Interpretation ID: aiam0153
Jr.
Automotive Safety Engineer
Consumers Union
Auto Test Division
367 Boston Post Road
Orange
CT 06477;
Dear Mr. Ulman: Thank you for your letters of March 17, 1969, and March 26, 1969 pertaining to certain child restraint devices and whether or not they are covered by Federal Motor Vehicle Safety Standard No. 209. Your specific questions and our corresponding answers are as follows:; >>>Question No. 1: Which of the commercially available devices mus comply with the Type 3 requirements of Standard No. 209, which must not?; Answer No. 1: Child restraint devices must comply with the Type requirements of Standard No. 209 if, by visual examination of the design and the advertising thereof, they are sold as being a Type 3 seat belt assembly. By definition, a Type 3 seat belt assembly is a combination pelvic and upper torso restraint for persons weighing not more than 50 pounds or 23 kilograms and capable of sitting upright by themselves, that is children in the approximate age range of 8 months to 6 years.; Question No. 2: How does one tell whether a given device is covered o not?; Answer No. 2: If the manifested purpose of any belt, strap, webbing o similar device is to secure a person in a motor vehicle in order to mitigate the results of any accident, then the belt has to comply with the applicable portions of Standard No. 209. There is a distinct difference between a child seating system' and a seat belt used to restrain a child. Child seating system' means an item of motor vehicle equipment for seating and restraining a child being transported in a passenger car. This child seating system is not covered by Standard No. 209, but will be covered by a future standard.; Question No. 3: Is the criterion (that a given device must comply whether or not the maker claims that the device offers protection against impact injury?; Answer No. 3: Whether or not the maker of a child restraining bel claims that the device offers protection against impact injury is not the criterion upon which the compliance interpretation is based. (Reference Answer No. 2)<<<; Further investigation is needed before we can provide an answer to you question pertaining to which specific manufacturers of the belts that you tested are in violation.; To assist you in your project on child restraint devices, we ar enclosing the latest copy of Federal Motor Vehicle Safety Standard No. 209 and the copy of the Notice of Proposed Rule Making on child restraint systems.; We trust that we have been of assistance to you. Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service;