Interpretation ID: aiam4249
CRS Research
P.O. Box 313
Buffalo
NY 14226;
Dear Ms. Kelleher: This responds to your letter to Stephen Kratzke of my staff, seeking a interpretation of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). Specifically, you stated that a client planned to produce two child restraint models whose harness and crotch straps would be integral parts of a movable shield. You stated your belief that these straps were an integral part of the shield within the meaning of section S6.1.2.3.1(c) of Standard No. 213. Accordingly, you asked that this agency permit these straps to be attached during the Configuration II testing required by section S6.1.2.1.2. You stated that a similar request for harness attachment was 'granted' to the Collier-Keyworth Company.; First, I would like to make clear that this agency does not gran requests by manufacturers to avoid following the compliance test procedures specified in Standard No. 213. We interpret the requirements of Standard No. 213 as they apply to particular factual situations. When those same factual situations arise again, our interpretation of the requirements is the same, regardless of which manufacturer is involved.; For your information, I have enclosed a copy of a July 3, 1985, lette this agency sent to Mr. Frederick Locker, addressing whether a proposed Collier-Keyworth child restraint could attach its belts during the Configuration II testing. We concluded that belts that are attached to and not easily removed from a movable shield are integral parts of the shield, within the meaning of section S6.1.2.3(c). This conclusion means that those belts may be attached during the Configuration II testing.; Judging by the pictures enclosed with your letter, it appears that eac of the two child restraint models designed by your client also has belts that are attached to and not easily removed from the movable shield. If our belief is correct, those belts could be attached during the Configuration II testing.; If you have any further questions or need more information on thi subject, please contact Mr. Kratzke at this address or by telephone at (202) 366-2992.; Sincerely, Erika Z. Jones, Chief Counsel