Interpretation ID: aiam0762
Executive Director
Consumers Union
256 Washington Street
Mount Vernon
NY 10550;
Dear Mr. Sandbach: This is in response to your letter of June 28, 1972, forwarding to us report to be published in the August issue of *Consumer Reports*, which raises numerous issues concerning child restraints and the efficacy of Motor Vehicle Safety Standard No. 213, 'Child Seating Systems.' You contend, based on testing you performed, that the static performance tests of the standard are meaningless, and that dynamic tests should be adopted.; We agree that a dynamic test should be included in the standard, and w discuss below our efforts and intentions in this regard. We also believe, however, that devices which conform to Standard No. 213 provide significant impact protection for children which is not available otherwise, and that the present standard has served a useful purpose in the development of effective child restraints and the removal from the marketplace of marginal products. We have pursued a vigorous enforcement policy with respect to the standard which has discovered and corrected numerous cases of noncompliance.; The 1,000-pound static test imposed by Standard No.213 was determine by the NHTSA to be an adequate first step in the development of standards for child seating systems. This determination was based, in part, on the state of the art of the development of these devices, and the financial resources of the affected industry. The limitations of the static test have been known for some time, and in the NHTSA *Program Plan for Motor Vehicle Safety Standards*, published in October 1971, the NHTSA made clear its intention to develop a dynamic test to measure the performance of all child restraint devices.; We believe the most effective way to utilize a dynamic test is t couple it with realistic injury criteria that reflect the ability of children to withstand crash impacts. This is the approach taken for adults by Standard No. 208, Occupant Crash Protection. Although we have developed adult injury criteria as part of our work on that standard, further work must be done to correlate these criteria with the protection needed for children.; Rather than delay dynamic testing until this work is completed however, the NHTSA plans to propose interim dynamic tests using other performance criteria which are presently being developed through research at the University of Michigan. We are also sponsoring other research on the problem of the development of realistic child dummies. Another problem in the development of a dynamic test for child seating systems, or any other performance requirements for them, is that the performance of the child seat is in large measure dependent upon the design and construction of the vehicle in which it is placed. Because manufacturers can market these devices economically only if they are suitable for large numbers of vehicles, an endless number of variables occur, with a resultant difficulty in prescribing reasonable 'worst case' test conditions.; We are presently working to provide answers to these questions, and ar hopeful that the research projects presently under way will provide data in the near future on which we can proceed. You mention that you will be submitting to us a petition for rulemaking regarding the standard. We request that you also submit to us any data which might assist us in solving these problems.; Sincerely, Douglas W. Toms, Administrator