Interpretation ID: aiam3676
TRANZ ACC Inc.
21807 Plummer Street
Chatsworth
CA 91311;
Dear Mr. Grant: This responds to your February 25, 1983, letter asking whether a chil seat that you would like to import would comply with Standard No. 213, *Child Restraint Systems*. Your child seat attaches to a vehicle by use of several of its own anchorage straps which are attached to existing vehicle belt anchorages or by drilling new anchorages. The seat does not use the existing car seat belt system.; Paragraph S5.3.2 of the standard states: 'When installed on a vehicl seat, each child restraint system, other than child harnesses, shall be capable of being restrained against forward movement solely by means of a Type I seat belt assembly (defined in S571.209) that meets Standard No. 208 (S571.208), or by means of a Type I seat belt assembly plus one additional anchorage strap that is supplied with the system and conforms to S5.4.' Since your system has its own harnesses and does not utilize the existing car seat belt system (Type I seat belt), it would not comply with this portion of the standard.; The agency requires child seats to be attachable by use of the existin car seat system for ease of installation and to assist in proper installation and usage. The agency determined in rulemaking that to permit other systems that were more complex and that require the proper attachment of several harness straps would not be in the interest of safety, since it would likely result in improper child seat installation.; Sincerely, Frank Berndt, Chief Counsel