Interpretation ID: nht92-7.1

DATE: May 18, 1992

FROM: Timber Dick -- General Manager, Safeline Children's Products Company

TO: Deirdre Fujita -- Office of the Chief Counsel, NHTSA

COPYEE: Michael Pyne -- NHTSA Enforcement; Kathleen Weber -- UMTRI

TITLE: None

ATTACHMT: Attached to letter dated 8/18/92 from Paul J. Rice to Timber Dick (A39; Std. 213)

TEXT:

We spoke on several occasions recently regarding Safeline's certification of the Sit'n'Stroll 2-in-1 Carseat/Stroller under FMVSS 213. In particular, our discussions focused on NHTSA's interpretation of the regulations, and whether a manufacturer could certify a rear-facing carseat at a weight greater than 20 lbs.

We were prompted to investigate certification at a higher weight than the standard 20-lb limit as a result of numerous safety studies (several of which are enclosed) which indicate that children are exposed to a lessened risk of cervical spine fractures, and consequent para- and quadriplegia, if they are rearward facing to a higher weight limit. I have a baby boy born with a 99%+ head circumference, and I've been afforded additional peace of mind by keeping him rear-facing in his Sit'n'Stroll as he has reached 25 lbs in body weight.

Safeline is committed to providing the highest degree of safety possible within practical and regulatory constraints. To this end, we recently tested the Sit'n'Stroll at the University of Michigan facility rear-facing using a 35 lb, NHTSA-approved dummy. FMVSS 213 positioning procedures were interpreted in a logical manner. The enclosed test results are a powerful testimony to the safety benefits afforded by use of the Sit'n'Stroll in this configuration.

Please note two important conclusions of the test. First, even with the 35-lb load, the test seat was well within the back angle limits imposed by FMVSS 213. Our maximum back angle was just 50 degrees, as compared to the maximum permissible of 70 degrees. Second, and in my eyes perhaps more compelling, our Head Injury Criteria was 289, a remarkably low figure as contrasted with the permissible 1000.

Safety experts across the nation have contacted Safeline to applaud our efforts to give parents of babies (like mine) with disproportionately large heads an safer way to transport their children. We submit that it is in the best interests of the taxpayers and their children to allow FMVSS 213 interpretations which would permit rear-facing carseats to be certified with 35-lb dummies to a weight higher than 20 pounds.

We sincerely appreciate your consideration of this matter.