Interpretation ID: aiam3342
Bartman
Braun & Halper
Suite 1015
1880 Century Park East
Los Angeles
CA 90067;
Dear Mr. Halper: This responds to your letter of May 28, 1980, on behalf of Californi Strolee, Inc. (Strolee), to Stephen Oesch of my office and to the questions you asked during your meeting of August 7 with members of the agency's staff. Both your letter and your meeting concerned Standard No. 213, *Child Restraint Systems*. You asked whether Strolee's prototype child restraint, described in your letter and demonstrated at the meeting, must be tested in accordance with section 6.1.2.1.2 of the standard and, if so, whether the agency will attach the harness system of the child restraint during that testing. The answers are that the child restraint must be tested in accordance with section 6.1.2.1.2 and the agency will attach the harness during that testing.; Your May 29, 1980, letter, describing Strolee's future product plans requested confidentiality for Strolee's request for interpretation and the agency's response. At your August 7, 1980, meeting, you informed Mr. Oesch that Strolee had decided to withdraw its request for confidentiality.; The child restraint described in your letter and demonstrated to th agency has a movable shield. The shield is attached to each side of the restraint by a pivot mechanism, which has a spring that lifts the shield. Because the movable shield is spring-loaded, it must be mechanically held down or it will automatically raise the shield above the child's head. Attached to the lower part of the child restraint is a crotch strap with a buckle on one end. The crotch strap is intended to be manually passed through a loop mounted on the bottom of the movable shield and attached to the other portions of the five point harness system within the restraint.; The other portions of the harness system consist of two straps, eac strap serves as an upper and lower torso restraint. Each strap has a movable metal latchplate which is inserted into the buckle attached to the crotch strap.; Once the crotch strap is passed through the loop mounted on the shiel and attached to the harness system, the shield is held in place in front of the child. The five point harness system provides the primary restraint of the child, but the movable shield, which will be designed to comply with the shape and radius of curvature requirements of section 5.2.2.1(c) of the standard, also provides restraint in a crash.; Your first question was whether the child restraint must be tested i accordance with test configuration II specified in Section 6.1.2.1.2 of the standard. More specifically, the issue is whether the Strolee shield is the sort of restraining surface described in section 5.2.2.2. As explained below, the answer is yes. The Strolee child restraint will be tested in accordance with test configuration II. When tested in that configuration, it will not have its top tether attached.; Section 5.2.2.2 of the standard requires that: >>>Each forward facing child restraint system shall have no fixed o movable surface directly forward of the dummy and intersected by a horizontal line parallel to the SORL and passing through any portion of the dummy, except for surfaces which restrain the dummy when the system is tested in accordance with S6.1.2.1.2 so that the child restraint system shall conform to the requirements of S5.1.2 and S5.1.3.1.<<<; When the Strolee child restraint is used in accordance with th manufacturer's instructions, the crotch strap is passed through the loop on the movable shield and attached to the harness system. Once that action is taken, the movable shield is positioned in front of the test dummy. Although the five point harness system provides the primary restraint in the Strolee system, the shield also provides restraint. Therefore, the child restraint must be tested in accordance with section 6.1.2.1.2.; Your second question, raised during your meeting, was whether th agency would attach the crotch strap of the Strolee child restraint if the restraint must be tested in accordance with section 6.1.2.1.2. The answer is yes.; Section 6.1.2.3.1.(c) of the standard provides that in the 20 mph tes of forward facing child restraints with fixed or movable surfaces that restrain the child, the restraint system's belts are not to be attached 'unless they are an integral part of the fixed or movable surface.'; The crotch strap used in the Strolee child restraint is not an integra part of the movable shield. The movable shield is a complete unit by itself. The crotch strap is a separate device that must be manually passed through a loop mounted on the shield every time the unit is used.; The rationale for the integral belt requirement involves the principa misuse of child restraints, which is the failure to attach buckles. This failure is often associated with child restraints having movable surfaces that can be positioned in front of the child. Parents mistakenly assume that such surfaces by themselves would provide sufficient protection and thus do not buckle the harness system in the restraint. To reduce that misuse, the agency established the requirement that belts may be attached during the testing of restraints equipped with movable shields only if they are integral parts of the shield. Attachment of belts that are integral parts is permitted since they remain attached to the restraining shield whether or not the restraint is in use. In addition, the need to buckle those belts is more readily apparent than in the case of belts that are not integral parts of the shield. Thus, the integral belts are not subject to the type of misuse described above.; This rationale applies to belts on a child restraint having a movabl restraining shield that is not spring-loaded. It does not, however, apply to a nonintegral belt on a restraint having a spring-loaded movable shield, if that shield can be held in place only by attaching the nonintegral belt so as to fully and properly restrain the child. The Strolee spring-loaded movable shield will not stay in place in front of the child unless the crotch strap is attached. If the crotch strap is not fastened to the remaining portions of the Strolee child restraint, the movable shield automatically rises above the child's head to signal that the buckle is unfastened and the child is unrestrained. Requiring the crotch strap to be an integral part of the movable restraining shield is unnecessary if the movable shield can only be positioned in front of the child when the child is properly restrained.; The agency originally had several concerns about whether the movabl shield in the Strolee child restraint could be positioned in front of the child without fully and properly restraining the child. One concern was whether the crotch strap and buckle could be passed through the loop mounted on the shield without attaching it to the remaining portion of the harness and the weight of the buckle would hold the shield in place in front of the child. At the meeting, you explained that the large buckle used on the prototype was for demonstration purposes only. Strolee demonstrated a smaller, lighter push-button buckle which would be used on production models and which could not hold down the movable shield by its own weight.; Another concern was whether the crotch strap and buckle could be passe through the loop on the movable shield and attached to only one of the two remaining straps of the harness system. Thus, the shield could be in front of the child, but the child would not be fully and properly restrained because a portion of the five-point harness system would not be connected. An examination of current restraint systems should show that one child restraint is already using a similar type of five-point harness as used in the Strolee system. The agency has not received any reports that parents are connecting only one half of that harness system. In addition, the need to connect both straps is readily apparent, since the buckle on the crotch strap has a separate receptacle for the latchplate on each belt.; The agency is still concerned about the durability of a spring-loade system such as Strolee's. To properly perform its function, the spring must have sufficient force to slowly but repeatedly, raise the movable shield. Further, child restraints are traditionally handed down from child to child and family to family. We, therefore, urge Strolee to design the spring so that it will have sufficient durability to withstand at least several years of repeated use.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel