Interpretation ID: aiam3307
Senior Industrial Designer
Cosco
2525 State Street
Columbus
IN 47201;
Dear Mr. Knoedler: This responds to your letter of April 17, 1980, to Mr. Vladisla Radovich concerning Standard No. 213, *Child Restraint Systems*. Your letter was referred to my office for reply.; You asked if a child restraint has 'shoulder straps that attach to shield or barrier, and these straps in turn are connected to a crotch strap in continuous loop by way of going behind and then coming up from below the shell, would these belts then be considered an integral part of the shield and would attaching the crotch strap to the shield by means of a buckle be allowed?'; Standard No. 213, *Child Restraint Systems*, is intended to address among other things, the problem of misuse of child restraints. The principal misuse involves the failure to attach buckles and latches. To ensure that children using child restraints are afforded protection notwithstanding such misuse, the standard specifies that the belts are to be attached to restraining shield during testing only if they are an integral part of the shield. Webster's New Collegiate Dictionary (1977) defines 'integral' as meaning 'formed as a unit with another part.' Attachment of belts that are integral parts is permitted since they are intended to remain attached whether or not the restraint is in use and thus are not subject to the type of misuse described above. The crotch strap you describe is not an integral 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 connected to the shield every time the unit is used.; You also asked if belts that must be adjusted to fit a child ar prohibited by the standard. The standard does not prohibit adjustable belts. Section 5.4.2 of the standard does, however, establish requirements for any belt adjustment hardware used in the restraint.; Finally, you asked whether a surface, which is contactable by the tes dummy head, that 'is not a rigid surface but instead is a soft flexible part or sling type of surface' would have to be covered with energy absorbing foam. Section 5.2.3.1 provides that each child restraint system, other than a harness, which is recommended for use by children weighing less than 20 pounds must comply with the performance requirements of section 5.2.3.2. Section 5.2.3.2 provides that 'Each surface, except for protusions (sic) that comply with S5.2.4, which is contactable by the dummy head when the system is tested in accordance with S6.1 shall be covered with slow-recovery, energy- absorbing material' of specified characteristics. The requirement for padding applies to any surface contactable by the test dummy's head, regardless of whether the surface is rigid or flexible. If the contactable surface is made of a flexible material that would meet the thickness and performance requirements for energy-absorbing padding set in section 5.2.3.2(a) and (b), the surface would not have to have a separate layer of energy-absorbing padding placed on top of it.; If you have any additional questions, please let me know. Sincerely, Frank Berndt, Chief Counsel