Interpretation ID: nht89-1.13

TYPE: INTERPRETATION-NHTSA

DATE: 02/03/89

FROM: ROBERT C. CRAIG -- QUALITY CONTROL MANAGER COSCO INC

TO: GEORGE L. PARKER -- DIRECTOR OFFICE OF DEFECTS INVESTIGATION - ENFORCEMENT U.S. DEPARTMENT OF TRANSPORTATION N.H.T.S.A.

TITLE: 49 CFR 571.213; STANDARD NO. 213 CHILD RESTRAINT SYSTEMS. @ 5.5.1. LABELING; RULING: INCORPORATE THE METRIC SYSTEM OF MEASUREMENTS INTO THE STANDARD.

ATTACHMT: ATTACHED TO LETTER DATED 04/17/89 FROM ERIKA Z. JONES -- NHTSA TO ROBERT C. CRAIG, REDBOOK A33(2), STANDARD 213

TEXT: Dear Mr. Parker:

Cosco, Inc. has been purchased by Dorel Industries, Inc. of Montreal, Quebec. With the purchase, Cosco is making child restraints for the United States and Canada. Canada requires the metric system of measurements on all child restraint labels and instr uctions. To meet the Canadian requirement, Cosco wishes to incorporate the metric system of measurements on their present labels and instructions.

Example: "This child restraint is designed for use only by children who weigh 40 pounds (18 kg) or less and are 40 inches (1 M) or less in height."

Cosco requests permission to include metric equivalents on all Cosco child restraints and confirmation that use of metric equivalents as described above is in conformance with the requirements of FMVSS 213.

Thanking you in advance for your consideration of the above. If there are any questions or information needed, please contact me directly.

Sincerely,