Interpretation ID: 86-5.35

TYPE: INTERPRETATION-NHTSA

DATE: 10/24/86

FROM: AUTHOR UNAVAILABLE; Erika Z.Jones; NHTSA

TO: Paul Meeker -- Senior Product Designer, Century Products, Inc.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 6/3/85 letter from Jeffrey Miller to Frederick Locker (Std. 213)

TEXT:

Mr Paul Meeker Senior Product Designer Century Products, Inc. 1366 Commerce Drive Stow, OH 44224-1793

This responds to your letter to Mr. Vladislav Radovich of our Rulemaking division, seeking an interpretation of Standard No. 213, Child Restraint Systems (49 CFR S571.213). Specifically, you noted that Collier-Keyworth now sells a child seat with a movable shield that is not spring-loaded. A movable shield that is not spring-loaded will remain in position in front of the child seat occupant, even if the crotch strap attached to the shield is not properly fastened. You stated that your company would like to build a child seat with a movable shield that is not spring-loaded, and stated your opinion that shields need not be spring-loaded to comply with the requirements of Standard No. 213.

Your opinion is correct if read narrowly, because no provision of Standard No. 213 requires or ever has required movable shields on child restraints to be spring-loaded. However, if a child restraint incorporates a movable shield, section S6.1.2.1.2 of Standard No. 213 specifies that the child restraint must be certified as complying with test configuration II. In test configuration II, the child restraints subjected to a 20 mile per hour frontal crash. Section S6.1.2.3.1(c) provides that none of the child restraint must be attached during this test, unless the belts are an integral part of the movable shield. Because of this requirement and the agency's interpretations thereof, child restraints have generally incorporated spring-loaded movable shields. This agency discussed these provisions and their applicability to the Collier-Keyworth non-spring-loaded shields at length in a July 1985, letter to Mr. Frederick Locker. I have enclosed a copy of this letter for your information.

If you have any further questions about this subject after reviewing the letter to Mr. Locker, please contact Mr. Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

See 6/3/85 letter from Jeffrey R. Miller to Frederick B. Locker

July 31, 1986

Mr. Val Radovitch DEPARTMENT OF TRANSPORTATION

Thank you for taking time to visit with Barbara Kelleher, Bob Quinlin and me on July 30.

Per our conversation, I am enclosing a copy of the Collier "Classic" Car Seat literature which shows its non-spring-load flip-over shield.

As we discussed, Century would like to build a seat with a similar flip-over shield and is concerned about whether it is necessary to spring-load the shield. Our opinion is that this type of shield meets the standard without spring-loading.

Will you comment?

Best Regards,

Paul Meeker Senior Product Designer

PM/dg enc.