Interpretation ID: aiam1680
The Bobby-Mac Company
Inc.
P.O. Box 209
Scarsdale
NY 10583;
Dear Mr. McDonald: This is in reply to your letter of October 10, 1974, to Mike Peskoe requesting our opinion that a draft label you plan to affix to the Bobby-Mac 2-in-1 Baby Chair will conform to the requirements of Motor Vehicle Safety Standard No. 213. Your letter indicates that although the Bobby-Mac 2-in-1 Baby Chair is not sold as a child seating system, you will be marketing a conversion kit which will enable purchasers to convert it into child seat use. With the conversion kit, the 2- in-1 Baby Chair will become the identical car child seat that you sell as the Bobby-Mac 2-in-1 Car Seat and the 3-in-1 Baby Chair.; We believe that attachment of the required label to the 2- in-1 Bab Chair, even though the chair is not a child seating system until the conversion kit is purchased, is the most satisfactory method of achieving conformity with Standard No. 213. Both of the additions you will make to the existing Bobby- Mac label are in keeping with the purpose of Standard No. 213's labeling requirements, and we will consider the draft label you enclose to conform to the labeling requirements of Standard No. 213 provided that the month and year of manufacture are included on the label.; As a suggestion, it seems to us that there should be a Part No reference to the conversion kit on the label. This might reduce any confusion with the other conversion kits that you offer for the other Bobby-Mac devices.; We are pleased to be of assistance. Yours Truly, Richard B. Dyson, Acting Chief Counsel