Interpretation ID: nht90-4.31

TYPE: Interpretation-NHTSA

DATE: October 2, 1990

FROM: Mark G. Southern

TO: Office of Chief Counsel, NHTSA

TITLE: Re Child car restraints

ATTACHMT: Attached to letter dated 1-4-91 to Mark G. Southern from Paul Jackson Rice (A37; Std. 213)

TEXT:

Recently I contacted Mr. George Shifflett in your office regarding federal and state safety requirements for child car restraints. I have reviewed FMVSS No. 213, and would like to obtain further clarification as to whether it is applicable to the device that I have designed. I have enclosed sketches of my devise for your review.

Specifically my question relates to FMVSS No. 213 S5.3.1 which reads as follows:

Each (add-on) child restraint system shall have no means designed for attaching the system to vehicle seat cushion or vehicle seat back and component (except belts) that is designed to be inserted between the vehicle seat cushion and vehicle seat back. (53 F.R. 1783-January 22, 1988. Effective: January, 22, 1988)

My child safety devise provides additional restraint for children from the ages of two (2) to seven (7) years old; however it is not the primary restraint. The vehicles existing seat belt is the primary restraint.

I am requesting an interpretation as to whether it is permissible for my devise to attach to the seat back as shown in the attached diagrams.

My patent council has recommended that I request confidentiality from anyone, with whom I show the design. I would like to request confidentiality in this matter and that your office not publish or release any information with respect to my design, with out my approval.

If you have any questions feel free to contact me at work (206) 389-5055 or at home (206) 838-4530.