Interpretation ID: aiam3964
Esq.
Locker Greenberg & Brainin
Esq.
One Penn Plaza
New York
NY 10001;
Dear Mr. Locker: This responds to your recent letter to Steve Kratzke of my staff seeking an interpretation of the requirements of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). Specifically, you asked if a belt which is attached to and is not easily removed from a movable shield is an integral part of the shield within the meaning of section S6.1.2.3.1(c), and may therefore be attached when the restraint is tested in test configuration II of Standard No. 213. Such a belt is an integral part of the movable shield and may be attached during test configuration II.; Your client, Collier- Keyworth, has designed a child restraint tha integrates the webbing of the upper torso restraint with the crotch strap and the movable shield in a continuous connection, with the bottom of the crotch strap webbing intended to be buckled to the base of the seat between the child's legs after the child is positioned in the restraint. As described in your letter and shown in the photographs enclosed therewith, the crotch strap portion of the webbing is considered an integral part of the movable shield, because it is formed as a unit with that shield. Hence, section S6.1.2.3.1(c) of Standard No. 213 allows you to attach the crotch strap portion of the webbing to the base of the seat during configuration II testing.; I suggest, however, that Collier- Keyworth incorporate into th restraint some means of alerting parents each time they place a child in the restraint that the crotch strap must be buckled into the base of the seat. This suggestion is based on past experience with child restraints which have both a movable shield and a crotch strap which must be buckled to adequately protect the child.; In the late 1970's, there were several child restraint designs whic had a crotch strap permanently attached to the base of the seat and a movable shield which lowered in front of the child. The designers of these restraints intended that the crotch strap be attached to the shield to properly restrain the child. However, such restraints were often misused by consumers who did not attach the crotch strap to the shield. NHTSA was concerned that in the event of a crash, a child occupant would submarine partly or completely out of restraints whose crotch straps were not fastened to the shield.; When amended Standard No. 213 was being promulgated, the agency decide to include some procedure for testing those child restraints whose design could lead a parent to believe that a child was adequately protected when the restraint was, in fact, being misused. In the case of restraints with movable shields, the agency believed that some parents would conclude that a child was protected by the restraint simply by lowering the movable shield in front of the child without buckling the crotch strap. Test configuration II in Standard No. 213 was intended to address this situation, by attempting to ensure that child restraint designs which would likely be misused would afford some minimal level of protection when they were misused. To achieve this end, test configuration II requires that child restraints with a movable shield in front of the child be tested in a 20 mile per hour crash with the shield in front of the test dummy, but without attaching any belts which are not an integral part of the shield.; Many previous interpretations of this standard explained that sectio S6.1.2.3.1(c) allows belts which are an integral part of the movable shield to be attached during configuration II testing because the agency believed that the need to buckle such belts would be more readily apparent than in the case of nonintegral belts. That is, a parent would be less likely to conclude that the child was adequately protected if the integral belt was not buckled.; During 1980, the manufacturers of the restraints with movable shield to which crotch straps were to be attached asked NHTSA if the crotch straps could be attached to the shield during configuration II testing if the movable shield were spring-loaded so that it would not stay in front of the child unless the crotch strap were attached. The agency concluded that the rationale for not allowing the nonintegral crotch strap to be fastened during configuration II testing would not apply if the crotch strap were to be fastened to spring-loaded movable shields. Unless these crotch straps were attached, there would be nothing in front of the child to restrain him or her in the event of a crash. Therefore, NHTSA decided it was unlikely that a parent would conclude that a child would be adequately protected without attaching these crotch straps, and permitted spring-loaded movable shields to attach nonintegral crotch straps during configuration II testing under Standard No. 213.; The shield on the Collier-Keyworth child restraint is not spring-loade and thus would remain in front of an occupant regardless of whether the crotch strap is fastened. Our examination of the photographs and materials enclosed with your letter suggests that it is possible a parent might conclude that a child was adequately protected simply by lowering the shield in front of the child without buckling the crotch strap. For instance, Figure 5 of Exhibit B shows the shield lowered and staying in place without buckling the crotch strap. I am sure that Collier-Keyworth wants to minimize the chances of this sort of misuse occurring, and will want to incorporate some means of alerting parents each time they place a child in the restraint that the crotch strap must be buckled. Such a means could be spring-loading the movable shield, sas would be required if the crotch strap were not an integral part of the shield, or could be a 'warning' label on the front of the shield explaining the need to buckle the crotch strap.; If you have any further questions or need more information on thi subject, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992.; Sincerely, Jeffrey R. Miller, Chief Counsel