Interpretation ID: aiam1471
Director
Technical Services
Questor Juvenile Products Company
771 N. Freedom Street
Ravenna
OH 44266;
Dear Mr. Koziatek: This responds to your April 9, 1974, petition to substitute th proposed performance requirements for child harness testing under Standard No. 213, *Child seating systems*, for the performance requirements of Standard No. 209, *Seat belt assemblies*, to which Questor's Model 275 child harness is presently subject. As reasons for the substitution, you cite the inappropriateness of attachment hardware requirements (S4.3(c)) and the configuration of the test device (Figure 7) of Standard No. 209 as well as the desirability of testing to dynamic performance requirements which may become a part of Standard No. 213.; The Standard No. 213 dynamic test values which you recommend are onl proposals at this time. Interested parties have not had a full opportunity to comment on them and the NHTSA has not, of course, had the opportunity to fully evaluate them. For these reasons your petition to substitute these new dynamic tests for the Standard No. 209 static tests is denied.; You state that testing of the Model 275 to the assembly performanc requirements of Standard No. 209 (S4.4(c)) is complicated by the configuration of the test device for Type III harnesses, which is not suited to test a child harness such as the Questor NO. 275 that utilizes the adult front lap belts and the rear adult lap belt or the package shelf as attachment points.; Paragraph S5.3(c) (2) of Standard No. 209 directs that in such a cas 'attachment shall be. . .in accordance with the [manufacturer's] installation instructions'. As adherence to Model 275 installation instructions requires a front and rear adult belt installation (and in some cases a package shelf) the use of an actual vehicle bench seat in a passenger car would be an appropriate method to evaluate the assembly under S4.4(c) of Standard No. 209. Moreover, because the 12-inch extension requirement for an assembly tested under S4.4(c) is based on zero deflection of the test device, the actual vehicle seat should be modified to eliminate deflection.; The NHTSA has previously determined that the requirements of S4.3(c) o Standard No. 209 do not apply to bolts used to secure an adult upper torso restraint, other than the continuous loop type. Similarly, we interpret this provision not apply to the child harness upper torso restraint described in your letter. The bolts would be regulated with respect to strength only by the assembly performance requirements of S4.4(c).; Yours truly, Richard B. Dyson, Assistant Chief Counsel