Interpretation ID: nht89-2.67

TYPE: Interpretation-NHTSA

DATE: August 10, 1989

FROM: William Shapiro -- Manager, Regulations and Compliance, Volvo Cars of North America

TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA

TITLE: Re Request for Interpretation FMVSS 213 - Child Restraint Systems

ATTACHMT: Attached to drawing of child booster cushion (graphics omitted); Also attached to letter dated 9-14-90 from P.J. Rice to W. Shapiro (A36; Std. 213)

TEXT:

Volvo has designed and developed a "built-in" child booster cushion for use in a future model vehicle. It will be integrated into the center rear seat arm rest such that the arm rest will split in half to form the booster cushion. The child using this "built-in" booster cushion will utilize the center rear 3-point seat belt for their restraint.

Because the agency has stated in the preamble to the final rule, that sets forth the requirements for "built-in" child seats, that "...S5.4.3.3 allows child restraint systems other than a 5-point harness...", Volvo believes that a "built-in" booster cush ion that utilizes the adult 3-point center rear seat belt and is designed with due care to meet all the requirements of FMVSS 213, as they apply to "built-in" child seats, is in compliance with FMVSS 213. Volvo believes that by meeting all the labeling, instruction and performance requirements set forth by FMVSS 213 - Child Restraint Systems, this "built-in" booster cushion can be marketed in the U.S. We ask that the agency confirm this as soon as possible.

Some illustrative sketches are attached. If you need any additional information, or would like to see the seat, please feel free to contact me.

Drawings of child booster cushion are attached (graphics omitted).