Interpretation ID: nht91-1.41

DATE: February 14, 1991

FROM: Michael L. Harmon -- President, Classic Interiors

TO: Paul J. Rice -- Chief Console

TITLE: None

ATTACHMT: Attached to letter dated 6-12-91 from Paul Jackson Rice to Michael L. Harmon (A38; Std. 213)

TEXT:

It was brought to my attention after having a conversation with Dee Fujita that the built in child restraint system (photo enclosed) we developed and tested to FMVSS 213 for use in multi purpose passenger vehicles may or may not comply with code 213's definition and/or application of built in child restraint systems. If you could please clarify S4. of Part 571 of FMVSS 213 defining a "build in child restraint system" as to whether or not the use as an"integral part of a passenger car" includes multi purpose passenger vehicles. If it is considered part of please advise if not what can I do to encourage the inclusion of multi purpose passenger vehicles in the code 213 test standards.

Attachment

CHILD RESTRAINT SYSTEM TEST RESULTS

Tests conducted for CLASSIC INTERIORS

Purchase order M. Harmon

TEST NUMBERS: HF 9003-07 Testing date: October 25-30, 1990

The University of Michigan Medical School Department of Surgery, Pediatric Surgery Section

Child Passenger Protection Research Program c/o UMTRI, 2901 Baxter Road, Ann Arbor, MI 48109

Test methods and data limitations and use. (Text omitted)

CHILD RESTRAINT SYSTEM Test Number: HF 9007 TEST DATA SUMMARY Test Date: 10/30/90 Model: Hassel Free Safety Seat integrated in Classic Interiors chair, Dygert frame with stop pins, Atwood track, Monitor reinforced pedistal

Manufacturing Status: experimental

SET-UP

Part 572 3-year-old Frontal impact Forward facing 30 mph, 20 G Chair full rearward Seatback at 4th detent

RESULTS Average Velocity 30.5 mph Acceleration 20.4 G

Buckle Release Force Pre-Test NA Post-Test NA

Head Excursion 27.4 in. Knee Excursion 20.0 in.

Head Injury Criterion 343 Interval 85 to 188 ms Chest Peak Resultant 32 G Duration over 60 G 0 ms

Seatback/Cushion Angle Maximum 62 deg.

Post-Test 83 deg. (right)

Comments: No head/leg contact. Seatback latch operational after test. More seatback rotation on left side, where back of-frame slipped past stop.

Sled Profile and Head Acceleration and Chest Acceleration Graphs dated 10-30-90. (Graphs omitted)

Brochure describing the Classic Safety Seating System. (Text and photos omitted.)

Copy of Federal Register, section 571.1. (Text omitted.)

Copy of 49 CFR Part 571, dated 3-23-87, proposed rules dealing with FMVSS - Child Restraint Systems. (Text omitted.)

Copy of 49 CFR Part 571, dated 1-22-88, final rule. (Text omitted.)

Copy of Part 552.1-552.9 petitions for rulemaking, defect & noncompliance orders. (Text omitted.)