Interpretation ID: nht89-2.75

TYPE: INTERPRETATION-NHTSA

DATE: AUGUST 22, 1989

FROM: BARBARA J. KELLEHER-WALSH -- HARTLEY ASSOCIATES INC.

TO: DEIRDRE FUJITA -- OFFICE OF CHIEF COUNSEL

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 3-2-90 TO GEN. JERRY RALPH CURRY, NHTSA, FROM CONGRESSMAN HENRY J. NOWAK; ALSO ATTACHED TO LETTER DATED 2-20-90 TO HENRY J. NOWAK FROM BARBARA J. KELLEHER-WALSH, HARTLEY ASSOCS. INC., AND LETTER DATED 3-16-90 TO BARBARA J. KELLEHER-WALSH FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; STD. 213]

TEXT: I am a consultant to Century Products Co. for research, development, testing, and evaluation of child restraint systems. Century Products Co. has designed a sun visor for permanent attachment to the Century Model 580 rear-facing infant restraint system. The purpose of the sun visor is simply to protect the infant from the rays of the sun during travel.

This sun visor is constructed of polyester/cotton material with two polyethelene plastic ribs which hold the polyester/cotton material in-place above the infant's head. The forward plastic rib pivots about the shell and the mid rib pivots about the forw ard rib. The visor material is attached to these two stays but not to the restraint system shell itself. The sun visor is designed so that the polyester/cotton material slips over the rear of the infant restraint and is not permanently attached.

Mr. Stephen Kratzke, Office of Chief Counsel, has provided me with letters of interpretation concerning sun visors. These letters state that sun visors attached to child restraints recommended for use by children under 20 pounds must comply with Section 5.2.3.2 of Federal Motor Vehicle Safety Standard No. 213 (FMVSS 213) - Child Restraint Systems when tested according to Section 6.1. Subsequent to receiving these letters of interpretation, a sled test was performed with the Century Model 580 infant res traint with the sun visor in place. During the sled test the sun visor folded back into the storage position and did not contact the infant dummy's head. The sled test was performed in accordance with the requirements of FMVSS 213, S6.1, with the excep tion that the sled pulse exceeded the upper bound of the FMVSS 213 acceleration versus time window, thus assuring that this was a more severe test than NHTSA would perform during the annual testing for enforcement of the standard.

The purpose of this letter is to request an interpretation of S5.2.3.2 of FMVSS 213 with regard to the Century 580 infant restraint system with sun visor. We request a meeting with you along with members of rulemaking and enforcement on Thursday or Frid ay, August 24 or 25, 1989 to provide you with the restraint system, photographs, test data documenting the sled test conditions, and high speed movies of the test which demonstrate the lack of dummy head contact with the sun visor during the sled test.

If you have any questions I can be reached by telephone at (716) 892-6313. Our telefax number is (716) 897-0515.