Interpretation ID: aiam3882
Senior Product Development Engineer
Fisher-Price Diversified Products
630 Girard Avenue
Last Aurora
NY 14052-1885;
Dear Mr. Merten: This responds to your letter to Mr. Oesch of my staff and to Mr Radovich of our Rulemaking division, seeking interpretations of the requirements of Standard No. 213, *Child restraint systems* (49 CFR S571.213). Specifically, you stated that your company plans to produce a new design of child restraint, which incorporates automatic belt retractors for the shoulder belts. These belts are permanently attached to a semi- rigid front restraining shield, which has a buckle built onto the bottom that attaches onto a tongue rigidly fixed within the seating surface. After connecting the buckle on the shield to the tongue, the parent must then push the shield toward the child so that it fits snugly. This automatically takes in the slack in the belts.; You asked two questions about the application of Standard No. 213 t this design of child restraint. The first concerned section S6.1.2.4, which specifies that, prior to testing, the belts on a child restraint shall be adjusted so that there is 1/4 inch of slack. The automatic belt retractors in your design may leave up to 3/4 inch of slack in the belts. You asked if the 1/4 inch slack requirement effectively prohibits the use of belts with an automatic retractor. It does not.; At the time Standard No. 213 took effect, all belts on child restrain systems then on the market were manually adjustable. Hence, they could be adjusted to introduce any amount of slack desired. To ensure that all child restraints would be tested under identical conditions, a provision was added to Standard No. 213 specifying the precise amount of slack which should be present. This specification of test conditions was not intended to establish a requirement that all belt systems on child restraints be manually adjustable, so that the specified amount of slack could be introduced. Instead, it was intended to function as an impartial specification for all belt systems, whether or not they were manually adjustable.; Section S6.1.2.4 sets forth the amount of slack to which all bel systems on child restraints should be adjusted before running the sled test. However, systems which are not manually adjustable may be tested with more slack present, since the greater slack would make the test more severe. No belt system, whether or not manually adjustable, can be tested with less than the specified 1/4 inch of slack, since that would make the test less severe for child restraints equipped with such a belt system. Section S6.1.2.4 is not intended to favor any particular type of belt system. Accordingly, you may test your child restraint with more than 1/4 inch of slack present in the belts.; The second question you asked was whether the language specified i section S5.5.2.(h) could be slightly modified for use on the labels to be affixed to your child restraints. That section requires that the following language appear on the label: 'Snugly adjust the belts provided with this child restraint against your child.' Since the belts on your child restraint will not be manually adjustable, you would like to modify the language to read: 'Snugly adjust the shield provided with this restraint against your child and test that the belts are locked.'; Your proposed modification would ensure that the directions, whic again were written with manually adjustable belts in mind, contained the appropriate modifications for belts with automatic retractors. Your proposed modification does not make any substantive change in the meaning of the directions specified for the label. Since the proposed change is a minor variation intended to clarify the language of the instructions for child restraints where the belts themselves are not manually adjustable, it is permitted.; Should you have any further questions or need further information o this subject, please contact Mr. Steve Kratzke of my staff at this address or by telephone at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel