Interpretation ID: nht93-2.44

DATE: April 5, 1993 EST

FROM: :Linda Roberson -- President, Body Safety Kids Club, Inc.

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6-25-93 from John Womack to Linda Roberson (A41; Std. 213; VSA 102); Also attached to letter dated 2-25-92 from Paul Jackson Rice to Phil Gray (VSA 108(a)(2)(A)); Also attached to letter dated 9-6-84 from Frank Berndt to Phillip Ables.

TEXT: Dr. Jeff Michael has talked with me this morning, and has very kindly given me your name and information to ask you to consider. I have enclosed two safety harness that I have two patents on. One is to the safety of tethering the child and one is a divisional patent to a safety club and ID system for children. There are several things here that I need information about and I enclosed some information for you to see what the safety club, in the future will evolve into, I hope.

My main concern with your council is for safety also when the child is riding in the car. I would like for these children to have a safety device when they are out with their guardian, and also when they are going to or returning from outings, etc. I have also enclosed a little hanging tag which is to be redone for the harness and to hang on for information. I have corrected some mistakes, and I also want to know what I can say when marketing these little harness. For my older grandson, I use the blue harness and I take the shoulder strap and go down through diagonally to keep it out of his hands and to keep it out of his face area. I would like very much for this to be tested. I have used it on him, but thankfully have never had any accident, or quick stops and I wondered if your testing lab and dummy could test this aspect. For the pink harness I have stapled or pinned a replica of a lap seat belt and how it passes through my harness for the 3 year old, before that age, they are in car seats. I say 35 pounds for this age, and approximately 34-40 pounds for the previous shoulder strap. Using the seat belt, I think this harness could also be labeled as an accessory to the seat belt; because when it is so threaded through the child cannot stand up and come out of their position. So many times they just slip out since the seat belt just goes across the lap and you turn around and the child is standing up. A very unsafe situation.

I have designed these harness so the child can't remove them, so they can grow with them, and so there is at least an inch on either side of the child waist band allowing for your seat belts and for growth.

The pink is a stronger webbing, and this was designed for blind children and hyperactive children and children who need extra strength. The regular harness in the summer material is the manufacturers. I have not started to manufacture the harness for the blind, as I have an improvement patent that is going in and it has lots of accessories on the harness for their needs.

I am going to try and write and find out the association where I could get my product tested for the high chair and my accessory belt in conjunction with the harness. If you know of any association on a federal level, please advise me. I also wanted to know if I could get approval from the council on new products

to get my harness tested, but I don't know how to do that. I am a nurse anesthetist and I work full time and also for the past two years part time in addition, but I have obtained 3 patents and have been trying to market and get manufacturing, etc. I am so tired and so broke, I just need help, assistance, or guidance. I am going to do a booth with the Governors Hwy. Safety in Asheville 14-16 of this month and I gave them harness (6) for door prices, but only for tethering children in crowds.

I do know this works for me and my grandson, but unfortunately they are in Fla. and I can't get their pictures with seat belts. I did some shading and drawings and they are attached, and tried to run a prototype of a shoulder strap and seat belt through the harness to show you how I threaded them. I just don't want to advertise wrong, or to do anything unsafe, or to be sued. I have just been selling these to two little stores and a lot of acquaintances.

I have given these little things I printed up, but I put the size 50 lbs. Truly it should be 35-40 lbs. Because the child starts to use these two devices by themselves at this age and weight. Age 3 1/2-4.

I also wanted you to look at my little paper that I will be including later for children as a service. My grandson got lost at Disneyworld 3 1/2 year ago for several hours and he had been wearing a wrist harness and he took it off. The lost and found was not for kids so I developed a safety emblem and an ID code and registration card for kids. Right now I am not using the club for record keeping as I can't afford it and I am using the information only as a warranty for the parent for the harness, but someday I would like to help the hwy. and local police to ID children, just from the harness number. My main aspect is to keep them from being lost, or keep them from getting hurt in cars in travel.

I would greatly appreciate any help you may give me or direction. Mr. Michael did not advise me to send the harness, but since I am the only employee of this business and I have to do everything, I just don't have the time to keep duplicating myself, and I certainly need help quickly, as I have told people this is something I do. I do not want to advise people wrongly, or harm anyone. Can you put these harness on dummies and try the seat belt and shoulder strap. Then, does this look like the harness can meet these standards you have an accessory to the existing seat belt and or shoulder strap for kids a certain age. What age, or weight do your standards allow children to use the two items mentioned without a car seat?

These items go over clothing so they do not have to be fire repellent as they are just like clothes. I always have one side cotton and the other water repellent or nylon to give strength and protection to chest area.

I am sure I must meet some sort of performance standards as a safety harness and for you as a safety belt accessory. The harness is better and safer for kids than any existing harness, and I have a patent readying for disabled kids of all kinds.

Isn't there anybody who can give me information on a grant or something as I have a very good patent for the existing seat belts, they are not right for children and I just can't afford to pay out anymore or work anymore to get this

accomplished. It would certainly help children in travel, we could also eliminate many devices that are sold in conjunction with safety in the high chair, and car to make children more comfortable and safer.

I have enclosed some information for your review, I have not yet sent Good Morning America any harness and I certainly did not want to go on the air and say anything about a seat belt and be incorrect. The second letter is from a woman who my sister sold a harness to when she was in London last year because the child kept leaving the parents side at the airport.

You see I am in a dilemma and I work on this stuff most of my off time from work. I also think having proof that this was indeed safe would greatly help me to market, not to mention the additional safety of kids; running out into moving cars, getting lost or missing; in cars to keep them in position, and even in high chairs in conjunction with little belts. We have a coloring booklet I am doing now and waiting for pictures to give children and parents instructions on safety and use of the harness. I would greatly appreciate any help you can give me, my phone number is on page one.

Any additional information you can think of I would appreciate. I am thanking you most sincerely.

P.S. On that sheet for the Safety Club and my club number, if and when I can ever afford to dot this as a service, how will law enforcement personnel know this is available, I still don't have a computer. Maybe this portion could be not for profit???

Attachments: - Body Safety Kids Club, Inc. Sales Brochure and Instruction/Direction Sheet - Diagram of Body Safety Kids Club Vest - Letter dated 3-2-93 from R. T. Sawyer, Director, Biopharm Limited to Liz Davies, Buying Director, MotherCare

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