Interpretation ID: nht80-2.9
DATE: 04/22/80
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Cosco Home Products
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your letter of March 27, 1980, to Mr. Stephen Oesch of my staff concerning Standard No. 213, Child Restraint Systems. You asked whether the labels and installation diagrams required by the standard must comply with Standard No. 302, Flammability of Interior Materials. In addition, you asked whether an upholstery tag, required by State law, attached to the seat must comply with Standard No. 302.
Section 5.7 of Standard No. 213 requires "each material used in a child restraint system" to conform to the performance requirements of Standard No. 302. Because the label, installation diagram and tag materials are affixed to the child restraint, they would have to comply with Standard No. 302.
Section 4.2.2 of Standard No. 302 provides that "any material that adheres to other materials at every point of contact" shall meet the performance requirements of the standard "when tested as a composite with the other materials." Thus, if the label, diagram and tag are affixed to the plastic shell of the restraint so that they adhere to the shell at every point of contact, they would be tested with the shell. If the label, diagram and tag do not adhere at every point of contact, section 4.2.1 requires them to meet the performance requirement of the standard when tested separately.
If you have any further questions, please let me know.
Steven L. Oesh Vehicle Safety Standards National Highway Traffic Safety Administration
March 27, 1980
Dear Mr. Oesh:
As you know, the Standard No. 213 requires labeling and installation diagrams. Normally, these labels are paper with a self-adhesive backing.
Some states require upholstery tags that are also normally paper, and almost always are torn off by the customer.
Our plastic shell to which the labels will be attached and the pad assemblies themselves will conform to the Flammability requirements of FMVSS No. 302.
As the two small labels and the upholstery tag are insignificant compared to the assemblies to which they are attached, and the method of testing is with a 4" x 14" specimen which is large compared to the labels, would paper labels as applied in our application be allowed? I would appreciate your immediate attention to this question.
Don Gerken Product Engineer