Interpretation ID: aiam3304
Assistant General Counsel
Questor Corporation
One John Goerlich Square
Toledo
OH 43691;
Dear Mr. Kramer: This responds to your letter of May 9, 1980,to Stephen Oesch of m office concerning Standard No. 213, *Child Restraint Systems*. You requested an interpretation of whether an alternative configuration you are considering for the Kantwet 'One Step' child restraint would comply with Section 6.1.2.2.1(c) of the standard.; You described the configuration as one in which the crotch strap woul be modified so that it 'is permanently attached to the shield (in a manner similar to the two upper torso restraints which the [agency's] April 29th letter stated were integral parts of the shield. The bottom end of the crotch strap would be buckled to the base of the seat between the child's legs after the child is seated.'; As you have described the modified crotch strap, it is an integral par of the movable shield since it is not a separate device that must be attached to the shield each time the restraint is used, but is formed as a unit with the shield. Since the crotch strap is an integral device, it can be attached during the testing of the restraint.; As mentioned in our letter of April 29, 1980, we urge that you an other manufacturers take the additional step of assuring that the upper torso restraint and the crotch strap permanently remain integral parts of the adjustment or anchorage device to which they are attached.; Sincerely, Frank Berndt, Chief Counsel