Interpretation ID: aiam0288
Vice President
Century Products
Inc.
2150 W. 114th Street
Cleveland
OH 44102;
Dear Mr. Rocker: This is in reply to your letter of January 28, 1971, requesting a interpretation of Motor Vehicle Safety Standard No. 213. Although your letter refers to S4.11(d) as the paragraph with which you are concerned, it appears from the text of your letter that you are requesting an interpretation of paragraph S5.1(d).; S5.1 of the standard specifies the test procedure that will be used b NHTSA to determine whether the child seating system meets the force resistance requirements specified in S4.1 of the standard. S5.1(d), the passage in question, reads as follows:; >>>'Apply an increasing load to the torso block in a forward direction not more that 15 degrees and not less that 5 degrees above the horizontal, until a load of 1,000 pounds is achieved. The intersection of the load application line and the back surface of the torso block, at the time that the force removes the slack from the load application system, shall not be more that 8 inches or less that 6 inches above the bottom surface of the torso block. Maintain the 1,000-pound load for 10 seconds.'<<<; Your question is whether the angle at which the force is applied, eve though initially between 5 degrees and 15 degrees above the horizontal, may move outside the range during application of the specified force.; The answer to your question is no. The relevant wording of th standard, that the force is to be applied in a forward direction 'not more than 15 degrees and not less than 5 degrees above the horizontal, *until a load of 1,000 pounds is achieved*,' clearly requires that the direction of the test force remain within the specified angular limits throughout the period of force application.; Please write if you have further questions. Sincerely, Lawrence R. Schneider, Acting Chief Counsel