Interpretation ID: nht92-9.54

DATE: January 13, 1992

FROM: Phil Gray -- Inventor, Westech U.S.A. Inc.

TO: Paul Jackson Rice -- Office of the Chief Council, NHTSA

COPYEE: Ed Jettner

TITLE: Re: Child Shoulder Belt Positioning Device

ATTACHMT: Attached to letter dated 2/25/92 from Paul Jackson Rice to Phil Gray (A39; VSA 108(a)(2)(A))

TEXT:

Firstly I would like to thank your staff especially Deirdre Fujita for all her help and the faxed letter she forwarded to me, I have enclosed a copy for your reference. Its nice to know that the little guy can still be heard in Washington. I read through the faxed letter and all the points that were brought up have been addressed and solved by my invention. If you would be so kind I would like to take a minute to give you a little background about myself.

My name is Phil Gray and I am an inventor, I have started a company Westech U.S.A. Inc. in Vermont to market my inventions.

One of my Inventions is a device that positions the car's Shoulder Belt in the correct position for children between 38 and 60 inches in height. Prior to the conception of the "CHILD-SAVER" there was no method for children to ride in a car using the Factory Installed Lap/Shoulder Seat Belt System in a safe and legal manner. Please refer to the accompanying product information.

The "CHILD-SAVER" has been designed to ensure the correct position of the Shoulder Belt up to the point of Impact. At the point of Impact the full weight of the child loads the Shoulder Belt holding it in the preset (correct) position during the Impact and Post Impact Stages of a collision. The designed "Break Away" Shoulder Belt Feeder Slot Section located at the top of the "CHILD-SAVER" is detached by the forces exerted on it at the point of impact thus allowing the "CHILD-SAVER" to rotate away from the child therefore preventing any possibility of contact with the child's head during the collision. With the position of the child's body at the point that the Shoulder Belt Feeder Slot "Breaks Away" there is no chance that the piece could possibly strike the child. This design has been proven effective with repeated Impact Crash Tests. I have enclosed a VHS tape of the Impact Test and some Test Results as well as some product samples.

With the "CHILD-SAVER" left unusable after a severe impact it is assured that it will be replaced as recommended by the manufacturer.

As the "CHILD-SAVER" is new technology that addresses and solves a Child Restraint problem that until now has not been dealt with, the only Standards that are available to test against are those for Child Safety Seats. It is expected that new standards will be written as this device proves it's worth in the market place.

All Impact Tests were run at 30 mph which is the accepted standard. The force of Impact in each test was equal to 20 G's, meaning the weight of a 501b child would be equal to 1000lbs during the collision.

Impact Crash Testing has clearly shown the Life Saving benefits of a Shoulder Belt that is correctly positioned prior to a collision. The same tests have also illustrated in dramatic fashion the Fatal Injuries inflicted upon the child when the Shoulder Belt is incorrectly positioned around the neck area.

Pertaining to the letter that was to faxed me by Deirdre.

i. Now that the technology exists it would be logical to develop a safety Standard that would require that the Seat Belt System to be operationally safe for children who are to large for Car Safety Seats or Booster Seats but to small for the present Shoulder Belts.

ii. I assure you that Westech U.S.A. will comply with Sections 151-159 of the Safety Act.

iii. Under normal operating conditions the Factory Installed Lap/Shoulder Seat Belts do not comply with Section S7.1.2 of Standard No. 208. However with the installation of the CHILD- SAVER compliance is achieved.

iv. With the installation of the CHILD-SAVER the length of Shoulder Belt used is increased by only one inch. It should be pointed out that the increased length is not in the form of loose belt, but used to tightly traverse the length of the CHILD-SAVER.

v. It is unknown if the CHILD-SAVER violates Section 108(a)(2)(A) for it does modify the position of the Shoulder Belt but by doing so enhances its performance by eliminating a fatal injury to the child which would normally occur

Could you please give me an interpretation of the Safety Standards as they apply to the CHILD-SAVER.

Thank you for taking the time to consider my request.