should not be reclined when attached in that position.

In addition, because the device has a dual use, we believe the proposed certification statement appears on the first page of the instruction sheet is misleading. It implies that the device meets applicable Federal standards in all configurations, although no standards exist for infant carriers. Accordingly, the statement should reflect the fact that no Federal standards exist for infant carriers.

Bolt Beranek and Newman Inc.

July 25, 1974

Richard Dyson Acting Chief Counsel -- NHTSA

The purpose of this letter is to request clarification of the applicability of FMVSS 213.

For several years, Bolt Beranek and Newman Inc. has provided technical consulting and testing services to Bunny Bear, Inc. of Everett, Massachusetts, among other child seat manufacturers. Bunny Bear is now in the process of introducing to the market an unusual new child seat. In accordance with its customary practice, Bunny Bear has solicited BBN's opinion as to whether its new seat meets all requirements of FMVSS 213.

The new seat is convertible from a semirecumbent infant carrier to an upright child seat, and is designed to eliminate the need for purchasing two different restraint systems as a child grows. In its child seat mode, it is a conventional forward-facing child seat. In its infant carrier mode, however, it is installed so that the child sits in a semirecumbent position with its spine oriented perpendicularly to the longitudinal axis of the automobile. The seat label and instructions state explicitly that it is to be used in the semirecumbent, sideways-facing mode only for infants weighing less than 15 lbs and unable to sit upright by themselves.

S2 of FMVSS 213 states that "This standard does not apply . . . to systems for use only by recumbent or semirecumbent children." S4.11.1(b) requires that "A child seating system in which the attitude of the child is adjustable pursuant to the instructions provided in accordance with paragraph S4.2 shall meet these requirements at each designed adjustment position."

The question that concerns us here is whether FMVSS 213 is applicable to this child seat when it is used in its semirecumbent, sideways-facing mode. The answer to this question appears to hinge upon whether the two modes of seat use are viewed as separate types of seating systems or merely as different adjustment positions.

We believe that the semirecumbent mode does not represent a different adjustment position as that term is used in S4.11.1(b), but rather represents a conversion of the seat for use exclusively by semirecumbent infants weighing less than 15 lbs. This conversion will occur only once, when the child's weight reaches 15 lbs; the seat will not be adjusted back and forth from one mode to the other.

On the basis of this reasoning, we have advised Bunny Bear that we do not believe that FMVSS 213 applies to the seat when used in its semi-recumbent sideways-facing mode. We would appreciate your comments regarding the correctness of our interpretation, since, if it is not correct, we must devise some method of conducting performance tests for the seat when used in its infant carrier mode.

Duncan C. Miller

Samuel Linden, Bunny Bear, Inc.

Bunny Bear, Inc.

August 14, 1974

Micheal Peskoe National Highway Traffic Safety Adm.

As you know, Dr. Duncan Miller of Bolt, Beranek & Newman, Inc. has contacted you on behalf of Bunny Bear, Inc. requesting clarification of the applicability of FMVSS 213 to our new car seat when used in the semirecumbent infant carrier position and placed laterally on the automobile seat.

Dr. Miller has asked me to send you a copy of our instructions to help you in your evaluation of the child seating system.

Enclosed you will find a copy of the instruction booklet which, of course, will not be printed until the final clarification has been made. This is merely a copy of the proof. The information will illustrate exactly how this item is used.

Thank you for your consideration of this matter.

Samuel Linden Executive Vice President

cc: Duncan Miller

Bunny Bear

AMERICA'S OLDEST MANUFACTURER OF NURSERY NECESSITIES SINCE 1918

NURSERY LANE

EVERETT, MASS. 02149

INSTRUCTIONS

THE SWEETHEART SEAT II (trademark)

THIS SEAT IS DESIGNED TO CONFORM TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE.

GENERAL INSTRUCTIONS

Please read thoroughly and follow carefully all instructions so that all safety features designed and built into this seat will be effective.

The certification label attached to the back or bottom contains important information which must be followed for proper use of this child's seat. Please do not remove this label

Use only in passenger cars at seating positions having an adult seat belt which can be used as per instructions given inside.

NOT FOR USE AT SEATING POSITIONS WHERE AN AUTO SHOULDER BELT IS PERMANENTLY ATTACHED TO THE AUTO LAP BELT.

WE RECOMMEND THAT THIS CHILD SEAT BE USED IN THE CENTER OF THE REAR SEAT WHENEVER POSSIBLE. THIS WILL PROVIDE INCREASED PROTECTION FOR THE CHILD.

Always loosen the lap belt attached to the child seat when changing from one position to another.

Be sure shoulder straps go through bottom slot in seat back when used in infant carrier position and through the top slot when used in the full upright position. (See instructions inside).

The strap in back of the child seat connecting the top and bottom frames, should always be centered on the bottom frame. It spreads the distribution of impact forces when child seat is used in upright position.

FASTENING CHILD INTO INFANT CARRIER OR UPRIGHT POSITION

1. When used in infant carrier position, the shoulder harnesses should come through the bottom slot in the child seat back. (See Diagram C-1)

2. When used in the upright sitting position, the shoulder harnesses should come through the top slot in the child seat back. (Diagram C-1).

To change shoulder straps from one slot to another simply pull ends of shoulder straps through adjustment slides -- one on each shoulder strap -- releasing them from the harness system. Then pull straps back through the slot they are in and thread through other slot back to front. Rethread ends of web through slots of eye loops and then through adjustment slides - reconnecting the harness system. (Diagram C-2 & C-3).

(Graphics omitted)

3. With snap buckle released and 5 point harness system loose, place child in infant carrier or in upright position. (Diagram C-4).

4. Place the shoulder straps one over each shoulder of the child. (C-4).

5. Bring each end of lap belt together so that the eyes of the metal loops - one on each end of the lap belt -- overlap on top of each other, aligning the holes. (Diagram C-5).

6. Bring tongue of snap buckle through the eyes of the metal loops and snap together securely. (Diagram C-5).

7. All belts have adjustment slides (C2). Adjust lap belt and crotch strap to fit around child's hips and lap, not around child's waist. Adjust straps to fit as snugly as possible and still be comfortable Leave one inch of space between shoulder straps and child's chest. (C6).

8. Bring ends of all straps back through slides for added locking strength. (Diagram C-3).

(Graphics omitted)