Interpretation ID: aiam3243
Product Engineer
Cosco Home Products
2525 State Street
Columbus
IN 47201;
Dear Mr. Gerkin: This responds to your letter of January 23, 1980, to Mr. Vladisla Radovich concerning Standard No 213, *Child Restraint Systems*. Your letter was forwarded to my office for reply.; You asked whether a crotch strap that is 'permanently attached to movable shield can be attached during the 20 mph test required for child restraint systems that have fixed or movable shields (sic). Sections S6.1.2.3.1(c) and S6.1.2.3.2(b) provide that, in the 20 mph tests, the child restraint belts are not to be attached unless 'they are an integral part of the fixed or movable shield.' The agency used the word 'integral' in its ordinary sense to mean something that is 'formed as a unit with another part.' (Webster's New Collegiate Dictionary, 1977). A crotch strap that is permanently affixed to the shield is formed as a unit with the shield, and therefore, can remain attached during the test.; You also asked, whether, if the movable shield 'were designed in such way that moving it into position for use it automatically locked in that position, and a child was unable to unlock it', would the 20 mph test be conducted with the shield locked into place? Sections S6.1.2.3.1(c) and S6.1.2.3.2(b) provide that each movable surface is to be positioned in accordance with the manufacturer's instructions. Therefore, as long as your instructions explain how to lock the movable shield, it can be locked into place prior to the testing.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel