Interpretation ID: nht81-2.23

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gateway Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 12 1981

NOA-30

Mr. John S. Miskowicz Gateway Industries, Inc. 17512 Carriage Way Drive Hazel Crest, Illinois 60429

Dear Mr. Miskowicz:

This responds to your letter of March 2, 1981, to Vladislav Radovich concerning Standard No. 213, Child Restraint Systems. Your letter was forwarded to this office for reply.

You asked whether a child restraint belt buckle must meet the buckle force release requirements when tested in an unloaded condition. As explained below, the answer is no. The buckle force requirements only apply to buckles tested in a loaded condition. In addition, you asked whether section 4.3(a) and 4.3(b) of Standard No. 209, Seat Belt Assemblies, are the only requirements of that standard which apply to buckles in child restraint systems. The answer is yes.

Section 5.4.3.5 of Standard No. 213 provides that each child restraint belt buckle, when tested in accordance with S6.2, must not release when a force of not more than 12 pounds is applied before the dynamic sled specified in S6.1 is conducted. The buckle must release when a force of 20 pounds is applied after the dynamic sled test. Section 6.2 provides that in conducting the belt buckle release force test, the appropriate test dummy is placed in the restraint and either a pull force of 20 pounds is applied, in the case of 6 month-old-test dummy, or a 45 pound pull force is applied, in the case of the three-year-old test dummy. Thus, the buckle is not tested in an unloaded state.

Section 5.4.2 of the standard provides that each belt buckle has to conform to the "requirements of S4.3(a) and S4.3(b) of FMVSS No. 209." No other provisions of Standard No. 209 apply to belt buckles used in child restraints.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

March 2, 1981

Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington D.C. 20590

Attention: Mr. Vladislav Radovich

Dear Mr. Radovich:

Enclosed please find three prototype samples of our child seat buckle we would like to market. Gateway Industries is a major supplier of seat belts to General Motors and Chrysler and we hope to expand our product line by offering this item to child seat manufacturers.

We feel that our buckle meets all of the specifications of Standard 213, however, there is one area we wish you would clarify in regard to the 12 lb. to 20 lb. release force. (You may recall my phone call to you in the first week of January.)

Our buckle meets the letter of the spec as written. That is, as specified in S5.4.3.5 we meet S6.2 before and after the test specified in S6.1. Standard 213 makes no mention of how to test the buckle in an unloaded state. Does the 12 to 20 lbs. apply to the unloaded condition?

The three enclosed buckles do meet the 12 lb. minimum in the unloaded state, however, we are marginal and I doubt we can consistently obtain this on a large volume product basis. I theorize that on cccasion we will have release efforts of 10 lbs. in the unloaded state. Would this mean that we do not comply with Standard 213? With the slightest load applied to the buckle (approximately 5 lbs.), the release efforts increase and we again are in compliance. Also, in the "Summary of Final Rule Provisions", No. 5 states the requirements in 209 apply and S5.4.2 states S4.3(a) and S4.3(b) of 209 apply. Does this mean that only the requirements of S4.3(a) and S4.3(b) apply or do all the requirements of 209 apply?

We thank you for your time in reviewing this matter and would appreciate your written response. Please feel free to include any comments you may have concerning our product.

I would like to add that our buckle has been dynamically tested to Standard 213 on a Strolee Seat System at the University of Michigan in Ann Arbor and proven successful. We can guarantee a tensile load of 750 lbs.

Truly yours,

GATEWAY INDUSTRIES, INC.

John S. Miskowicz Manager, Design Engineering