Interpretation ID: 15596buc.kle

Mr. Bengt Rimark
Br. Holmbergs Fabriks AB
Box 63
S-334 21 ANDERSTORP
SWEDEN

Dear Mr. Rimark:

This responds to your letter asking about paragraph S6.2.1 of Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding. You ask whether we would consider the buckle you developed for infant restraints to be a "hinged button" as the term is used in S6.2.1, or a buckle in the "other buckle release mechanism" category in S6.2.1. Our answer is the buckle would be a hinged button.

S6.2.1 sets forth the buckle release test procedure in Standard 213. The procedure determines where to apply the force needed to release the buckle based on the type of buckle (e.g., hinged, pushbutton, or other) being tested. If the buckle is of the hinged button category, the force would be applied "at the centerline of the button, 3 mm away from the movable edge directly opposite the fixed edge, and in the direction that produces maximum releasing effect." If the buckle is in the "other" category, the force would be applied "on the centerline of the buckle lever or finger tab in the direction that produces the maximum releasing effect." You state that if your buckle is a hinged button, it would have to be redesigned to increase the force needed to release the buckle. You also state that while you can do this, you would prefer not to because the buckle "works well and feels right" with a depression in the buckle that guides the finger to the release point, and because you prefer to keep any force applied close to a newborn as low as possible.

We have examined the sample buckle you sent with your letter and conclude that the buckle has a pushbutton-release mechanism with a fixed edge, which the standard refers to as a "hinged button." While you have reasons for wanting to call the buckle other than hinged button, under the clear language of the standard the buckle is not in the "other" category. If you believe the standard should be changed, there are procedures for petitioning the agency to amend the standard. See 49 CFR Part 552 of our regulations (copy enclosed).

If you have further questions, please contact Deirdre Fujita of my staff by telephone at 011-202-366-2992 or fax at 011-202-366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
ref:213
d.1/30/98