Interpretation ID: aiam3378
Esq.
Office of the General Counsel
Ford Motor Company
The American Road
Dearborn
MI 48121;
Dear Mr. McGuigan: This responds to your letter of November 10, 1980, concerning Standar No. 213, *Child Restraint Systems*. You asked whether Ford may make a minor variation in the language specified in S5.5.2(g) for the label that must be permanently affixed to child restraints. As explained below, you may use the language proposed in your letter.; Section 5.5.1 of the standard requires that each child restraint b permanently labeled with specified information. Section 5.5.3 requires that the information specified in S5.5.2(g)-(k) must be displayed on the child restraint so that it is visible when the restraint is installed in the vehicle.; You state that the only information specified for the visible labe that is applicable to the Ford 'TOT GUARD' is the language in S5.5.2(g). That section provides that the child restraint must be labeled with the following words:; >>>WARNING! FAILURE TO FOLLOW EACH OF THE FOLLOWING INSTRUCTIONS CA RESULT IN YOUR CHILD STRIKING THE VEHICLE'S INTERIOR DURING A SUDDEN STOP OR CRASH:; SECURE THIS CHILD RESTRAINT WITH A VEHICLE BELT AS SPECIFIED IN TH MANUFACTURER'S INSTRUCTIONS LOCATED________________.<<<; You are concerned that the above language may create potentia confusion for users of the 'TOT GUARD' since the user might be led to believe that more than one instruction is applicable. In your proposed revision, the word(sic) 'each of' would be deleted from the warning and the word 'instructions' would be changed to the singular.; Your proposed revision does not make any substantive change in th meaning of the warning specified for the label. Since the proposed change is a minor variation intended to clarify the language for restraints that only need to be labeled with one of the specified instructions, it is permitted.; Sincerely, Frank Berndt, Chief Counsel