Interpretation ID: nht92-3.34

DATE: 10/01/92

FROM: MICHAEL J. VACANTI

TO: OFFICE OF THE CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO MICHAEL J. VACANTI (A40; STD. 208; VSA 108)

TEXT: I, Mike Vacanti, have designed an after market seat belt accessory to help fit the shoulder strap and the lap belt properly on small children.

Information on this device is enclosed. Please evaluate this information and offer a ruling as to the compliance with current Federal standards.

Also, enclosed please find a self addressed, stamped envelope for convenience in replying. Your prompt attention will be greatly appreciated. Thank you for this consideration.

Attachment

"Embrace" - Child Safety Seat Belt Accessory

PREMISE:

At the age of four, children can legally ride in a car without a "child safety seat" (car seat). To date, auto manufacturers have not made available any device to properly fit the shoulder strap of the seat belt to small children (roughly ages 4-10 years). Without a proper fit, the shoulder strap of the seat belt will the cross the small child near the head and neck area. Therefore, parents generally will loop the shoulder strap behind the small child, or behind the passenger seat. Neither method is safe.

THE DEVICE:

"Embrace", child safety seat belt accessory will effectively fit the shoulder strap of the seat belt to a small child. (See drawing B1).

"Embrace" is a polyurethane device that latches onto the lap belt of the seat belt and also to the shoulder strap of the seat belt, changing the angle at which the belt crosses the child's upper body in front of the child. (See Drawing A1).

USAGE:

I believe this device can be widely used with any and all automobiles that employ a shoulder strap with the seat belt. This device should not be limited to children. Size variances can be developed to fit different groups, such as senior citizens, physically challenged individuals or other special needs. The first application of the device will be children.

DESIGN: This device was initially conceived by Michael Vacanti in the year 1991. After testing with mock-up and redesigning, this device if believed to be ready for production.

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