Interpretation ID: aiam0606
Design Engineer
Cosco Household Products
Inc.
2525 State Street
Columbus
IN 47201;
Dear Mr. Parrott: This is in reply to your letter of February 8, 1972, requestin information pertaining to reclining type child seating systems. You describe these seats in your letter as those which allow the child to ride in a semi-recumbent posture by moving the seating surface forward while maintaining the upper back in a more or less fixed location. You state the hip of the child moves forward as a result, while the head remains in roughly the same place.; The questions you asked regarding this type of child seat are repeate below, followed by our responses.; >>>1. Is NHTSA now testing, or does it intend to test, reclining ca seats in both the upright and reclining configurations?; Paragraph S4.11.1(b) of Standard No. 213 requires that each chil seating system in which the attitude of the child is adjustable meet the performance requirements of the standard when placed in each designed adjustment position. Consequently, reclining child seats must meet these requirements in both reclining and upright positions.; 2. Is the allowed twelve-inch excursion to be measured from th reference point of the semi- recumbent dummy, or from the location of this point were the seat assumed to be upright?; The allowable forward movement of the dummy reference point is to b measured using the reference point of the semi-recumbent dummy, and the forward movement must not exceed 12 inches when measured from that point.; 3. Does the NHTSA intend to make a specific statement on th requirements of reclining car seats . . .?; We believe the language of paragraph S4.11.1 of the standard to b sufficiently explicit regarding this requirement.<<<; Yours truly, Richard B. Dyson, Assistant Chief Counsel