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Interpretation ID: 21411



    Mr. Eduardo A. Favela
    P.O. Box 19995
    Denver, CO 80219


    Dear Mr. Favela:

    This responds to your March 15, 2000, letter concerning a product that you have developed, called Seatlock. You ask whether the Seatlock is subject to any Federal standards or safety guidelines, and also ask if we have any safety concerns about the product.

    You describe the Seatlock in a letter and in diagrams available on a web page. According to your letter and the information on your web page, the Seatlock is a device designed for use with child restraint systems, to reduce any slack left in the lap and shoulder belt used to secure the child seat in the vehicle. The Seatlock consists of a ratchet locking mechanism attached to a metal fork which slides over the webbing of the existing seat belt. Once the child seat is secured in the vehicle and the seat belt is fastened, the ratchet on the Seatlock is turned so that the belt webbing winds around the Seatlock's metal fork. As the ratchet mechanism allow the fork to turn in only one direction, the operation of the Seatlock tightens the seat belt and removes any slack. A release mechanism incorporated into the device can be used to release the tension on the seat belt so that the Seatlock can be removed. You state that the Seatlock does not interfere with the normal operation of the seat belt.

    By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, Congress has established a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the information set forth in your letter.

    There currently are no Federal motor vehicle safety standards that directly apply to the Seatlock. Our standard for "child restraint systems," Standard 213, applies to "any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less." The standard does not apply to accessory items, such as a supplemental belt that is used with a child safety seat. NHTSA also does not consider the Seatlock to be a seat belt assembly subject to Standard 209, as it is a supplemental accessory to the existing seat belt assembly and not intended to be used alone.

    While no standard applies to the Seatlock, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. '30118-30121 concerning the recall and remedy of products with safety-related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

    One concern we have relates to the additional stress that the operation of the Seatlock may place on other seat belt components, including the retractor and buckle mechanisms. While these components are required to withstand the high momentary forces that result in a crash, we note that the Seatlock, unless designed to limit the loads that can be applied by the user, has the potential to place a sustained load on the seat belt system that would be greater than that experienced in normal use. This sustained load, if maintained over a long period of time, could negatively impact the performance of the vehicle belt system. In addition, when the Seatlock is in place, it may generate sufficient tension on the seat belt buckle release mechanism to interfere with the normal operation of the buckle. This could make the child seat more difficult to remove in an emergency situation.

    For your information, passenger vehicles manufactured since September 1, 1995, are required to have a locking mechanism for the lap belt or lap belt portion of lap and shoulder belts, to enable them to be capable of being used to tightly secure child safety seats without the necessity of the users attaching any device to the seat belt webbing, retractor, or any other part of the vehicle. In addition, under a final rule issued by the agency in March 1999, vehicle manufacturers are required, beginning on September 1, 2000, to equip a percentage of the cars they produce with a uniform child restraint attachment. This uniform child restraint attachment, when used with a compatible child seat, eliminates the need to secure a compatible child restraint with a seat belt. Instead, the child restraint itself will engage the restraint attachment and latch directly to the structure of the vehicle. Under this final rule, all passenger cars and light trucks manufactured after September 1, 2002, will be required to have the uniform attachments.

    I hope this information is helpful. If you have any other questions, please do not hesitate to contact Mr. Otto Matheke or Ms. Deirdre Fujita at (202) 366-2992.

    Sincerely,

    Frank Seales, Jr.
    Chief Counsel

    Enclosure
    ref:208
    d.10/17/00