Interpretation ID: aiam0286
Head
Traffic Sciences
Bolt (sic) Beranek and Newman
Inc.
50 Moulton Street
Cambridge
MA 02138;
Dear Mr. Dietrich: This is in reply to your letters, both dated December 16, 1970 concerning Motor Vehicle Safety Standard No. 213, Child Seating Systems.' One of these letters enclosed a request for clarification of two provisions of Standard No. 213. This request is presently under review and you should be hearing from the agency concerning it in the near future. You also enclosed in this letter a copy of a page from the 1970 Sears, Roebuck & Co. catalogue showing a child harness that is advertised as not a safety harness,' and ask whether this type of harness is exempt from the requirements of Motor Vehicle Safety Standard No. 209. The agency considers these types of harnesses to fall within the purview of Standard No. 209 and they are required to comply with the requirements for Type 3 seat belt assemblies as specified in S4. of that standard. Enforcement procedures are currently in progress in this area to eliminate those child harnesses that do not comply with the standard.; Your second letter requests that a study conducted by the University o Michigan Highway Safety Research Institute (Contract No. FH- 11-6962), entitled Integrated Seat - Restraint and Child Systems,' be placed in the public docket, and further request that the data films of the dynamic sled test be made available through the Docket.' The report to which you apparently refer has been placed in the general reference section of Docket 2-15. It is entitled Child Seat and Restraint Systems Test Program' but bears the same contact number as the one you request. With reference to your request for data films, these films are presently available for examination by the public through the agency's Research Institute, and information to this effect has been placed in the Docket.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel