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Interpretation ID: aiam3619

Mr. Robert C. Craig, Quality Control Manager, Cosco, 2525 State Street, Columbus, IN 47201; Mr. Robert C. Craig
Quality Control Manager
Cosco
2525 State Street
Columbus
IN 47201;

Dear Mr. Craig: This responds to your letter of August 13, 1982, concerning th application of the belt buckle requirements of Standard No. 209, *Seat Belt Assemblies*, to child restraints meeting Standard No. 213, *Child Restraint Systems*. As explained in the enclosed letters of interpretation of May 12, 1981, and May 21, 1981, the only requirements of Standard No. 209 that apply to child restraint belt buckles are the corrosion resistance requirement of S4.3(a) and the temperature resistance requirement of S4.3(b). The buckle release requirements of S4.3(d) and the buckle latch requirements of S4.3(g) do not apply to child restraints.; Because of reports of problems relating to difficulty in operatin child restraint buckles, the agency is considering issuance of a proposal to apply the requirements of S4.3(d)(2) and S4.3(g) to child restraint system belt buckles. Any such proposal would be published in the *Federal Register* to provide all interested parties with notice and opportunity to comment.; If you have any further questions, please let me know. Sincerely, Frank Berndt, Chief Counsel