Interpretation ID: aiam0712
Design Engineer
Hamilton Cosco
Inc.
State Street
Columbus
IN 47201;
Dear Mr. Parrott: This is in reply to your letter of May 4, 1972, posing certai questions concerning paragraph S4.10 of Motor Vehicle Safety Standard No. 213, 'Child Seating Systems.' You ask 'what criteria are to be used to determine whether an area is a contactable area under S4.10.'; The components that would be considered contactable by the head unde S4.10.1, or by the torso under S4.10.2, are any components which a child within the weight and height range for which the seat is recommended might contact in a 30 m.p.h. barrier crash, as represented by the test procedure specified in S5.1 and S5.2.; You also ask for clarification of the meaning of 'rigid side' as tha phrase is used in S4.10.3. As we indicated to you in our letter of February 23, 1972, manufacturers should rely on generally available definitions of 'rigid' in determining whether or not components are within the term. The reference to 'side' includes components placed both to the right and left, and forward of and behind the child occupant. Consequently, both an arm rest and a head rest (either separate from the back of a child seat or part of a one piece back of a child seat) could fall within the exemption of S4.10.3. The reference to 'back or side' in the proposed amendment to S4.10 published September 23, 1972 (35 F.R. 14786), is intended purely as a clarification of the existing language, the main thrust of the proposed revision would be, as stated in its preamble, to eliminate the exemption in the head- contact area.; With reference to the status of the September 23 proposal, a final rul based on this notice is still under consideration and we cannot presently provide an indication as to when it may become effective.; Yours truly, Richard B. Dyson, Assistant Chief Counsel