Interpretation ID: 22843

Mr. Matz Larsson
Sales Manager
Broderna Holmbergs Fabriks AB
Box 63
SE-334 21 Anderstorp
Sweden

Dear Mr. Larsson:

This is in response to your letter of March 7, 2001, asking whether the buckle release on your child restraint system meets the area requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, "Child Restraint Systems." The answer is yes.

S5.4.3.5(c) of Standard No. 213 requires any buckle in a child restraint system to "[m]eet the requirements of S4.3(d)(2) of FMVSS No. 209," which reads:

A buckle designed for pushbutton application of buckle release force shall have a minimum of 452 mm with a minimum linear dimension of 10 mm for applying the release force, or a buckle designed for lever application of buckle release force shall permit the insertion of a cylinder 10 mm in diameter and 38 mm in length to at least the midpoint of the cylinder along the cylinder's entire length in the actuation portion of the buckle release. A buckle having other design for release shall have adequate access for two or more fingers to actuate release.

Since your buckle requires a sliding action to activate the buckle release, we consider your buckle release to be designed for slide application rather than pushbutton or lever application. Thus, your buckle release falls under the "other design for release" category.

Under the last sentence of S4.3(d)(2), a buckle having other design for release must have adequate access for two or more fingers to actuate release. You claim that your buckle release meets this requirement. We agree. All of our staff working on this response were able to place two fingers into your slide action release button to actuate release. Thus, we have determined that your buckle release meets the requirement of S4.3(d)(2).

If you have any further questions, please feel free to contact Mr. Dion Casey of this office at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel
ref:213#209
d.4/10/01