Response from Transport Canada

snowbird25ca

Moderator - CPST Instructor
I can't find my previous post where I said I'd emailed TRansport Canada asking them some questions about the interim order...

Anyways, I got a response from them today. Some of which we've since found out, but some of it is new information and overall a step in the right direction.

Here's my original email:

comments: Regarding this notice:

http://canadagazette.gc.ca/partI/2007/20070505/html/notice-e.html#i13

I have a few questions about the change in regulations that I hope you'll be able to help me with.

1) The effective date is May 1 07 until April 30 08, does this mean that the lower weight limit may return as of april 30 next year, or is this more of a temporary order until a permanent change can be made?

2) The FMVSS 213 is talked about. This is the United States certification on american car seats, so will this change whether or not an individual is able to purchase a seat from the US for their own personal use provided they use the top tether? Most seats sold in the US now come with a top tether.

3) Will the change in regulations make it easier for car seat manufacturers to certify their seats to Canadian standards? Or does this order make the CMVSS 213 and FMVSS 213 standards more in line with each other?

(edited some comments out that aren't really needed to get the gist of the email...lol)

~~~~~~~~~~~~~~~~~~~~~

I also have a question about maximum rear-facing heights and weights. All convertible car seats that I've looked at in stores recently have had a maximum rear facing weight of 30 lbs, despite some of them having 33lb and 35lbs limits in the US. Is there a reason for why our seats are only labelled for 30lbs when the same model in the US is labelled for a higher weight?

Also, the maximum height for rear-facing I have seen on any convertible is 32", with the exception of Evenflo who gives a 1" of shell above the head rule. Identical models sold in the US have varying height limits which also puzzles me. Specifically, Cosco convertible seats being manufactured and sold in the US are now being labelled with a 34" height minimum in order to be used as a forward facing child restraint, yet the same restraint in Canada is being labelled as a 32" maximum for rear facing and doesn't have the same minimum applied to it.

Is there a reason for this standard labelling amongst all convertibles? Given the proven safety of keeping a child rear-facing as long as possible, maintaining labelling of 32" when a seat can safely provide another few inches of torso height, can greatly shorten the length of time a child can remain rear-facing and still be following manufacturers guidelines.

~~~~~~~~~~~~~~~~~~~~~~~~

Thank you in advance for taking the time to answer my questions and address my concerns. I am very passionate about child safety and felt it best to get these questions answered by the experts. Depending upon some of the information I receive, I may also contact Recaro again, so your information will be of great help to me.

Sincerely,

And their reply:

Good afternoon. Your web mail of May 20th, 2007, regarding car seat regulations has been forwarded to this office for reply.

Under the Motor Vehicle Safety Act, Transport Canada develops regulations for the safety performance of vehicles, tires and other vehicle products, including booster cushions and child restraint systems. The applicable regulations for restraint systems can be found on Transport Canada's website at the following address:
www.tc.gc.ca/acts-regulations/GENERAL/M/mvsa/regulations/rssr/rssr.htm

An Interim Order was recently published which temporarily modifies the regulations pertaining to child restraint systems in Canada. Canada's regulations currently specify that forward-facing child restraints must be used for children weighing between 20 and 48 pounds. During the interim period, Transport Canada expects to publish final amendments to its regulations in order to continue to allow child restraint systems for children with a weight up to 30 kg (65 pounds). However, Transport Canada continues to recommend that, once a child has outgrown a child restraint system, parents should seat them using a booster cushion and restrain them with the vehicle's seat belt assembly.

Note that the reference to our U.S. countepart's FMVSS 213 is simply being made to adopt some of the technical testing procedures and does not include all of its safety provisions. This was done to align with many of the requirements from the U.S. This will make it easier for child restraint manufacturers to certify to the Canadian requirements. That being said, it is still important that you continue to purchase child restraint systems, which have been certified to the Canada standards and to which a National Safety Marks has been affixed.

As for your concerns with the rear-facing applications of child restraint systems, manufacturers are at liberty of providing the weight and height limits for their products. However, they must certify to those limits in accordance with the federal regulations. We recommend you contact the restraint system manufacturers for more information on their allowable weight limits.

We hope this information has been of assistance.

Regulations Officer / Agent de règlements
Road Safety and Motor Vehicle Regulation / Sécurité routière et réglementation automobile
Transport Canada / Transports Canada
MotorVehicleStandardsResearch@tc.gc.ca

So that explains all the reference to FMVSS 213 in the interim order - and I'm happy to hear they're trying to make it easier for restraint manufacturers to know how to certify their seats to Canadian standards.

I also found it interesting that there is no official limit on rf'ing seats. Apparently manufacturers are able to set them independently as long as they meet Canadian standards. So I wonder why some of the seats with higher rf'ing limits were reduced to 30lbs?
 
ADS

snowbird25ca

Moderator - CPST Instructor
Someone at RC decided it would "level the playing field" if all seats had to meet the same limit - and then chose the lowest limit around.

Who's RC? Or do you mean TC for Transport Canada? ;)

According to this letter here there is no restriction in effect from them - as long as manufacturers comply with Canadian standards and certify their seats, they're able to label to what weight they want. So from this letter it looks to me like it's the manufacturers themselves?

Maybe they had the limit at one time, then it was removed and the manufacturers have just never bothered to increase the limits again?
 

CDNTech

Senior Community Member
Maybe they had the limit at one time, then it was removed and the manufacturers have just never bothered to increase the limits again?

From what I have been told, they did have the limit at one time... it was lifted within two years but manufacturers never upped their weight limits again. Most likely did not want to go through the expense of raising them again and then having to decrease them if TC once again changed their minds.
 

cantech

New member
Sorry, the cynic in me had to respond to this thread...

I wouldn't be surprised to hear that the manufacturers haven't raised the rearfacing weight limits for existing seats because it would result in a cost increase! :rolleyes: They would have to retest and re certify to the higher weight and they already meet Canadian standards with the lower weights so why change it? Will they sell more seats? Not enough to justify the cost!

Strictly my opinion here!

Belinda
 

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