Interpretation ID: aiam3670
Vice President
Gold Bug
2151 West 57th Avenue
Denver
CO 80221;
Dear Mr. Eschino: This responds to your February 9, 1983, letter asking about th compliance of a device that you manufacture with Federal motor vehicle safety standards. The device is a head support for children which has several uses, one of which would be in a car seat. You specifically ask to obtain the Federal seal for use on your package.; Only those items of equipment to which specific Federal safet standards apply are marked with the DOT symbol which indicates that they are in compliance with applicable safety standards. From our analysis of your product, it is not a piece of equipment subject to any Federal motor vehicle safety standard. Since your device does not need to comply with any of our requirements, you would not need, nor would you be permitted to use, the DOT symbol.; We would recommend, however, from a product liability point of vie that you ensure that your product complies with flammability requirements. I am enclosing a copy of our flammability standard that you might use as a guideline, although as I stated earlier, you would not be required to comply with this standard.; Sincerely, Frank Berndt, Chief Counsel