Interpretation ID: nht80-3.2

DATE: 06/11/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Questor Corporation

COPYEE: D. F. MITCHELL -- V. P. AND GEN. MGR, QUESTOR JUVENILE FURNITURE CO.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 9, 1980, to Stephen Oesch of my office concerning Standard No. 213, Child Restraint Systems. You requested an interpretation of whether, an alternative configuration you are considering for the Kantwet "One Step" child restraint would comply with Section 6.1.2.2.1(c) of the standard.

You described the configuration as one in which the crotch strap would be modified so that it "is permanently attached to the shield (in a manner similar to the two upper torso restraints which the [agency's] April 29th letter stated were integral parts of the shield. The bottom end of the crotch strap would be buckled to the base of the seat between the child's legs after the child is seated."

As you have described the modified crotch strap, it is an integral part of the movable shield since it is not a separate device that must be attached to the shield each time the restraint is used, but is formed as a unit with the shield. Since the crotch strap is an integral device, it can be attached during the testing of the restraint.

As mentioned in our letter of April 29, 1980, we urge that you and other manufacturers take the additional step of assuring that the upper torso restraint and the crotch strap permanently remain integral parts of the adjustment or anchorage device to which they are attached.

SINCERELY,

Questor Corporation

May 9, 1980

Steven Oesch National Highway Traffic Administration United States Department of Transportation

Re: NOA-30

Dear Mr. Oesch:

Mr. Frank Berndt's letter of April 29, 1980, addressed to our Mr. J. P. Koziatek, P.E., has been referred to my attention for follow-up. As stated in our phone conversation of today, it appears that the basis of the opinion expressed in that letter is contained in the first sentence of the third paragraph: "The crotch strap used in the Kantwet 'One Step' is not an integral part of the movable shield." That paragraph continues, "The crotch strap is a separate device . . . In Contrast, the two upper torso restraints appear to be integral parts of the shield since they are designed to remain attached to an adjustment device and anchorage which are in turn permanently affixed to the shield."

The purpose of this letter is to suggest an alternative configuration for the subject seat embodying a crotch strap that would fall within the above quoted parameters, and request an interpretation of the modified configuration vis-a-vis Section S6.1.2.2.1(c) of Standard No. 213, Child Restraint Systems. The modified crotch strap to be used in the Kantwet "One Step" would be an integral part of the movable shield, that is permanently attached to the shield (in a manner similar to the two upper torso restraints which the April 29th letter stated were integral parts of the shield). The bottom end of the crotch strap would be buckled to the base of the seat between the child's legs after the child is seated.

Your department's prompt opinion would be greatly appreciated, inasmuch as we need to finalize design of the seat at this time in order to be in compliance with the Standard by its effective date, and to comply with the catalog printing deadlines of certain of our customers.

Ronald A. Kramer Assistant General Counsel