Interpretation ID: nht71-2.13

DATE: 03/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bolt Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: During your visit which Michael Peskoe on March 4, 1971, you indicated that you were desirous of having a reply to the question that you posed in your letter of December 14, 1970, concerning S4.6 of Standard No. 213, without delaying that answer until the response to the entire letter had been prepared.

Your question concerning S4.6, which states in part, " . . . [Each] forward-facing child seating system shall have a seat back. The height of the seat back shall be . . .," is whether an adjustable head restraint can be used to meet this requirement provided "(a) it meets the height requirement measured at the lateral center of the head restraint, and (b) it is accompanied, in the instruction sheet, by instructions for adjustment to fit the child."

It was intended by paragraph S4.6 that a head restraint could be used to meet the above height requirement, proviced that it meets the other requirements of the standard, such as the head impact protection requirements of S4.10, as well as those you described.