Interpretation ID: Harness_and_LATCH

Mr. Terry Emerson
Product Standards Manager
Cosco
2525 State Street,
Columbus, IN 47201

Dear Mr. Emerson:

This responds to your letter of July 12, 2001, asking "Is the Cosco Travel Vest required to be LATCH compatible by September 1, 2002?" Stated differently, you ask whether child restraint vest systems are required by Standard No. 213 to have attachments that enable the restraint to connect to a child restraint anchorage system on a vehicle (49 CFR 571.225). ⁽¹⁾ The answer to your question is no.

According to the marketing literature you enclosed with your letter, the Travel Vest is a 5-point harness restraint. Section 5.9(a) of Standard No. 213 (49 CFR 571.213) excludes harnesses from the requirement in the standard that child restraints must have components that attach to the lower anchorages of a LATCH system. We excluded harnesses out of practicability concerns. We did not know whether harnesses had a structural member that was strong enough to withstand the forces that would be imposed on it by the LATCH connectors. (See LATCH final rule, 64 FR 10786, 10808; March 5, 1999.)

I hope this information is helpful. If you have any questions, please feel free to contact Deirdre Fujita at this address or at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:213
d.8/31/01

1. ¹ "LATCH" is a term used by industry and retail groups referring to the child restraint anchorage system required by Standard No. 225. LATCH stands for "lower anchorages and tethers for children." For convenience, we will use the term in this letter.