Interpretation ID: 24740GMF_width_of_latchbelt

Mr. Agus The
Project Engineer
AMSAFE Commercial Products
240-C N. 48^th Avenue
Phoenix, AZ 85043

Dear Mr. The:

This responds to your August 8, 2002, letter concerning whether Federal Motor Vehicle Safety Standard No. 213, Child Restraint Systems, permits the use of 1-inch webbing for use in "Lower Anchor and Upper Tether assemblies." [1] We understand you to ask whether you may use 1-inch webbing to permanently attach the components to a child restraint that enable the restraint to be securely fastened to the child restraint anchorage system specified in Standard No. 225. Our answer is yes, provided that the webbing meets the applicable performance requirements.

Federal Motor Vehicle Safety Standard No. 213 requires at S5.9 that "Each add-on child restraint system manufactured on or after September 1, 2002, other than a car bed, harness and belt-positioning seat, shall have components permanently attached to the system that enable the restraint to be securely fastened to the lower anchorages of the child restraint anchorage system specified in Standard No. 225 (571.225)." S5.4 of the standard addresses belts, belt buckles and belt webbing of child restraint systems. S5.4.1 states:

The webbing of belts provided with the child restraint system and used to attach the system to the vehicle or to restrain the child within the system shall

1. After being subjected to abrasion as specified in S5.1(d) or S5.3(c) of FMVSS 209 (571.209), have a breaking strength of not less than 75 percent of the strength of the unabraded webbing when tested in accordance with S5.1(b) of FMVSS 209.
2. Meet the requirements of S4.2 (e) and (f) of FMVSS No. 209 ( 571.209); and
3. If contactable by the test dummy torso when the system is tested in accordance with S6.1, have a width of not less than 1 inches when measured in accordance with S5.4.1.1." (Emphasis added.)

Based on your letter, it is our understanding that you are exploring the use of 1-inch wide webbing only for use in attaching the "LATCH" components to a child restraint. Therefore, we assume that the proposed webbing would not be "contactable by the test dummy torso." If it is so, the requirements of S5.4.1(c) are inapplicable to the webbing in question and do not prohibit you from using 1-inch-wide webbing.

While Standard No. 213 does not expressly restrict the use of webbing for the LATCH components on the basis of width, each child restraint must meet Standard No. 213s performance requirements in a dynamic test. Therefore, in making your decision on whether to provide slimmer webbing to child restraint system manufacturers, you should ensure that the restraints can comply with the dynamic testing requirements in the standard.

Finally, you ask whether 1-inch webbing would violate any future Federal motor vehicle safety standard. Please be advised that this interpretation letter pertains to current requirements and makes no representations about any future or proposed rule changes. Although we do not have any pending rulemakings pertaining to the width of webbing used to attach LATCH components, manufacturers bear the responsibility to keep abreast of all developments with the Federal standards.

I hope this information is helpful. If you have further questions, please feel free to contact Deirdre Fujita of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:213
d.1/30/03