Karen Ahmad - Comments

Document ID: NHTSA-2009-0108-0010
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: August 31 2009, at 11:23 AM Eastern Daylight Time
Date Posted: September 2 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: July 1 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: August 31 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a19806
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This is comment on Rule

Vehicle Safety Rulemaking and Research Priority Plan (2009-2011)

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Please Consider: 1. Whether or not computer modeling might be a beneficial adjunct in helping to establish child restraint to vehicle fit. 2. Please consider establishing a rule to require child restraints to have "lock-offs" for both forward facing and rear facing installation. This rulemaking would allow the FMVS (Lockability) Standard to be phased out without impacting the safety of children traveling in child restraints. For a variety of reasons many child restraints must be installed with seat belts. A child restraint that can not be properly secured places a child at risk. On the other hand....unused seatbelts with switchable retractors are a risk to children traveling in child restraint systems secured with LATCH as these unused belts pose an entanglement risk. This entanglement risk is very likely grossly underestimated.