Interpretation ID: nht90-3.16

TYPE: Interpretation-NHTSA

DATE: July 12, 1990

FROM: Michael L. Hayes

TO: James Gilkey -- NHTSA

TITLE: Re Non Compliance to Standard 213 in the Transport Incubator

ATTACHMT: Attached to letter dated 1-15-91 from Paul J. Rice to Michael L. Hayes (A37; Std. 213; FMVSS 102(4)); Also attached to letter dated 7-12-90 from Michael L. Hayes to General Curry

TEXT:

In our resent phone conversation regarding transport safety for the new born infant which is transported in incubators, I brought to your attention that the child restraint equipment used in this area does not meet Standard 213. I have enclosed a sales brochure to illustrate my point. It is anticipated that the companies involved will claim that, due to the special circumstances involved in this type of transport, Standard 213 cannot be met and, thus, is not applicable to transport incubators. In view of this objection, I have included a copy of an engineering analysis of a restraint technique showing a design that can meet Standard 213 and meet the special needs of this type of transport as well.

It is estimated that close to 100,000 infants are transported in this type of equipment each year. If only one half of one percent of these infants are injured due to the lack of proper protection, this represents hundreds of needless injuries and possi bly scores of deaths.

The companies involved are aware of the moldable air-bag restraint technique and its ability to vastly improve the safety of the infant. However, the belief that it would not be profitable "enough" to up grade the transport incubator with proper occupant protection has lead to the continued sales of substandard equipment. This equipment is designed and sold specifically as a "transport" incubator in that its principal purpose is the transport of the infant. It is clear that if this equipment is capabl e of meeting child transport safety standards through specifically designed occupant protection systems the compliance should be halted.

I would like to ask that you take up this project on behalf of the infant and enforce Standard 213 as it applies to "car bed" type restraints.

Attachment

Air-Shields Vickers sales brochure entitled TI-100 Infant Transport Incubator (Text omitted)

Attachment

An Engineering Analysis of a Developmental Transport Restraint System for the Neonate by Michael L. Hayes and Dr. Brent Coleman (Text and graphics omitted)