Interpretation ID: nht80-2.10

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Union Springs Central School District

TITLE: FMVSS INTERPRETATION

TEXT:

APR 22 1980

Steven J. Kalies, Ed.D Asst. Supt. for Business Union Springs Central School District Union Springs, New York 13160

Dear Dr. Kalies:

This is in response to your letter of January 22, 1980, asking whether the Dubl-Life Saver Support restraint vest manufactured by Easy Way Products Co. is in compliance with applicable Federal motor vehicle safety standards. The advertisement you enclosed with your letter describes the Dubl-Life Saver as a support restraint vest for the safe transportation of all sizes of handicapped children in motor vehicles. The advertisement further claims that the safety belts used with the vest exceed "federal specifications".

Based on the information in the advertisement, it appears that the restraint vest does not provide pelvic restraint and thus does not comply with Standard No. 209, Seat Belt Assemblies. I have referred this matter to the agency's Office of Vehicle Safety Compliance for appropriate action.

The University of Michigan's Highway Safety Research Institute has conducted tests of various devices used to restrain handicapped children. I have enclosed a copy of a Society of Automotive Engineers paper describing the results of the testing.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

January 22, 1980

National Highway Traffic Safety Administration Office of Chief Counsel 400 7th St., S.W. Washington, D. C. 20590

Gentlemen:

As requested in the attached letter from Mr. Irving Rodness, Motor Vehicle Program Specialist, we are enclosing a copy of the brochure concerning the Dubl-Life Saver Support restraint vest from Easy Way Products Co.

Please advise as soon as possible if this vest meets federal specifications, as stated in the attached brochure.

Sincerely,

Steven J. Kalies, Ed.D Asst. Supt. for Business

jf Enc.

January 18, 1980

Mr. Steven J. Kalies Union Springs Central School District Union Springs, New York 13160

Dear Mr. Kalies:

During our telephone conversation, I envisioned the device you described being covered by our Federal Motor Vehicle Safety Standard (FMVSS) 209, Seat Belt Assemblies. By the description on the price sheet you enclosed in your letter of 1/8/80, I am now not too sure. This device may not be covered at all or is covered under our FMVSS 213, Child Restraint.

After a conversation with the NHTSA's Office of Chief Counsel, I am taking the liberty of forwarding your letter to them for their review and response. It would be helpful if a brochure or picture of this device could be sent to our Washington Office. If available, mail it to: NHTSA, Office of Chief Counsel (NOA-30), 400 7th Street, S.W., Washington, D.C. 20590, ATTN: Mr. Stephen L. Oesch. Thank you for bringing this matter to our attention.

Sincerely,

Irving Rodness Motor Vehice Program Specialist

cc: OCC NOA-30