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From Products Liability Law Daily, January 26, 2015

Ease of use standard for child restraint anchorage systems proposed by NHTSA

By Pamela C. Maloney, J.D.

As required by MAP-21 and in accordance with its 2011-2013 Priority Plan, the National Highway Traffic Safety Administration has proposed amendments to the child restraint anchorage system standard to improve the ease of use of both lower and tether anchorages of child restraint anchorage systems. Comments on the proposed amendments are due on or before March 24, 2015 (80 FR 3743, January 23, 2015).

Background. In its 2011-2013 Vehicle Safety and Fuel Economy Rulemaking and Research Priority Plan, which was issued in March 2011, NHTSA announced that it would be addressing issues relating to the usability of child restraint anchorage systems in light of increased consumer complaints about the difficulties they face in understanding and using these systems. In 2012, Congress passed the Moving Ahead for Progress in the 21st Century Act, or MAP-21, (Pub. L. 112-141), requiring NHTSA to initiate a rulemaking proceeding to amend FMVSS No. 225 in order to improve the ease of use for lower anchorages and tethers in all rear seat seating positions in all vehicles in which installation of anchorages and tethers is feasible. The proposed rulemaking satisfies the requirements of MAP-21 by proposing requirements that would improve the ease with which consumers can access and use the anchorages and improve the visibility of these anchorages so that consumers could more easily identify them as parts of a child restraint anchorage system.

Proposed changes to lower anchorages. In order to make it easier for consumers to attach child restraints to the lower anchorages of the child restating anchorage system, the proposed amendments to FMVSS No. 225 would ensure that vehicle manufacturers produce lower anchorages that (a) have sufficient clearance around each lower anchorage for consumers to maneuver the child restraint system (CRS) connector; (b) are located such that the CRS connector can be attached to the bar using a reasonable amount of force; and (c) are within two centimeters (cm) of the outer surface of the ‘‘seat bight’’ (the seat bight is approximately the intersection of the seat bottom cushion and seat back cushion).

Proposed changes to tether anchorages. To make tether anchorages easier to use, the proposal would standardize the configuration by prohibiting the anchorages from being placed under a vehicle’s seat or hidden under a vehicle’s carpet and by requiring anchorages to be placed where there is enough space for consumers to tighten the tether strap.

Identification of anchorages. The proposal would also require vehicles and CRSs to use a standardized symbol to more effectively identify the anchorages in the vehicle and the components on CRSs that attach to those anchorages.

Comments requested. In addition to requesting comments on the proposed changes to FMVSS No. 225, NHTSA has requested comments on several other issues relating to the usability of child restraint anchorage systems, including whether child restraint anchorage systems and/or tether anchorages should be required in more rear seating positions than the current standard requires. NHTSA is also seeking comments on the merits of requiring vehicle and CRS manufacturers to use standardized terminology in users’ manuals when describing components of the child restraint anchorage system and the connectors of these systems and on the merits of consumer information that advises users to attach the tether when restraining a child in a harnessed child restraint, regardless of the weight of the child.

Compliance date. NHTSA proposed a compliance date of three years following the date of publication of the final rulemaking in the Federal Register, with optional early compliance.

MainStory: TopStory NHTSANewsStory ChildrensProductsNews BabyProductsNews MotorEquipmentNews

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