Interpretation ID: nht81-2.28

DATE: 05/21/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Indiana Mills & Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 21 1981

NOA-30

Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 120 West Main Street Carmel, Indiana 46032

Dear Mr. Lawler:

This responds to your recent letter concerning S6.2.4 of Standard No. 213, Child Restraint Systems. You asked whether section 5.2(d)(1) of Standard No. 209 is the relevant section to be used in testing the release force on buckles used on a child restraint system. The answer is yes.

Section 6.2 of Standard No. 213 sets out the test procedure for measuring the release force for buckles used in child restraint systems. Section 6.2.4 states that the buckle is to be operated in the manner described in section 5.2(d) of Standard No. 209, Seat Belt Assemblies. S5.2(d)(1) of Standard No. 209 sets out the procedure for measuring the buckle release force. You are correct that S5.2(d)(2) and (3) set out the procedures for conducting several other requirements of Standard No. 209 which do not apply to child restraints and thus are not relevant to the buckle release force test.

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

Sincerely,

Frank Berndt Chief Counsel

April 2, 1981

Mr. Frank Berndt, Chief Counsel National Highway Traffic Safety Administration 400 7th Street S.W., Room 5219 Washington, D.C. 20590

Dear Sir:

Indiana Mills and Manufacturing, Inc. is a manufacturer of seat belt assemblies for use in motor vehicles. We make every effort to comply with the requirements of the motor vehicle safety standards set forth by the National Highway Traffic Safety Administration.

Standard No. 213 (49 CFR 571.213), Child Restraint Systems, refers in S6.2.4 to S5.2(d) of Standard No. 209 (49 CFR 571.209), Seat Belt Assemblies. The buckle release mechanism mentioned in S6.2.4 (213) is to be operated in the specific manner described in section 5.2(d) of Standard No. 209. We assume that only the portion of S5.2(d) of Standard No. 209 pertaining to the method of releasing the buckle mechanism is included by reference in Standard No. 213, and we believe that portion consists of paragraph (1) beginning with the words "The buckle release force shall be measured..." through the end of the paragraph. Because S5.2(d)(2) and S5.2(d)(3) deal with subjects other than the proper method of releasing the buckle mechanism, we interpret Standard No. 213 as excluding them while including only the portion of S5.2(d)(1) described above.

We would appreciate receiving from you an official written explanation of the intent of S6.2.4 of Standard No. 213.

Thank you for your assistance.

Yours very truly,

William E. Lawler Specifications Manager

WEL/jr