Interpretation ID: aiam1730
P.O. Box 172
Action
MA 01720;
Dear Ms. Nolan: A copy of your October 21, 1975, letter to Peterson Baby Products ha been forwarded to this agency by the Consumer Product Safety Commission for our consideration. In your letter, you indicated to the Peterson Company that you have experienced problems with their 'safety shell' child carrier as follows: A child can climb out of one model, vehicle seat belts do not readily attach to one model, while in both models, directions for adjustment of a tether strap appear inadequate, the child harness system does not adjust easily, and the padding materials are insufficiently durable.; Safety Standard No. 213, *Child Seating Systems*, regulates certai safety aspects of the type of child restraint system that seats a child for transportation in a motor vehicle. Peterson products subject to the requirements of the standard have been tested under NHTSA enforcement programs without failure.; Standard No. 213 does not include durability requirements for th padding or other material of the device. The standard does establish requirements for the retention of a simulated child's torso in the system when it is subject to frontal crash forces. This test, however, would not ensure that a child would be retained in the system if it attempted to release itself from the system. A 'child proof' system would make routine release by the parent extremely difficult.; As for belt webbing, the present standard only requires tha installation instructions be provided with the system, and that the webbing fit snugly those children for which the system is recommended. There are no requirements for the ease of seat belt hardware operation.; The NHTSA has proposed a more comprehensive child restraint standar that would regulate all child restraint systems, and would subject them to testing under dynamic loads that should result in upgraded performance of child restraint systems. I have forwarded your letter to the public docket on this rulemaking so that your views will be considered in the rulemaking process.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;