Stephanie Merton Tombrello - Comment

Document ID: NHTSA-2008-0149-0004
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: September 25 2008, at 01:57 AM Eastern Daylight Time
Date Posted: September 25 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: September 12 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: November 12 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 80722cec
View Document:  View as format xml

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The issue of lockable belts as regulation equipment in motor vehicles is key to making the tools for secure installation of safety seats for children readily available for all sizes of children. In the past few years, the marketplace has expanded greatly with more and more safety seats with full harness systems becoming available for children weighing more than 48 lbs. However, the LATCH bars/attachments in cars and on safety seats are not certified above 48 lbs in most cases. Lockable belts are essential to support this trend. As children tend to weigh more at younger ages, it is necessary for them to have access to seats with harness systems built in for higher weight young children and for active older children who are not prepared to manage a safety belt and booster seat successfully. For booster-users, especially at the youngest ages for which these products are recommended, being able to lock the safety belt is very important to their protection. Otherwise, they often misplace the shoulder belt or allow slack to creep into their belts. This is particularly important for those children who have been buckled up snugly until they move into the booster and aren't used to managing a harness that loosens. Although LATCH is a useful tool as well, many parents prefer to use the belt system to take advantage of the combination of lap-shoulder belt which can reduce forward movement and is designed to handle much heavier persons than children in safety seats. From my personal perspective and on behalf of SafetyBeltSafe U.S.A., I share our appreciation that the National Highway Traffic Safety Administration is prepared to lift the sunset on mandatory lockable belts in locations with LATCH bars.

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