Interpretation ID: nht93-7.46

DATE: November 1, 1993

FROM: Dan Neaga -- Project Engineer, Advanced Engineering Business Unit, Johnson Controls, Inc.; Dianna Sabo -- Engineering Manager, Advanced Engineering Business Unit, Johnson Controls Inc.

TO: DOCKET SECTION, NHTSA

COPYEE: S. Furr; B. Batzer

TITLE: Re: Request For Clarification On FMVSS 213 S5.2.2.1 (b)

ATTACHMT: Attached To Letter Dated 6/9/94 From John Womack To Dan Neaga And Dianna Sabo (A42; Std. 213)

TEXT: Dear Sir/Madam:

This letter is in regard to FMVSS 213 S5.2.2.1 (b). Johnson Controls, Inc. designs child seats for children that weigh from 20 to 60 pounds. We have developed a new design for an Integrated Child Restraint System (ICRS) that uses the same seat back surface as the adult occupant. Therefore, no lateral support other than the one offered to the adult occupant is provided.

We have enclosed a set of three illustrations that show a generic adult seat (a) with the child seat in fully stored position; (b) with the child seat deploying; (c) with the child seat fully deployed.

The wording in FMVSS 213 S5.2.2.1 (b) is "Each system surface provided for support of the side of the child's torso shall be flat or concave and have a continuous surface of not less than 24 square inches for systems recommended for children weighing 20 pounds or more . . . ", and we have interpreted it to mean that lateral support is not necessarily required. Please confirm that surface provided for support of the side of the child's torso is not required by FMVSS 213 under these circumstances.

The information and design concepts that we have provided you with are confidential. If you need additional information regarding this matter, please contact me at the above address, or you may reach me at [Illegible Word]. My fax number, should you require it, is (313) 454-7874.

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We thank you very much for your cooperation and look forward to hearing from you soon.

Sincerely,

JOHNSON CONTROLS, INC.

Enclosures