Interpretation ID: nht94-4.48

TYPE: INTERPRETATION-NHTSA

DATE: October 11, 1994

FROM: Robert L. Hart -- Manager - Legal & Engineering Services, Gerry Baby Products Company

TO: Dee Fujita -- NHTSA

TITLE: NONE

ATTACHMT: Attached to 1/4/95 letter from Philip Recht to Robert L. Hart (A43; Std. 213)

TEXT: Dear Ms. Fujita:

Several weeks ago I discussed our new child restraint with you. It is our model #632 with a preliminary name of Gerry Belt Right II Booster/Toddler Car Seat. A copy of the proof from our 1995 catalog describing this product is enclosed.

Model #632 has a removable 5 point restraint system. When the restraint is removed, it is a booster seat according to the definition in FMVSS 213.

Gerry is developing the final name for the product from these nine choices and we want to make sure we are not in violation of the standard if we use any of these names.

Belt Right 20 to 60 Lb. Car Seat

Belt Right Booster Car Seat

Belt Right Convertible Car Seat

Belt Right Convertible/Booster

Belt Right Convertible Toddler Seat

Belt Right Toddler Car Seat

Belt Right Baby to Toddler Car Seat

Belt Right Baby to Booster Car Seat

Belt Right Beyond Baby Car Seat

Please review these names at your earliest convenience and let me know if there are any problems. Thank you very much for your help.

Enclosure (Brochure omitted.)