Interpretation ID: aiam3267
P.E.
Director
Technical Services
Questor Juvenile Products Company
771 N. Freedom Street
Ravenna
OH 44266;
Dear Mr. Koziatek: This responds to your letter of January 25, 1980, requesting a interpretation of section S6.1.2.2.1 (c) of Standard No. 213, *Child Restraint Systems*. Section S6.1.2.2.1(c) specifies that in the 20 mph test of forward facing child restraints with fixed or movable surfaces designed to restrain the child, the restraint system's belts are not to be attached 'unless they are an integral part of the fixed or movable surface.' You asked whether the crotch strap used in your Kantwet 'One Step' Model 400 child restraint would be considered an integral part of the movable shield used on that device. After reviewing the diagrams and description contained in your letter, I conclude that the crotch strap is not an integral part of the movable surface and thus must not be connected during the 20 mph test.; Amended Standard 213 is intended to address, among other things, th problem of misuse of child restraints. The principal misuse involves the failure to attach buckles and latches. To ensure that children using child restraints are afforded protection notwithstanding such misuse, the standard specifies that the belts are to be attached to restraining shields during testing only if they are integral parts of the shields. Webster's New Collegiate Dictionary (1977) defines 'integral' as meaning 'formed as a unit with another part.' Attachment of belts that are integral parts is permitted since they are intended to remain attached whether or not the restraint is in use and thus are not subject to the type of misuse described above.; The crotch strap used in the Kantwet 'One Step' is not an integral par of the movable shield. The movable shield is a complete unit by itself. The crotch strap is a separate device that must be manually connected to the shield every time the unit is used. In contrast, the two upper torso restraints appear to be integral parts of the shield since they are designed to remain attached to an adjustment device and anchorage which are in turn permanently affixed to the shield. Nevertheless, we are concerned about the possibility that the upper torso restraint could be detached from the adjustment device. We urge that you and other manufacturers take the additional step of assuring that the belts permanently remain integral parts of the adjustment device.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel