Interpretation ID: aiam3404
Gateway Industries
Inc.
17512 Carriage Way Drive
Hazel Crest
IL 60429;
Dear Mr. Miskowicz: This responds to your letter of March 2, 1981, to Vladislav Radovic concerning Standard No. 213, *Child Restraint Systems*. Your letter was forwarded to this office for reply.; You asked whether a child restraint belt buckle must meet the buckl force release requirements when tested in an unloaded condition. In addition, you asked whether section 4.3(a) and 4.3(b) of Standard No. 209, *Seat Belt Assemblies*, are the only requirements of that standard which apply to buckles in child restraint systems. The answer is yes.; Section 5.4.3.5 of Standard No. 213 provides that each child restrain belt buckle, when tested in accordance with S6.2, must not release when a force of not more than 12 pounds is applied before the dynamic sled specified in S6.1 is conducted. The buckle must release when a force of 20 pounds is applied after the dynamic sled test. Section 6.2 provides that in conducting the belt buckle release force test, the appropriate test dummy is placed in the restraint and either a pull force of 20 pounds is applied, in the case of 6-month-old test dummy, or a 45 pound pull force is applied, in the case of the three-year-old test dummy. Thus, the buckle is not tested in an unloaded state.; Section 5.4.2 of the standard provides that each belt buckle has t conform to the 'requirements of S4.3(a) and S4.3(b) of FMVSS No. 209.' No other provisions of Standard No. 209 apply to belt buckles used in child restraints.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel