Interpretation ID: nht92-7.25

DATE: April 28, 1992

FROM: Dave Durenberger -- United States Senator

TO: Jerry R. Curry -- Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/28/92 from Jerry R. Curry to Dave Durenberger (A39; Std. 209)

TEXT:

I am writing on behalf of my constituent, McNaughton Incorporated of Minneapolis, Minnesota to request your input concerning a safety belt product they have developed to encourage safety belt compliance for children.

As you know, all 50 states have child restraint laws and 41 states have mandatory seat belt laws with varying levels of compliance. Part of the problem, in general, is compliance. Another part of the problem is that although an adult may secure a child in a seat belt restraint, that doesn't mean the child will keep the belt on.

McNaughton Inc. has developed a product that will inhibit a child from unbuckling a seat belt until assisted by an adult. McNaughton would like to be advised of any regulations that may pertain to their product and how they can abide by any legislation that may effect the feasibility of such a product.

I have enclosed photos of the prototype for your inspection. The buckle part of the seat belt fits into the little "box". There is a slot through which you plug in the tongue of the belt. The release button is covered by a removable, FDA-approved "pull and turn" child safety cap. To undo the belt lock, one simply pulls and turns the cap and inserts a finger in the round opening to the release button.

This is an item that the individual consumer would purchase and personally position on their existing safety belts. It would not need commercial installation. Although an adhesive tape will be included to keep the device in place, the product is fully removable, temporary and does not alter the function of the buckle in any way other than its intended design.

In addition to ensuring that it remains in compliance with all regulations and legislation, McNaughton Incorporated would like to become involved in the Department's safety belt campaign. I would greatly appreciate receiving any pertinent information, input, comments and suggestions on ways that my constituent could participate in this endeavor.

I appreciate your serious consideration of this request and look forward to your response.