Interpretation ID: nht72-1.46

DATE: 06/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Peterson Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 24, 1972, inquiring whether Standard No. 213 requires head rests, arm rests, and shields of certain Peterson child seats to be covered with nonrecovery, or slow-recovery energy absorbing material.

Paragraph S4.10.3 of Standard No. 213 exempts the contactable area of a rigid side of a child seating system from the requirement that it be covered with deformable, nonrecovery, or slow-recovery energy absorbing material (S4.10.1 and S4.10.2), when the contactable area of the side that is higher than the system's seating surface is at least 24 square inches. We would consider head rests, arm rests, and shields of the Peterson child seats in question to be within the exemption of S4.10.3 if their contactable area above the child seating surface is 24 square inches or more.

I point out, however, that the proposal of September 23, 1970 (35 F.R. 14786) would alter this result, as the exemption would no longer extend to any components contactable by the head.