Interpretation ID: nht88-1.14

TYPE: INTERPRETATION-NHTSA

DATE: JANUARY 12, 1988

FROM: ROBIN C. GELBURD -- MORRISON & FOERSTER

TO: ERIKA C. JONES -- CHIEF COUNSEL-NHTSA

TITLE: COMPLIANCE WITH 49 C.F.R. @ 571.213 "CHILD RESTRAINT SYSTEMS"

ATTACHMT: ATTACHED TO MAY 31, 1988 LETTER FROM JONES TO GELBURD

TEXT: We represent Hasbro, Inc. and seek an opinion from the National Highway Traffic Safety Administration ("the Agency") about whether a proposed Hasbro product would, in any way, contravene or compromise regulations promulgated by the Agency pursuant to the National Traffic and Motor Vehicle Safety Act -- specifically 49 C.F.R. @ 571.213, the regulation pertaining to Child Restraint Systems.

The product, which we have enclosed for your convenience and evaluation, is intended, inter alia, to be used in conjunction with a car seat restraint; it would be inserted inside the seat to cushion and insulate the child. It should be noted that the product, as finally marketed, will have two additional features:

1. A pocket will be added below the word "Playskool" which will contain a squeaking teddy bear made of 100% spun polyester; and

2. A set of plastic keys on a key ring, detachable with velcro, will be added on the end of the yellow tether. Each key will be 2-1/8 inches long and will have rounded edges.

Please advise me if any further information is necessary to determine whether the product complies with relevant statutes and regulations within your jurisdiction.

We appreciate your prompt consideration of this matter.

Enclosure