Interpretation ID: nht71-5.53

DATE: 06/10/71

FROM: CLUE D. FERGUSON -- NHTSA; SIGNATURE BY ZEMAITIS

TO: Physicians for Automotive Safety

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 24, 1971, informing us of Mr. Hurley's Safe-Trip-Seat and inquiring about enforcement of Standard No. 209 concerning a non-complying Hankscraft child harness.

Mr. Hurley sent us a letter on April 10, 1971, informing us of his device. Our letter to him was sent out on May 10, 1971, so he had not received it when he wrote to you. I believe we have adequately informed him of his lack of compliance with Standard No. 213 and the penalties involved if he does not. A copy of our letter to him is enclosed for your information. Our compliance personnel were also alerted on the Safe-Trip-Seat.

Hankscraft was notified in a letter dated March 23, 1971, of our position on any child harness (copy enclosed). Please note that we will enforce Standard No. 209 on harnesses advertised in any way to provide any measure of protection in a vehicle accident. We will not enforce the requirements of Standard No. 209 on harnesses which "carefully state that they are not intended to protect a child from the effects of an accident."

A copy of this letter is being forwarded to our compliance personnel for appropriate action by them.

ENC