Interpretation ID: 3064yy
First Company
9571 Alden
Lenexa, KS 66215
Dear Mr. McCormick:
This responds to your letter to Stephen Wood, our Assistant Chief Counsel for Rulemaking, seeking information about any provisions of Federal law that might apply to a belt positioning device for children. Based on the information provided in your letter, it appears that this device attaches to the seat back of the rear seat and includes an adjustable cushioned head support and an adjustable "convenience center," which serves to reroute the belt to offer a better belt fit for a child occupant of the position.
For your information, I have enclosed two letters in which we have provided a general description of how Federal requirements might apply to belt positioning devices. The first is a February 11, 1988 letter to Mr. Roderick Boutin and the other is a November 22, 1988 letter to Ms. Claire Haven. These letters explain the applicable Federal requirements and the letter to Mr. Boutin sets forth some safety concerns applicable to that particular design. In addition, I have enclosed an information sheet for new manufacturers of motor vehicles and motor vehicle equipment that explains how to obtain copies of our safety standards and other regulations.
I hope this information is helpful.
Sincerely,
Paul Jackson Rice Chief Counsel
D. 7/1/91