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Interpretation ID: 22044



    Mr. Matthias Friedrich
    Managing Director
    Van Riesen GmbH+CoKG
    IndustriestraBe 10
    D-32130 Enger
    Denmark


    Dear Mr. Friedrich:

    This is in response to your letter asking whether the buckle release on your child restraint system meets the area requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, "Child Restraint Systems." The answer is no.

    S5.4.3.5(c) of Standard No. 213 requires any buckle in a child restraint system to "[m]eet the requirements of S4.3(d)(2) of FMVSS No. 209 ( 571.209), except that the minimum surface area for child restraint buckles designed for push button application shall be 0.6 square inch." You state that your buckle release design would meet this requirement if we add the "press" area (0.39 square inch) of the release button to the bottom area (0.23 square inch) of the release button.

    We do not consider your buckle release to be designed for push button application because a sliding action activates the buckle release. In fact, it is apparent from your letter that you concur that the buckle release is not of a push button type. You state in your letter: "The button is not a push-button as described in the FMVSS-standard, [sic] it is as [sic] slide action release button . . . ." Since your buckle release is not designed for push button application, the 0.6 square inch minimum surface area requirement in S5.4.3.5(c) does not apply.

    S4.3(d)(2) of Standard No. 209 reads:

      A buckle designed for pushbutton application of buckle release force shall have a minimum of 452 mm with a minimum linear dimension of 10 mm for applying the release force, or a buckle designed for lever application of buckle release force shall permit the insertion of a cylinder 10 mm in diameter and 38 mm in length to at least the midpoint of the cylinder along the cylinder's entire length in the actuation portion of the buckle release. A buckle having other design for release shall have adequate access for two or more fingers to actuate release.

    (Emphasis added.)

    Because your buckle release is designed for slide application rather than push button or lever application, your buckle release falls under the "other design for release" category. Under the last sentence of S4.3(d)(2), it must have adequate access for two or more fingers to actuate release. None of our staff working on this response was able to place two fingers into your slide action release button to actuate release, and you do not claim otherwise. Thus, we do not agree that your buckle release meets the requirement of S4.3(d)(2).

    If you have any further questions, please feel free to contact Mr. Dion Casey of this office at (202) 366-2992.

    Sincerely,

    John Womack
    Acting Chief Counsel

    ref:213#209
    d.2/6/01