Interpretation ID: 1983-1.35

TYPE: INTERPRETATION-NHTSA

DATE: 03/30/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: TRANZ ACC Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 30 1983 NOA-30

Mr. Mike Grant TRANZ ACC Inc. 21807 Plummer Street Chatsworth, California 91311

Dear Mr. Grant:

This responds to your February 25, 1983, letter asking whether a child seat that you would like to import would comply with Standard No. 213, Child Restraint Systems. Your child seat attaches to a vehicle by use of several of its own anchorage straps which are attached to existing vehicle belt anchorages or by drilling new anchorages. The seat does not use the existing car seat belt system.

Paragraph S5.3.2 of the standard states: "When installed on a vehicle seat, each child restraint system, other than child harnesses, shall be capable of being restrained against forward movement solely by means of a Type I seat belt assembly (defined in S571.209) that meets Standard No. 208 (S571.208), or by means of a Type I seat belt assembly plus one additional anchorage strap that is supplied with the system and conforms to S5.4" Since your system has its own harnesses and does not utilize the existing car seat belt system (Type I seat belt), it would not comply with this portion of the standard.

The agency requires child seats to be attachable by use of the existing car seat system for ease of installation and to assist in proper installation and usage. The agency determined in rulemaking that to permit other systems that were more complex and that require the proper attachment of several harness straps would not be in the interest of safety, since it would likely result in improper child seat installation.

Sincerely,

Frank Berndt Chief Counsel

February 25, 1983

MR. FRANK BERNDT Chief Council U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 4O0 Seventh Street S.W. Washington D.C. 20590

Dear Sir,

I represent an accessory company who are interested in importing a child seat from England. The seat has passed the British and Dutch safety tests which are probably the most rigorous of its kind in Europe.

However, we think the method of attaching the seat is not covered by your current safety regulations. Due to the complex nature of your regulations I find it difficult to determine whether or not the seat complies with them, and I would appreciate your help and advice in this matter.

I have written to Barbara Kelleher of Arvin Calspan Corp. who advised me to write to you and explain our situation. We both agree that as far as safety standards are concerned the seat easily meets the requirments of Calspan's sled tests.

I am eager to have the seat tested and approved but this would seem little purpose until I receive a decision from your department as to the suitability of our method of attaching the child safety seat.

Please find enclosed fitting instructions and information about the seat and if you require any further information or a sample seat please don't hesitate to contact me.

Your earliest attention to this matter would be greatly appreciated.

Yours Sincerely

Mike Grant