Interpretation ID: 24421safeline_LATCH_buckle

Mr. Keith Poulson
Vice President of Product Development
Safeline Kids, Inc.
475 W. 115^th Avenue, Suite 3
Northglenn, CO 80234

Dear Mr. Poulson:

This responds to your letter and follow-up e-mail asking about a design concept for components on a child restraint that attach to the lower anchorages of a child restraint anchorage system on a vehicle.The components are required by Federal Motor Vehicle Safety Standard No. 213 (S5.9) for child restraints manufactured on or after September 1, 2002.The child restraint anchorage system, which you refer to as the LATCH system, is required to be installed in vehicles by Standard No. 225. [1]You ask if the concept you have developed would meet our requirements.With certain caveats, our answer is yes.

Background

By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment.Under 49 U.S.C. Chapter 301, manufacturers are required to ensure that their vehicles and equipment meet applicable requirements. The following represents our opinion based on the facts you provided in your letter, and addresses some or all of the specific issues you raised as necessary to render this interpretation.If we have not addressed an issue, you should not assume that we have concurred with a position you have expressed on that issue.Likewise, this interpretation may not discuss every requirement of the Federal motor vehicle safety standards that might apply to your product.It is your responsibility as a manufacturer to determine the requirements that apply and certify the compliance of your product with those requirements.NHTSA determines the compliance of products with the safety standards in the context of an agency enforcement proceeding.

You explain that your letter concerns the Sit' n 'Stroll, which converts from a child restraint to a stroller.You have designed LATCH attachments for the restraint system keeping in mind that the Sit' n 'Stroll will be removed from the vehicle several times a day for use as a stroller.You state:

As standard equipment on each product the Sit' n 'Stroll would have permanently attached to the seat shell, a snap hook and also a quick release buckle latch clip.Both are permanently attached to the product on the same piece of webbing [2]

As an option, a consumer could then purchase as an accessory a buckle(s) with a snap hook attached to it, that could be secured to the anchor point in the vehicle seat, allowing the consumer to quickly release the Sit' n 'Stroll from the vehicle seat using the buckle.The buckle will remain secured to the anchor point in the vehicle using the snap hook, but can be easily removed should the consumer decide to transfer the Sit' n 'Stroll and this accessory to a different vehicle. [3]

Discussion

S5.9(a) of Standard No. 213 requires child restraint systems of the type you manufacture to have components permanently attached to the system that enable the restraint to be securely fastened to the lower anchorages of a LATCH system.Your child restraint would have snap hooks permanently attached to the child restraint that enable the restraint to fasten to the lower LATCH anchorages.As such, the restraint provides the components required by S5.9(a).The standard does not prohibit a child restraint from having other components attached to it.However, the other components must not make inoperative the LATCH snap hooks that are installed in compliance with Standard No. 213.Further, under S5.6.1, each child restraint system that has components for attaching to a child restraint anchorage system must include a step-by-step procedure for properly attaching to that anchorage system.This means that the installation instructions you provide must include instructions for properly attaching the buckle with snap hook to the LATCH anchorage system.In addition, child restraint systems are tested to Standard No. 213's performance requirements when attached to a LATCH anchorage system "in accordance with the manufacturer's instructions provided with the system pursuant to S5.6.1."(S6.1.2(1)(i)(C)).Thus, your child restraint must meet the standard's performance requirements when attached by the buckle with snap hook component.

Note also that S5.9(d) specifies an additional requirement for child restraint systems other than systems with hooks for attaching to the lower LATCH anchorages.Such systems must provide an indication when each attachment to the lower anchorages becomes fully latched or attached.Because the "buckle Latch (sic) clip" is a part of your system, the child restraint must meet S5.9(d).We consider an audible "click" of the buckle LATCH clip connecting to the "quick release buckle" as satisfying S5.9(d).

I hope this information is helpful.If you have any questions, please contact Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:213
d.11/8/02