Interpretation ID: aiam0620
Irvin Industries Inc.
51 Weaver Street
Greenwich
CT 06830;
Dear Mr. Danker: This is in reply to your letter of February 23, 1972, in which you lis information you wish to label on child seats you will manufacture, and ask whether the information as presented will comply with Motor Vehicle Safety Standard No. 213. You state that a label containing the model number, date of manufacture, and the company's name and place of business will be permanently affixed to the product, while a separate legend, containing other information, will be molded on the bottom of the seat in raised letters at least 3/32 inches high.; The labeling scheme you with to use would conform to paragraph S4. ('Labeling') of Standard No. 213, providing, of course, the blank spaces for model number and date of manufacture are appropriately filled in. We would suggest, however, that that part of the molded legend beginning '. . . and there is a minimum of 19 inches vertical clearance between this seating . . .', to the end of that provision be simplified to be more understandable to an ordinary consumer.; We are pleased to be of assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel