Interpretation ID: aiam4285
Esq.
Brendel
Flanagan
Sendik & Fahl
S.C.
6324 West North Avenue
Milwaukee
Wisconsin 53213-2099;
Dear Mr. Fahl: This responds to your letter to Dr. Richard Strombotne, the chief o our Crashworthiness Division. In your letter, you posed three questions about child restraint systems. I will answer those questions in the order you presented them.; >>>1. Does NHTSA have information as to where a family with tw children 3 years of age or under should put the second of two child restraint systems, assuming that the safest place for one is the middle of the rear seat?<<<; NHTSA has not specifically addressed this topic in any of ou regulations or recommendations. We believe, however, that in this situation both child restraint systems should be placed in the rear seat. This belief is based on the generally greater distance from the rear seat to the interior surface in front of that seat and the fact that the interior surface in front of the rear seat is primarily the rear of the front seats. The rear of the front seats tends to be a less hostile surface than the dashboard. Additionally, crash data show that all vehicle occupants (both adults and children) suffer fewer injuries and fatalities in the rear seating positions than in the front seating positions.; >>>2. Has NHTSA developed any rules or regulations suggesting o requiring that manufacturers of child restraint systems advise the consumer where to put a second child restraint, assuming that two children under 3 years of age will be occupying a motor vehicle at the same time and also assuming that neither child restraint system is a backward facing system?<<<; No, NHTSA has not impose any such requirements. With respect to chil restraints manufactured before August 12, 1986, section S5.6.1 of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213) specified that: 'The instructions shall state that the rear center seating position is the safest seating positions to most vehicles for installing a child restraint system.' For child restraints manufactured on or after August 12, 1986, section S5.6.1 requires: 'The instructions shall state that, for maximum safety protection, child restraint system should be installed in a rear seating position in vehicle with two rear seating positions and in the center rear seating position in vehicles with such a seating position.'; NHTSA has somewhat modified its position about the rear *center seating position being the safest place to install a child restraint system in a recent rulemaking action amending Standard No. 210, *Seat Belt Assembly anchorages* (49 CFR S571.210). Please note that this standard applies only to vehicle manufacturers, and not to child restraint manufacturers. However, in an August 19, 1986 rule 951 FR 29552, copy enclosed), section S6(b) of Standard No. 210 requires the owners manual for vehicles manufactured after September 1, 1987 to state that 'according to accident statistics, children are safer when properly restrained in the rear seating positions that in the front seating positions.' We are currently considering whether Standard No. 213 should be amended to include similar language. However, neither of these requirements specifically addresses the situation where two child restraints are to be installed in the same vehicle.; >>>3. Has NHTSA done studies to determine that the right fron passenger seat is not an appropriate place for a child restraint system and, if so, what are the results of those studies?<<<; No study of which we are aware, whether done by this agency or an other party, suggests that the right front passenger seat is not an appropriate place for a child restraint system. In fact, those studies of which were are aware indicate that a properly installed child restraint system in the right front passenger seat will afford the child occupant a high level of safety protection in a crash situation. The safety protection can be maximized by properly installing the child restraint in a rear seating position, but we are aware of no basis for stating that the right front passenger seat is not an appropriate place for a child restraint system.; If you have any further questions on this subject need mor information, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.; Sincerely, Erika Z. Jones, Chief Counsel