Interpretation ID: nht73-1.49

DATE: 08/30/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Physicians for Automotive Safety

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 12, 1973, concerning children's car harnesses and car seats.

In response to your inquiry about the "Auto-babe" car harness, it is our opinion that the harness is a Type III seat belt assembly under Standard No. 209 and we presently are investigating the product as an apparent noncompliance with the standard.

The next stage in the rulemaking on child restraints will be reached this fall with a notice of proposed rulemaking on dynamic test requirements. We will be interested to have your comments on this proposal when it is issued.

Yours truly,

PHYSICIANS FOR AUTOMOTIVE SAFETY

July 12, 1973

James Wilson -- Acting Administrator, NHTSA, U.S. Dept. of Transportation

Dear Mr. Wilson:

I am enclosing a brochure describing a child auto harness, and would very much like to know 1. does the device meet requirements of Standard 209, Type II, and 2. if not, what action will be taken to prevent manufacture of the device and recall of those still in the stores.

I should also like to receive information with respect to the date a proposal for the upgrading of Standard 213 can be expected.

Your help in this matter would be very much appreciated.

Sincerely,

Seymour Charles, M.D.

President

Enclosure

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