Interpretation ID: aiam3808
Senior Product Engineer
Research and Development
COSCO
2525 State Street
Columbus
IN 47201;
Dear Mr. Gerken: This responds to your letter asking for an interpretation of Safet Standard No. 213, *Child Restraint Systems* (49 CFR S 571.213). Specifically, you noted that your company would like to begin producing a child restraint system with a new shield design. The new shield would be substantially smaller than the shield your company currently uses. You noted that this type of shield is already being sold by other companies, and that in your restraint, the harness system, but not the shelf-like shield, would restrain the child's forward movement. A system with that characteristic would not comply with Standard No. 213.; Section S5.2.2.2 of Standard No. 213 specifies that no fixed or movabl surface shall be in front of the child, except surfaces which restrain the child. Since your proposed new shield does not restrain the child, it is expressly prohibited from being mounted on the child restraint.; Even assuming that the proposed new shield did act to restrain th child, there is still a question of whether the shield would comply with section S5.2.2.1(c), since your drawing does not indicate which portions of the shield would restrain a child's torso and thus would need to comply with the 2-inch radius of curvature requirement.; At this time, the Enforcement Division of this agency has severa investigations pending concerning potential violations of the standard by firms using shields along the lines of the shield you propose. These investigations focus primarily on whether such shields satisfy the 2-inch radius of curvature requirement of section S5.2.2.1(c) of Standard No. 213.; Please do not hesitate to contact me if you need further information o have further questions on this matter.; Sincerely, Frank Berndt, Chief Counsel