Interpretation ID: aiam4219
Senior Product Designer
Century Products
Inc.
1366 Commerce Drive
Stow
OH 44224-1793;
Dear Mr. Meeker: This responds to your letter to Mr. Vladislav Radovich of ou Rulemaking division, seeking an interpretation of Standard No. 213, *Child Restraint Systems* (49 CFR S571.213). Specifically, you noted that Collier-Keyworth now sells a child seat with a movable shield that is not spring- loaded. A movable shield that is not spring loaded will remain in position in front of the child seat occupant, even if the crotch strap attached to the shield is not properly fastened. You stated that your company would like to build a child seat with a movable shield that is not spring-loaded, and stated your opinion that shields need not be spring-loaded to comply with the requirements of Standard No. 213.; Your opinion is correct if read narrowly, because no provision o Standard No. 213 requires or ever has required movable shields on child restraints to be spring-loaded. However, if a child restraint incorporates a movable shield, section S.6.1.2.1.2 of Standard No. 213 specifies that the child restraint must be certified as complying with test configuration II. In test configuration II, the child restraint is subjected to a 20 mile per hour frontal crash. Section S6.1.2.3.1(c) provides that none of the child restraint belts are to be attached during this test, *unless* the belts are an integral part of the movable shield. Because of this requirement and the agency's interpretations thereof, child restraints have generally incorporated spring-loaded movable shields. This agency discussed these provisions and their applicability to the Collier-Keyworth non-spring-loaded shields at length in a July 3, 1985, letter to Mr. Frederick Locker. I have enclosed a copy of this letter for your information.; If you have any further questions about this subject after reviewin the letter to Mr. Locker, please contact Mr. Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.; Sincerely, Erika Z. Jones, Chief Counsel