Interpretation ID: 23451

Mr. Chris Tinto
Director, Technical & Regulatory Affairs
Toyota Motor North America, Inc.
1850 M Street, NW, Suite 600
Washington, DC 20036

Dear Mr. Tinto:

This responds to your letter concerning S9.1.1 of Federal Motor Vehicle Safety Standard No. 225, "Child Restraint Anchorage Systems" (49 CFR 571.225). Standard No. 225 requires vehicles to have child restraint anchorage systems meeting configuration and other requirements of the standard. S9.1.1 specifies that the lower anchorages "consist of two bars" that, among other things, are not less than 25 mm, and not more than 40 mm in length ⁽¹⁾ 

You ask about forming the two lower anchorages by bending two bar segments from one continuous rod. Your letter is the second from you relating to such a method. Your first was a March 19, 2001, letter (see docket NHTSA-01-10302-2) asking about forming two bar segments that were approximately 35 mm long and that protruded 67 mm from the rest of the rod. In a July 30, 2001, letter (NHTSA-01-10302-1), we responded:

because the bars protrude 67 mm from the main portion of the rod and the part of the rod between the two bars would be in the seat bight and not visible to the consumer, two distinct bars are presented to consumers. A consumer is not likely to be confused about where a child restraint should be attached.We could have concluded otherwise had the bars not protruded 67 mm (or some other substantial distance) from the rest of the rod. For example, if they protruded only 10 mm from the rest of the rod, it would not be apparent that two bars are present. An anchorage system with such a design would not meet S9.1.1 of the standard.

You now ask about bar segments that protrude only about 15 mm from the rest of the rod. Further, the bar segments are gradually ramped from the main portion of the bar. You state:

the rod is bent such that there are 19 degree angled portions of the rod between the rear portion of the rod and the bar segments and 23 degree angled portions of the rod between the edges of the rod and the bar segments [Figure 2]. These angled portions of the rod create ramps, such that even if a parent incorrectly attaches the child restraint's soft anchors onto the rod instead of the bar segment, as the parent tightens the soft anchors, they will self correct and slide onto the bar segments (the 31.5 mm bar segments in Figure 1 and Figure 2).

Issue Presented

The issue you present is whether your lower anchorages consist of two bars meeting the configuration requirements of S9.1.1. One of the purposes of requiring the lower anchorages to consist of two bars and to meet configuration requirements is to standardize the design of the anchorage system, in part to avoid consumer confusion as to where a child restraint should be attached. If the bars were not distinct, consumers may attach a child restraint improperly, e.g., to a part of the seat that was not intended for anchoring a child restraint. The configuration requirements also ensure the universal attachment of all child restraints to anchorages in any vehicle.

Your design raises two questions. First is whether your anchorages consist of two bars, i.e., whether components extraneous to the bars are permitted, such as the straight portion of the rod between the bars. Our answer is no, in that only the bars can be visible to the consumer, and not the extraneous components. This is to standardize, to the extent possible, the design of anchorage systems.

The two bar segments of your current design protrude only 15 mm from the rest of the rod. This is a much shorter distance than the 67 mm protrusion of the design described in your March letter. We will evaluate whether the portion of the rod between the segments is visible when the vehicle seats are adjusted according to the specifications in S10(a) of Standard No. 225. S10(a) specifies that the seats are adjusted to their full rearward and full downward position, and the seat backs are adjusted to their most upright position. ⁽²⁾

The second question involves whether the two bar segments are "straight, horizontal and transverse" (S9.1.1(b)), and "are not less than 25 mm, but not more than 40 mm in length" (S9.1.1(c)). This question relates to the ramped angles forming the bars. Unlike your earlier design, the bars are not distinctly attached to segments that protrude 90 degrees from the rod. Instead, they are gradually ramped 19 and 23 degrees from the rod, and the apex of the protrusion is a straight, horizontal, portion that is 31.5 mm in length. You intend for the portion of the rod forming the apex to be the "bar" that meets the requirements of S9.1.1, and not the portion of the rod that angles from the straight part of the rod.

Your design is permitted. Standard No. 225 does not require the two bars to be mounted on segments that are parallel to the longitudinal centerline of the vehicle. However, we are concerned that consumers might attach the restraint to the ramped portion of the bars. While you believe that a soft anchor will "self correct" and slide onto the straight part of the bar when the parent tightens the webbing attachment, some parents might not tighten the soft attachment as they should. Further, future child restraint anchor attachments might consist of "hard" attachments in addition to soft ones. For these reasons, we recommend that the vehicle be clearly marked as to where the child restraint attachment should be properly anchored.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:225
d.4/10/02

² When the Static Force Application Device (SFAD) 2 is used in testing and cannot be attached to the lower anchorages with the seat back in this position, S10(a) specifies that the seat back is adjusted as recommended by the manufacturer in its instructions for attaching child restraints. If no instructions are provided, the seat back is adjusted to the position closest to the upright position that enables SFAD 2 to attach to the lower anchorages.