Interpretation ID: nht71-3.7

DATE: 05/24/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 7, 1971, requesting clarification of S4.9 of Motor Vehicle Safety Standard No. 213, "Child Seating Systems." Your letter asks whether the release mechanism requirements of S4.9 apply to either a Type 1 or Type 2 seat belt assembly that is used to restrain the child seating system pursuant to S4.4(b) of the standard. Your letter also raises by implication the question whether a Type 1 or Type 2 seat belt assembly that pursuant to S4.9, is used to directly restrain the child must also meet the release mechanism requirements of S4.9.

The answer to both questions is no. The release mechnism requirements that each Type 1 or Type 2 seat belt assembly is required to meet are those specified in Motor Vehicle Safety Standard No. 209. The requirements for the release mechanism specified in S4.9 of Standard No. 213 apply to those components, other than a Type 1 or Type 2 seat belt assembly, that directly restrain the child.