Interpretation ID: nht94-6.30

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John Rhein -- Fisher-Price, Inc. (East Aurora, NY)

TITLE: None

ATTACHMT: Attached to letter dated 5/3/93 from John Rhein to John Womack (OCC 8639)

TEXT:

This responds to your letter about the consumer registration card required by Safety Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding.

You ask about three features of a registration card you wish to produce, and enclosed a sample card setting forth a "proposed format." You first ask whether you may specify "Please Print" on the card. The answer is yes. NHTSA interpreted Standard 213 as permitting this feature, in an October 20, 1993 letter to Mr. Richard Glover of the Evenflo Juvenile Furniture Company.

You also ask whether you may use "open box spaces" for the consumer's name and address, to encourage consumers to print the information clearer (one character per box space). The answer is yes. NHTSA interpreted Standard 213 as permitting "blocked squares" for the consumer's name and address in a June 14, 1993 notice (copy enclosed) denying Evenflo's petition for reconsideration of the rule that established the registration card requirement.

Finally, you ask whether you may enlarge the consumer name and address space of the card, to provide consumers more space to print the information and thus increase the likelihood the information will be legible. The answer, with reference to the sample card you provided, is yes. Under S5.8 of Standard 213, the registration form must conform in size, content and format to forms depicted in the standard (figures 9a and 9b). The figures specify a minimum size for the card. Moreover, in the enclosed June 1993 notice, NHTSA explained that "(f)ormat refers to the general appearance of the form and to aspects such as type size, size and placement of margins, size and placement of the spaces for the consumer's name and address, and overall organization of the printed material."

The sample card you provided meets the minimum size requirement specified in the standard, and the general appearance and overall organization of the card is the same as that depicted in the standard (figure 9a). While the consumer name and address space is slightly larger than depicted in the standard, we conclude that this slight deviation is consistent with the standard's format requirements. This conclusion is based on the fact that this slight change does not affect the general appearance or overall organization of the card, and because the change provides consumers more space to print the information, i.e., it will not detract from the utility of the card.

Please contact Ms. Deirdre Fujita of my staff at (202) 366-2992 if you have any questions.