Interpretation ID: aiam3487
Cosco
2525 State Street
Columbus
IN 47201;
Dear Mr. Knoedler: This responds to your letter concerning the application of Standard No 213, *Child Restraint Systems*, to a booster seat that uses a vehicle lap belt or lap/shoulder belt to restrain a child weighing 20 or more pounds. The following discussion answers your questions concerning the application of specific sections of the standard to a booster seat.; Section 4 of the standard defines a 'child restraint system' as 'an device, except Type I or Type II seat belts, designed for use in a motor vehicle to restrain, seat, or position children who weigh not more than 50 pounds.' Since the booster seat you described would be used to seat a child weighing less than 50 pounds in a vehicle, it is a child restraint system and thus must meet the requirements of the standard. The vehicle lap belt (Type I belt) or lap/shoulder belt (Type II belt) used with the system are specifically excluded by the definition of child restraint system and thus are not covered by the requirements of the standard.; You said that the booster seat would have no sides, back or fixed o movable surface directly in front of the child and asked how the standard would apply to such a design. The standard does not require a child restraint to have a back, sides or fixed or movable surface in front of the child. If such surfaces are provided, however, they must comply with the applicable requirements of sections 5.2.2, 5.2.3, and 5.2.4.; Each child restraint is required to meet the minimum head suppor surface requirements of S5.2.1. Section 5.2.1.2, however, exempts forward-facing child restraint (sic) from the minimum head support surface requirement if, 'the target point on either side of the dummy's head is below a horizontal plane tangent to the top of the standard seat assembly when the dummy is positioned in the system and the system is installed on the assembly in accordance with S6.1.2.' Thus, unless your design is within the exception of S5.2.1.2, it would have to comply with the minimum head support requirements of S5.2.1.1. Any head support surface would also have to comply with the applicable requirements of S5.2.3. and S5.2.4.; You asked about the application of S5.4.3.2 to a booster seat. Sectio 5.4.3.2 provides that:; >>>Each belt *that is a part of a child restraint system* and that i designed to restrain a child using the system and to attach the system to the vehicle shall, when tested in accordance with S6.1, impose no loads on the child that result from the mass of the system or the mass of the seat back of the standard seat assembly specified in S7.3. (Emphasis added.); <<>>(c) In the case of each seating system recommended for children ove 20 pounds, crotch restraint in the form of:; (i) a crotch strap connectable to the lap belt or other device used t restrain the lower torso, or; (ii) a fixed or movable surface that complies with S5.2.2.1(c).<<< The purpose of subsection (c) is to require a belt or surface desig that will prevent the child from submarining under the lap belt (i.e., sliding down and forward under the belt). Thus, if a crotch belt is not provided, the surface of the restraint must be designed to prevent submarining and comply with S5.2.2.1(c). For example, the seating surface of the restrain could be designed to prevent submarining.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel