Interpretation ID: 21274airbaglabellocation

Mr. John K. Stipancich
Senior Corporate Counsel
Evenflo Company, Inc.
Northwoods Business Center
707 Crossroads Court
Vandalia, OH 45377

Dear Mr. Stipancich:

This responds to your letter concerning the air bag warning label requirement in S5.5.2(k)(4) of Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding. The standard requires rear-facing child seats to have a specified label "permanently affixed to the outer surface of the cushion or padding in or adjacent to the area where a child's head would rest, so that the label is plainly visible and easily readable."

You ask whether the standard would permit you to locate the warning label in a particular location on the back of the seat. You attach a photograph of a convertible restraint on which the label is "located on the back of the seat, a few inches below the lowest set of harness strap openings" (your words).

The label may be located in the location you suggest. The National Highway Traffic Safety Administration requires the label to be where the child's head rests or adjacent to that area "to ensure that parents see the label each time they place the [rear-facing child] seat in a vehicle." 61 FR 60206, 60214. We agree that, in your proposed location, the label would be in or adjacent to the area where a child's head would rest, and that it would be plainly visible and easily readable.

If you have any further questions, please contact Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,

Frank Seales, Jr.
Chief Counsel
ref:213
d/7/31/00