Interpretation ID: 22892twobarsfromonerod

Mr. Chris Tinto
Director, Technical & Regulatory Affairs
Toyota Motor North America, Inc.
Washington Office
1850 M Street, NW, Suite 600
Washington, DC 20036

Dear Mr. Tinto:

This responds to your March 19, 2001, letter concerning Federal Motor Vehicle Safety Standard No. 225, "Child Restraint Anchorage Systems" (49 CFR '571.225). The standard requires the installation of child restraint anchorage systems consisting of two lower anchorages and a top tether anchorage. You ask about the configuration requirements specified in S9.1 for the lower anchorages.

Toyota would like to form the two lower anchorages by bending two bar segments from a long, continuous 6 millimeter (mm) diameter rod. According to the diagram you attached to your letter, each bar segment to which a child restraint would latch onto is approximately 35 mm long and parallel to the main portion of the rod. The rod is bent such that the bar segments protrude about 67 mm (about 2.5 inches) from the rest of the rod. You ask if forming the two lower anchorages from one continuous piece of rod would be permitted if the anchorages were so configured.

Our answer is yes, the bar segments are permitted to be configured as you described.

S9.1.1 of Standard No. 225 specifies that "[t]he lower anchorages shall consist of two bars that . . .  [a]re not more than 40 mm in length . . . ." ⁽¹⁾  Your question raises the issue of whether your anchorages consist of two bars. The bars are formed from one continuous rod. However, because the bars protrude 67 mm from the main portion of the rod and the part of the rod between the two bars would be in the seat bight and not visible to the consumer, two distinct bars are presented to consumers. A consumer is not likely to be confused about where a child restraint should be attached. We thus conclude that the lower anchorages consist of two bars, each of which is not more than 40 mm in length. We could have concluded otherwise had the bars not protruded 67 mm (or some other substantial distance) from the rest of the rod. For example, if they protruded only 10 mm from the rest of the rod, it would not be apparent that two bars are present. An anchorage system with such a design would not meet S9.1.1 of the standard.

I hope this information is helpful. If you have further questions, please contact Deirdre Fujita of my staff at (202) 3366-2992.

Sincerely,

John Womack
Acting Chief Counsel

Ref:225
d.7/30/01

1. ¹ The agency has received petitions for reconsideration asking that the maximum limit ofm 40 mm be deleted or increased to 50 mm. See Docket No. 98-3390, Notice 2. NHTSA will be responding to the petitions in the near future.