Interpretation ID: nht93-8.4

DATE: November 9, 1993

FROM: Jerry Schwebel -- Executive Vice President, Star Comm Ltd.

TO: Walter Myers -- Attorney, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 5/12/94 From John Womack To Jerry Schwebel (A42; Std. 213)

TEXT: Dear Mr. Myers,

Thank you for the time given to us by you and your associates to discuss our air filled children's car seat.

In accordance with our discussion we are requesting an opinion with respect to the retention of the front strap. This strap is marked in the attached diagram. (Exhibit A)

Description:

The strap is not part of the primary restraint. Its main function is to offer additional side impact protection by keeping the leading side of the seat attached to the opposite side so as to prevent the child from rolling out. The strap is non load bearing in frontal impact.

Summary:

We recommend use of the strap based upon the improved HIC factor, and additional side impact protection. Test data, with and without the strap is included as shown on exhibits respectively B & C to substantiate this.

Your prompt response is appreciated.

Sincerely,