Interpretation ID: nht73-4.20

DATE: 05/21/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Help of Nebraska, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 30, 1973, in which you ask whether an "infant car hammock" which you manufacture is required to conform to Motor Vehicle Safety Standard No. 213. A picture of the hammock, which you enclosed, shows the hammock attached to both rear doors of a vehicle, and extended between them, with a child lying on it.

As pictured, the hammock is not subject to Standard No. 213. The standard applies, at present, to devices for seating and restraining a child being transported in a motor vehicle. Effective November 1, 1973, it will apply to all devices for seating a child being transported in a motor vehicle, irrespective of whether the device is used for restraint. Because the hammock is not designed to seat a child, it is not subject to the standard. A copy of the standard is enclosed.

We are presently developing proposed amendments to the standard that would apply to all types of infant and child restraints, including devices in which children do not sit. These proposals will be published in the Federal Register when completed.

We are enclosing a copy of our consumer information booklet, "What to Buy in Child Restraint Systems". Our recommendations for infant carriers and car beds are found at the center pages of the booklet.

We hope the information we have provided answers your questions and we appreciate your concern for child restraint safety.

Sincerely Yours,

ENCLS.

HELP OF NEBRASKA, INC.

April 30, 1973

National Highway Traffic Safety Administration Department of Transportation

Gentlemen:

We have acquired the rights to an Infant Car Hammock from the inventor. We are making the first production run now. The question has come up as to whether or not Federal Standard 213 is applicable to this item. We have tried to obtain a copy of this Standard but no one in the Omaha area seems to have a copy.

A photo of the hammock as mounted in a car is enclosed. The hammock itself is made of poplin material which is 65% Kodel and 35% combed cotton. It is permanent press, mercerized and has a 1% shrinkage factor. There are two belts on top of the hammock, one of which goes around the childs waist, the other goes from one hip across the body to the opposite shoulder. These safety belts are stitched through the hammock and through another piece of belting on the bottom that has a "D" ring fastened to it. The "D" Ring is secured to a two inch wide piece of web belting by passing a one inch piece of web belting through the "D" ring and then stitching the two pieces of belting together. By stitching through all safety belts we have a solid base both for the two belts around the child and for the "D" ring. A separate belt with a snap hook is anchored through the floor of the car by placing a bolt through the floor and then through the heavy washer fastened to the end of this belt. The snap hook is then fastened through the "D" ring on the hammock. This gives a down pressure on the hammock and puts the steel tubing brackets placed in the window wells under tension. These belts are not shown in the enclosed photo.

If Federal Standard 213 does apply to this type device, please send us a copy of it. We will be more than happy to send you one of the hammocks for your inspection and/or testing.

Any assistance you can give us will be appreciated.

Sincerely,

John L. Wilson Jr. President

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