Interpretation ID: nht80-3.40

DATE: 08/28/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cosco

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 30, 1980, asking whether various parts of your Peterson 78 Child Restraint must comply with section 4.3(a) of Standard No. 209, Seat Belt Assemblies. As explained below, the buckle slides located behind the seat and below the unit and the buckle release button must comply with section 4.3(a) and (b) of the standard. The adjustment lever plate does not have to comply with those sections.

Section S5.4.2 of Standard No. 213, Child Restraint Systems, provides that "Each belt buckle and item of belt adjustment hardware used in a child restraint shall conform to the requirements of S4.3(a) and S4.3(b) of FMVSS 209(S571.209)." As shown in the illustration accompanying your letter, the purpose of the slides located below the unit and behind the seat is to adjust the harness system within the child restraint. Thus they are items of belt adjustment hardware and must comply with S4.3(a) and (b) of Standard No. 209. Likewise, section S4.5.2 of Standard No. 213 specifically identifies the belt buckle as an item which must comply with S4.3(a) and (b) of Standard No. 209. The adjustment lever plate on your restraint adjusts the position of the child restraint from fully upright to fully reclining. It does not adjust the child restraint harness system, however. Thus, the lever plate is not an item of belt adjustment hardware covered by section 5.4.2 of Standard No. 213.

If you have any further questions, please let me know.

SINCERELY,

COSCO

Frank Berndt Chief Counsel U.S. Dept. of Transportation National Highway Traffic Safety Administration

July 30, 1980

Dear Mr. Berndt:

Because of some interpretation differences in our own ranks concerning the Standard No. 213, Child Restraint Systems Requirements for Belt Buckles and Belt Adjustment Hardware, we need an official interpretation of some specific parts of our Peterson 78 Child Restraint.

Please refer to the attached illustration showing the child restraint parts. The slides behind the seat and below the unit, the adjustment lever plate, and the buckle release button are the parts in question.

Do these specific parts have to be in compliance with Standard No. 209 S4.3A or will nickle chrome or a zinc finish be adequate as the parts do not come into contact with the occupant.

Your attention to this matter will be greatly appreciated.

Don Gerken Product Engineer

ENCL.

(Graphics omitted)