Interpretation ID: 86-6.27

TYPE: INTERPRETATION-NHTSA

DATE: 12/31/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ms. Barbara J. Kelleher -- CRS Research

TITLE: FMVSS INTERPRETATION

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

TEXT:

Ms. Barbara J. Kelleher CRS Research Buffalo, NY 14226

This responds to your letter to Stephen Kratzke of my staff, seeking an interpretation of Standard No. 213, Child Restraint Systems (49 CFR S571.213). Specifically, you stated that a client planned to produce two child restraint models whose harness and crotch straps would be integral parts of a movable shield. You stated your belief that these straps were an integral part of the shield within the meaning of section S6.1.2.3.1(c) of Standard No. 213. Accordingly, you asked that this agency permit these straps to be attached during the Configuration II testing required by section S6.1.2.1.2. You stated that a similar request for harness attachment was "granted" to the Collier-Keyworth Company.

First, I would like to make clear that this agency does not grant requests by manufacturers to avoid following the compliance test procedures specified in Standard No. 213. He interpret the requirements of Standard No. 213 as they apply to particular factual situations. When those same factual situations arise again, our interpretation of the requirements is the same, regardless of which manufacturer is involved.

For your information, I have enclosed a copy of a July 3, 1985, letter this agency sent to Mr. Frederick Locker, addressing whether a proposed Collier-Keyworth child restraint could attach its belts during the Configuration II testing. We concluded that belts that are attached to and not easily removed from a movable shield are integral parts of/the shield, within the meaning of section S6.1.2.3(c). This conclusion means that these belts may be attached during the Configuration II testing.

Judging by the pictures enclosed with your letter, it appears that of the two child restraint models designed by your client also has belts that are attached to and not easily removed from the movable shield. If our belief is correct, those belts could be attached during the Configuration II testing.

If you have any further questions or need more information on this subject, please contact Mr. Kratzke at this address or by telephone at (202) 346-2992.

Sincerely,

Erika Z. Jones Chief Counsel

October 1, 1986

Mr. Stephen R. Kratzke, NOA-32 U.S. Department of Transportation National Highway Traffic Safety Administration Room 5219 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Kratzke:

I have been retained by Century Products Inc, to request an interpretation of section S5.1.2.3.1.(c) of Federal Motor Vehicle Safety Standard Number 213 (FMVSS 213) - Child Restraint Systems (48 CFR 571.213) with regard to Century's Model 3000 and Model 400-XL child restraint systems. Since the harness and crotch strap belts of the Model 3000, and the harness belts and the crotch restraint mechanism of the Model 400 XL are integral parts of a movable surface as described in section S5.2.2.2, we request that the belts of these models be attached during Configuration II sled testing. As similar test for harness attachment during Configuration II testing was granted to the Collier-Keyworth Company on July 3, 1985 for a comparable restraint system with an integral harness/shield/crotch strap design. Photographs of Century's Model 400XL restrain systems are enclosed as figures 1 through 5.

The Model 3000 restraint system, figure 1, utilizes harness straps over each shoulder for upper torso restraint and a webbing and buckle crotch strap for lower torso and extremity restraint. Both are integrated with the movable shield in a continuous loop harness and cannot be easily removed. When the shield is lowered the harness straps over each shoulder of the child occupant and the crotch strap must be attached to the seat belt base between the child's legs. Although it is obvious that the crotch strap must be buckled (as a permanent part of the shield) we have also attached a warning label to the crotch strap webbing, figure 2, explaining the need to buckle the crotch strap to preclude any misinterpretation by the consumer.

The Model 400-XL, figure 3, has an integral harness design with straps passing over each shoulder of the child when the shield is lowered. Lower torso protection is provided by a combination shield/crotch restraint design that buckles into the seat base. The crotch restraint mechanism of the Model 400-XL and the shield that provides the lower torso and extremity restraint for the child are one piece and therefore cannot be separated. This shield cannot be properly positioned for a child unless the crotch portion is buckled into the seat base. In order to misuse this design a consumer would have to deliberately remove the harness straps which are threaded through the shield and secured with plastic tips, figure 4. The latching mechanism of the shield has a red label permanently attached to indicate when the shield is not properly latched, figure 5.

We would appreciate a reply to this request at your earliest convenience. If you require more information, please call me at (716) 674-48822.

Sincerely,

Barbara J. Kelleher

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