Interpretation ID: nht67-1.10

DATE: 08/01/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Sears, Roebuck & Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 20, 1967, concerning restraining straps for children.

Initial Federal Motor Vehicle Safety No. 209 provides that seat belt assemblies shall meet the requirements of Department of Commerce, National Bureau of Standards, Standards for Seat Belts for Use in Motor Vehicles (15 CFR 9) (31 F.N. 11528). For your convenience a copy of the Federal Register containing the seat belt standard is enclosed.

The standard affects any seat belt manufactured for sale after February 23, 1967, including Type 3 belts which are designed for children between 8 months and 6 years of age. The problem you discuss in your letter, that of manufactures who consider their devices something less than seat belts, and so label them, is under review to determine if there is any violation of the National Traffic and Motor Vehicle Safety Act of 1965.

Sincerely,

June 20, 1967

Department of Transportation Washington, D.C.

Attention: Dr. Haddon

Dear Dr. Haddon

Sears Automotive Department carries only a child's harness that meets your new federal safety standard, but many competitors are carrying inexpensive restraining straps which obviously do not meet the standard. We would like to know the position that the federal government will take regarding them. If inexpensive restraining straps state on the package clearly that "this is not a safety harness but only a child's restraining strap" or words to that effect, will they be legal since the federal standard does not apply to them? A statement regarding this form you will be greatly appreciated.

Very truly yours,

C.M. HATTERSLEY, Buyer -- Auto Parts and Accessories, Department 628,SEARS, ROEBUCK AND CO.