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Interpretation ID: Hyundai_flaps_and_dots

    Robert Babcock, Manager
    Hyundai America Technical Center, Inc.
    5075 Venture Drive
    Ann Arbor, MI 48108


    Dear Mr. Babcock:

    This responds to your letter concerning the lower anchorage marking requirements in S9.5 of Federal Motor Vehicle Safety Standard (FMVSS) No. 225, "Child Restraint Anchorage Systems" (49 CFR 571.225). As explained below, the concept you ask about would be permitted.

    By way of background, FMVSS No. 225 requires vehicles to have child restraint anchorage systems consisting of two lower bars and a tether anchorage. The standard contains "marking and conspicuity" requirements for the lower bars to increase the likelihood that consumers will know that a child restraint anchorage system is present in their vehicle and that they will use it. These requirements are for manufacturers either to mark the vehicle seat back with a small circle where the bars are located (S9.5(a)), or to install a child restraint anchorage system such that the bars are visible (S9.5(b)).

    You request confirmation "that the marking and conspicuity requirements of S9.5 are satisfied when child seat anchorages that are covered with a removable flap or cover are identified with words, symbols or pictograms within the spacing limitations provided by S9.5(a)(3)". Stated differently, you ask whether, having marked the seat back as specified by S9.5(a), you may cover the bars with an unmarked removable cap or cover.

    Our answer is yes, the cover is permitted, even if the cover is unmarked. In the situation you describe, Hyundais marking the vehicle seat back with the small circles specified in S9.5(a) satisfies the marking and conspicuity requirements of FMVSS No. 225. Having met the requirements by the option of S9.5(a), you are not prohibited from placing a cover over the bars. In fact, the requirements of S9.5(a) presume that the lower bars are hidden from view. Covering them as you describe is therefore not a problem. We assume, of course, that the covers will not obscure the circles required by S9.5(a).

    If you have further questions, please contact Ms. Deirdre Fujita of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:225
    d.3/22/05