Interpretation ID: nht81-1.39
DATE: 03/16/81
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Cosco
TITLE: FMVSS INTERPRETATION
TEXT:
MAR 16 1981
NOA-30
Mr. Roy Knoedler Senior Industrial Designer COSCO 2525 State street Columbus, IN 47201
Dear Mr. Knoedler:
This responds to your letter of January 9, 1981, concerning Standard No. 213, Child Restraint Systems. You asked whether a three-point harness system can be used on a rear-facing infant restraint. As explained below, the answer is yes.
Section 5.4.3.3 of the standard sets requirements for the belts or other devices used as an integral part of a child restraint to restrain a child. Section 5.4.3.4 of the standard, referred to in your letter, sets requirements for child restraint systems which consist solely of a harness, such as the Little Rider Child's Safety Harness formerly produced by Rose Manufacturing Co. (The harnesses covered by section S5.4.3.4 of the standard were formerly classified as type III seat belt assemblies and regulated by Standard No. 209, Seat Belt Assemblies.)
Section 5.4.3.3. provides, in part, that its requirements apply to "each child restraint system that is designed for use by a child in a seated position...." In referring to systems that are used by a child "in a seated position", the section is referring to conventional, forward-facing child restraints where the child sits in the restraint in the same manner as he or she would sit in a chair. It does not refer to rear-facing devices for use by infants where the infant is always held in a reclining position.
Because rear-facing restraint systems use the surface behind the child as the primary means of restraining the infants, the belts in such systems are primarily used to control the excursion of the child upon rebound after an impact. Field and laboratory test data available on rear-facing infant restraints indicate that a three point belt system can adequately restraint a child in rebound situations.
If you have any further questions, please let me know.
Sincerely,
Frank Berndt Chief Counsel
Mr. Frank Berndt, Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590
January 9, 1981
Dear Mr. Berndt:
Our company would like a written opinion by NHTSA on whether three-point harness systems will be allowed on rear-facing infant car restraints under the specifications outlined in the Standard No. 213-80 "Child Restraint Systems."
There have been rear-facing infant restraints which use three-point harness systems for many years. By a 3-point harness, I mean belts which pass over each shoulder of the child and a crotch strap to which the two shoulder straps attach. This method has been, and still is, being used on rear-facing restraints manufactured or sold by General Motors, Ford, Questor, Century, and Peterson. To my knowledge, there has never been any information gathered to indicate that such harness systems are anything but safe, effective, and convenient methods of restraining rear-facing infants.
It states in the Standard 213 under Section S5.4.3.4. Harnesses "Each child harness shall:
(a) Provide upper torso restraint, including belts passing over each shoulder of the child;
(b) Provide lower torso restraint by means of lap and crotch belt; ..."
Since there is no reference here to whether this applies to rear-facing or forward-facing units, does this mean that a three-point harness would not be allowed on rear-facing infant restraints? Such a requirement would ban from the market many universally recognized safe and effective infant restraints and apparently nothing would be gained in the way of increased safety.
As this may affect our method of manufacture, an early response to this matter will be greatly appreciated.
Sincerely,
Roy Knoedler Senior Industrial Designer
cc: Val Radovich