Child Safety Information and Resources 2019 7-35-57


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Recaro Child Safety Llc

The petition, supporting materials, and all comments received before the close of business on the closing date indicated below will be filed and will be considered. All comments and supporting materials received after the closing date will also be filed and will be considered to the extent possible. When the petition is granted or denied, notice of the decision will be published in the Federal Register pursuant to the authority indicated below.

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(A) Recaro first characterizes NHTSA's installation of the ProRIDE and Performance RIDE with a top tether as “a direct violation of the instructions and warnings . . . and would constitute a misuse” condition. The petitioner's reasoning is unpersuasive. Recaro apparently argues (the petitioner's arguments are unclear) that NHTSA should not have tested the child restraints attached to the test seat assembly with a lap belt and tether because the manufacturer instructs consumers to use the “vehicle seat belt for any child weighing more than 52 lbs (23.6 kg).” The petitioner is unclear but we surmise that Recaro is saying that because it instructs users not to use the top tether with children weighing more than 52 lb, NHTSA's tethering the CRS was in error.Start Printed Page 39834

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(E) The shortcoming in Recaro's design to meet the applicable FMVSS No. 213 dynamic test requirements poses an unacceptable safety risk. The risk exists and is unacceptable even if there has been no incident of separation in the tether anchorage area thus far.[8] NHTSA does not agree that the tether separation occurs in testing due to the testing equipment [9] but rather as a shortcoming in Recaro's design to meet the applicable FMVSS No. 213 dynamic test requirements.

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c. Electronically: by logging onto the Federal Docket Management System (FDMS) Web site at http://www.regulations.gov/​. Follow the online instructions for submitting comments. Comments may also be faxed to 1-202-493-2251.

This notice of receipt of RECARO's petition is published under 49 U.S.C. 30118 and 30120 and does not represent any agency decision or other exercise of judgment concerning the merits of the petition.

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b. By hand delivery to U.S. Department of Transportation, Docket Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue SE., Washington, DC 20590. The Docket Section is open on weekdays from 10 a.m. to 5 p.m. except Federal Holidays.

We further note that the weighted six-year-old child test dummy is not instrumented and is not used to measure injury values and excursion limits when testing CRSs under FMVSS No. 213.[7] Accordingly, the structural integrity requirement is especially pertinent in assessing the crash performance of the subject Recaro child restraints when used with children weighing above 22.7 kg (50 lb), since Start Printed Page 39835that is the only dynamic performance requirement that applies to the CRSs. Failure to comply with the requirement is not inconsequential to safety.

For further information on this decision contact Zachary Fraser, Office of Vehicle Safety Compliance, the National Highway Traffic Safety Administration (NHTSA), telephone (202) 366-5754, facsimile (202) 366-5930.

1. The dynamic test requirements of FMVSS No. 213 S6.1.2(a)(1)(i)(D) require using a six year old test dummy secured to the test bench using lower anchors and no tether. This test procedure is a direct violation of the instructions and warnings in the instruction manual included with each ProSport child restraint system and would constitute a major misuse of the child restraint by the consumer. (RECARO provided the entire manual as part of its petition.)


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