Interpretation ID: nht89-3.47
TYPE: Interpretation-NHTSA
DATE: November 28, 1989
FROM: Jonathan P. Reynolds -- Corporate Attorney, Cosco
TO: Steve Kratzke -- Office of Chief Councel, NHTSA
TITLE: Re Cosco Dream Ride-Convertible Infant Restraint/Car Bed
ATTACHMT: Attached to Cosco restraint system labels and instruction sheets (graphics and text omitted); Also attached to letter dated 9-13-90 from P.J. Rice to J.P. Reynolds (A36; Std. 213)
TEXT:
On October 6, 1989, we sent a prototype of the Dream Ride-Convertible infant restraint/car bed to George Chiang with Cosco's proposed labels and instruction sheet. We requested that NHTSA review the product and the written material regarding compliance with FMVSS 213 and advise us of any suggestions or recommendations.
In a later conversation with Richard Jasinski, it was suggested that Cosco should submit its analysis of the FMVSS 213 and how it applies to this product when used in the car bed position. Following are our comments in this regard. These comments do no t include any mention of the product as used in the rear-facing infant position, as such use requires no clarification in terms of compliance with the standard.
S4. Definitions. The following three definitions appear to be the most relevant concerning the car bed.
"Car bed" means a child restraint system, designed to restrain or position a child in the supine, or prone position, on a continuous flat surface.
The Dream Ride meets this definition, as shown in the enclosed copies of the labels and instruction sheet. Based upon our analysis, testing and input from our outside consultants, we have determined that the most favorable position for the car bed is th e right rear seat. The car bed is designed so that it can only be installed in that seating location with the child's head toward the center of the vehicle.
"Contactable surface" means any child restraint system surface (other than that of a belt, belt buckle, or belt adjustment) that may contact any part of the head or torso of the appropriate test dummy, specified in S7, when a child restraint system is te sted in accordance with S6.1.
When tested in accordance with S6.1, the "contactable surface" of the Dream Ride is that side of the restraint to the infants left when the infant is properly positioned face-up in the unit.
"Torso" means the portion of the body of a seated anthropomorphic test dummy, excluding the thighs, that lies between the top of the restraint system seating surface and the top of the shoulders of the test dummy.
This definition refers to traditional forward-facing or rear-facing restraints. Cosco and its outside consultants have concluded that the "torso" of the test dummy applicable to the traditional rear-facing restraint is also applicable to the Dream Ride c ar bed, and the harness
system of the Dream Ride and the dynamic test criteria for the Dream Ride in the car bed position rely on this definition of "torso" which is generally from the crotch to the top of the shoulders of the test dummy.
S5.1.1 Child-restraint system integrity. The Dream Ride complies with sub-part (a) and (b) as the Dream Ride exhibits no separation and remains in the initial adjustment position when tested in accordance with S6.1.
S5.1.2. Injury criteria, is not applicable, as the Dream Ride is recommended for use by children weighing 17 pounds or less.
S5.1.3.3 Occupant excursion-car beds. "In the case of car beds, all portions of the test dummy's head and torso shall be retained within the confines of the car bed."
Cosco interpreted the phrase "confines of the car bed" to mean the horizontal plane formed by the top edge of the entire shell of the Dream Ride, when installed in conformance with Cosco's instructions. When tested in accordance with S6.1, all portions of the test dummy's head and torso are retained within this horizontal plane.
S5.2.3.2 Head impact protection. All surfaces which are contactable by the test dummy in any direction are covered with slow-recovery, energy-absorbing material with the required characteristics.
S5.2.4 Protrusion limitation. The Dream Ride complies with the protrusion limitations of this section.
S5.3 Installation.
S5.3.1 The Dream Ride car bed complies with the attachment limitations. The vehicle belt is intended to be threaded through two car bed belt loops when installed in accordance with Cosco's labels and instructions.
S5.3.3 Car beds. "Each car bed shall be designed to be installed on a vehicle seat so that the car beds longitudinal axis is perpendicular to a vertical longitudinal plane through the longitudinal axis of the vehicle."
The Dream Ride car bed complies with this requirement, as shown on the enclosed labels and instruction sheet.
S5.4 Belts, belt buckle, and belt webbing. The Dream Ride complies with each of the requirements of this section.
S5.5 Labeling. The enclosed labels for the Dream Ride reflect an exhaustive effort on the part of Cosco to not only meet the specific requirements of this section, but to also impart to the consumer the information necessary to properly use this child-r estraint as a car bed and a conventional, rear-facing infant restraint.
The large label contains the information required in S5.5.2 (a) through (f). The warning language of S5.5.2 (g) is found on both labels.
The required language of of S5.5.2 (h) is identified as statement # 2 on
the large label.
The language required by S5.5.2 (k), concerning use in the rear-facing position, required certain modification. In order not to confuse the consumer, Cosco determined that it was necessary to expand on the required language of this section, as shown on the section denoted as number 3 on the large label, which states as follows:
Place this infant restraint in a rear-facing position when using it in the vehicle as a car seat. This infant restraint must face sideways when used as a car bed; see label inside shell.
Throughout the instruction sheet and labels, Cosco has elected to refer to the two positions that this restraint may be used in as the car seat position (traditional rear-facing position) and the car bed position. Cosco believes that this provides the cl earest guidelines to the consumer concerning the proper use of the restraint in each position.
S5.5.2 (1) requires installation diagrams showing the child restraint in the right-front and center-rear seating positions. For the traditional rear-facing restraint, Cosco has provided these diagrams on the large label. Cosco's research and testing of the child-restraint in the car bed position resulted in the determination that the center-rear seating positions is not recommended for the car bed position and may be potentially unsafe. In testing the performance of the car bed in a simu- lated side- impact on the drivers side of a vehicle, it was determined that a car bed, when properly installed in the center seating position may move in the direction of the impact to the extent that the "head" of the car bed (that area of the car bed where the chi ld's head would be positioned) may strike the interior of the left-rear door or body panel of many newer vehicles with small rear seats. While Cosco has engineered the Dream Ride to provide the best possible protection for the child from this type of im pact by the use of energy absorbing foam and by introducing a flexible grid at the head of the shell, intrusion from a severe side-impact could result in serious head and neck injuries to infants if the car bed was installed in the center seating positio n. Cosco has thus warned through-out its labeling and instructions that the car bed should only be installed in the right-rear seat, or the right-front seat. Cosco and its consultants believe that this provides the best possible protection for the crit ical head and neck area of an infant.
The large label contains the required language of S5.5.2 (m).
S5.6 Printed instructions for proper use. Cosco complies with each of the applicable sub parts of this section, specifically S5.6.1.4, which requires that instructions for each car bed shall explain that the car bed should be positioned in such a way th at the child's head is near the center of the vehicle. The above explanation concerning the installation diagrams is applicable to Cosco's instructions that the car bed be installed only in the right-rear and right-front seating positions.
The specific language concerning the installation of the car bed so that the baby's head is toward the center of the vehicle is found on page 5 of the instruction sheets under the warning section at the top, paragraph number two.
Cosco has sled-tested the Dream Ride in the car bed position not only as required in S6.1, but also to simulate side-impacts and various misuse configurations. The reports and films of these tests are available for your review upon request.
Cosco looks forward to your comments regarding the Dream Ride.
(Attached are copies of Cosco restraint system labels and instruction sheets (graphics and text omitted).)