Interpretation ID: nht94-3.89

TYPE: INTERPRETATION-NHTSA

DATE: August 5, 1994

FROM: Bruce Monnie -- Senior Designer, ADVANCED DESIGN ASSOCIATES

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO LETTER DATED 10/27/94 FROM PHILIP R. RECHT TO BRUCE MONNIE (A42; REDBOOK 6; STD. 208; STD. 209; STD. 213)

TEXT: We are going to be manufacturing a product that is used by consumers, to improve the security of childseats. I would like an interpretation from you, of Standards 209 and 213 or any other standards, that may apply. Below is a description of the how the product is to be used.

The product itself is one-piece steel construction, similar to the flat metal brackets included with some childseats already on the market. The bracket is installed on the seatbelt of the vehicle, to prevent slippage between the lap and shoulder port ions of the seatbelt and to tighten up slack in the lap portion of the seatbelt. It is a temporary installation that does not require any alterations to the vehicle, the seatbelt or the childseat. It does not render the seatbelt inoperative. It does n ot attach to the childseat nor does it interfere with the operation of the childseat. The consumer would be the user.

Our expectation is that this product does not fit the definitions as stated in 213, nor does it fall under 209. In the event that some other Standard may apply, I will give you additional information regarding the performance of the bracket. However , we cannot provide you with a drawing or picture of the product at this time.

Again, the bracket is one-piece with no moving parts. The design makes incorrect installation difficult; whether installed correctly or incorrectly, it cannot become a projectile. The strength required to remove the bracket is greater than the typic al 6 year old child would possess. There is no way for the bracket to be installed incorrectly that would impair or defeat the seatbelt. Incorrect installation would not increase slack in the seatbelt. The strength of the bracket itself, is engineered to withstand forces far beyond those occurring in vehicle accidents.

Furthermore, we will be submitting the product to actual crash-testing, to gather performance data. The results of the testing will be made available at a later date.

Please send me a letter stating your interpretation of Standards 209 and 213, as relating to the bracket. If you have any questions or if more information is needed for your interpretation, please contact me at (503) 235-9447. I am usually at my des k between 8am and 1pm, eastern time.

Thank you for your time in considering this request. Any effort on your part to expedite this matter would be greatly appreciated.