Interpretation ID: nht80-2.3

DATE: 04/15/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cosco Home Products

TITLE: FMVSS INTERPRETATION

TEXT:

APR 15 1980

NOA-30

Mr. Don Gerkin Product Engineer Cosco Home Products 2525 State Street Columbus, Indiana 47201

Dear Mr. Gerkin:

This responds to your letter of January 23, 1980, to Mr. Vladislav Radovich concerning Standard No. 213, Child Restraint Systems. Your letter was forwarded to my office for reply.

You asked whether a crotch strap that is "permanently attached to a movable shield can be attached during the 20 mph test required for child restraint systems that have fixed or movable shields. Sections S6.1.2.3.1(c) and S6.1.2.3.2(b) provide that, in the 20 mph tests, the child restraint belts are not to be attached unless "they are an integral part of the fixed or movable shield." The agency used the word "integral" in its ordinary sense to mean something that is "formed as a unit with another part." (Webster's New Collegiate Dictionary, 1977). A crotch strap that is permanently affixed to the shield is formed as a unit with the shield, and therefore, can remain attached during the test.

You also asked, whether, if the movable shield "were designed in such a way that moving it into position for use it automatically locked in that position, and a child was unable to unlock it", would the 20 mph test be conducted with the shield locked into place? Sections S6.1.2.3.1(c) and S6.1.2.3.2(b) provide that each movable surface is to be positioned in accordance with the manufacturer's instructions. Therefore, as long as your instructions explain how to lock the movable shield, it can be locked into place prior to the testing.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

Mr. Vladislav Radovich Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590

January 23, 1980

RE: (49CFR Part 571) (Docket No. 74-9; Notice 6)

Dear Mr. Radovich:

After reviewing our arm rest model and shield model Child Restraints, it is obvious we can salvage nothing. We must start over with some new concepts.

As there is no time for us to waste, we need the Agency's official answer on some points in order to continue.

1. If a barrier were designed in such a way that the top end of the crotch strap was permanently attached to it. The other end of the strap was removable from its anchorage point below the plastic shell attached to a frame only by removing some hardware that is never intended to be removed as long as the barrier is attached to the child restraint.

Can the 20 MPH test for compliance be conducted with the barrier and crotch strap hooked up as described above?

2. If a barrier were designed in such a way that moving it into position for use it automatically locked in that position, and a child was unable to unlock it. Would the 20 MPH test for compliance be conducted with it locked as described above?

We would appreciate your attention to these points at the earliest moment.

Sincerely,

Don Gerken Product Engineer

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