Please, comment on the federal register!

Ok, got this email today. Not sure if this has been discussed, but please, take the time to go sign.

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I recently visited the Federal Register to see if there were any additional comments on the Notice of Proposed Rulemaking to delete the sunset clause for manually lockable belts in locations with lower anchors for the LATCH system. I was pleased to see comments from folks in NY, VT, IL, CA, AZ, WA but I know there are those with interest in and knowledge about child passenger safety in every state. It would be wonderful to have comments on this from every section of the country, perhaps every state. It doesn't take long to do it, but the deadline is fast approaching: November 12.

Please consider visiting www.carseat. org, click on laws/regulations, and then on the link to the Federal Register. If you have any questions about the issue, we are happy to respond.
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This is what I wrote, basic, but that is what I am!

If this happens, it will be a step down in safety for our children. At 40-48 lbs, latch can no longer be used. So a locking clip would then have to be used for all higher weigh harness car seats.

On carseat.org

"Lockability. NHTSA has issued a Notice of Proposed Rulemaking to remove the sunset clause that would rescind the lockability requirement for safety belts in 2012. A petition requesting this action was submitted by SafetyBeltSafe U.S.A. and Safe Ride News and supported by 177 CPS advocates, many of whom were attendees of Kidz in Motion Conference 2006.

Thanks to everyone who supported this important petition. The next step is to send comments online or by fax (202-493-2251) by November 12, 2008.

To comment online at regulations.gov, enter the Docket Number NHTSA-2008-0149 in the search window, check the “Select” box below the window, and click on “Go.” When the next window appears, click on “Send a comment or submission.” Enter your contact information, Government Agency Type (Federal), Government Agency (National Highway Traffic Safety Administration). In the General Comments box, describe why you believe lockable belts are needed. For example: (1) to secure safety seats for children above 48 lbs., especially children who are large for their age or have special needs (2 for children in boosters who are not able to stay properly seated and/or keep the shoulder belt properly positioned; (3) to enable caregivers to lock unused belts, which some children have wrapped around their necks, coming close to strangulation. "

I tried to comment last night... I can't figure out how to do it! how bad is that... Do you select the "comment" button on someone elses comment??? And it wouldn't let me "send" it... it was weird...

Safe Ride News had a reminder about this in their latest issue. I meant to post here about it, but forgot. I also forgot to comment myself. So thanks for the reminder! :thumbsup:

Ok, wish I could do screen shot, but instead we get cut and paste. When you put in the docket number, this will come up. click up send comment or submission.


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Federal Motor Vehicle Safety Standards; Occupant Crash Protection
Send a Comment or Submission | Notification

...2008 (Volume 73, Number 178)] [Proposed Rules...CFR Part 571 [Docket No. NHTSA-2008-0149] RIN... …

Agency: NHTSA Document Type: RULES Comments Due: Nov 12, 2008 11:59:59 PM EST
Docket ID: NHTSA-2008-0149 Document ID: NHTSA-2008-0149-0001
Date Posted: Sep 12, 2008
View this Document: |

Bump

Judi , I'm confused.....:dizzy:!

Can you break it down Barney style for me? Must be preggo hormones.

Does it mean that they will be removing ALR or locking latch plates from LATCH seating positions?? That would suck a$*! What would people do that have Regents or other HWH seats have to do them use the seat belt with a locking clip?

Is that what your talking about?

Most people don't understand ALR or locking latch plates NOW! Do you know how many parents think you just click the male end into the female buckle and TA DAH magic it's buckled and safe! The have no clue the have to pre-crash lock a seat!!!

PixieEMT said:

Judi , I'm confused.....:dizzy:!

Can you break it down Barney style for me? Must be preggo hormones.

Does it mean that they will be removing ALR or locking latch plates from LATCH seating positions?? That would suck a$*! What would people do that have Regents or other HWH seats have to do them use the seat belt with a locking clip?

Click to expand...

I went and commented and, yes, the idea was that by the sunset date all car seats would be LATCH style and that the "lockability" requirement for LATCH equipped seating positions would be essentially redundant. Which was OK except now some harnessed seats go (way) over the LATCH limit of 40~48lbs. Making a locking clip required if the belt can't lock somehow.

The ideal solution I think would be to mandate that LATCH be redesigned around a higher weight limit(at least 80 pounds, may be even 100); that would of course would probably take 5-10 years to implement, necessating the current rules to stand.

kdgrayson said:

The ideal solution I think would be to mandate that LATCH be redesigned around a higher weight limit(at least 80 pounds, may be even 100); that would of course would probably take 5-10 years to implement, necessating the current rules to stand.

Click to expand...

Yes, and they are working on it, but they aren't any closer to that than when they started. Really, in would have to go to 150 lbs or so, to cover all seats.

I commented!

Thanks!

Just bumping this back up. The info below taken from the CPS express:


To view the NPRM and submit a comment

Go to http://www.regulations.gov/
In the search box, enter “nhtsa-2008-0149” and click submit.
Look at the first posted comment. You will see two clickable options:
You can read the document by clicking on “View this Document” (directly under date posted).
You can enter a comment by clicking in “Enter a Comment or Submission” (directly under the person’s name).
Submitting a comment
You may copy and paste the submission by Safe Kids Buckle up (below) or write your own.
CAREFUL: Anything you submit will be posted exactly as written.
Comments must be submitted by November 12, 2008.
Comment Submitted by Safe Kids Worldwide
Safe Kids Worldwide agrees with NHTSA and supports any amendment that retains the current lockability standard in vehicles equipped with lower anchors and tethers (LATCH). There are a number of reasons for retaining this standard:

While LATCH is available in many vehicles now and will be available in all vehicles by 2012, many child restraint installations obtain a better, more secure fit using the safety belt instead of the LATCH system. Parents and caregivers are instructed to use whichever system provides the best and most secure child restraint fit in the vehicle. For that reason alone, seat belts that meet the lockability standard may reduce misuse because caregivers will not need an additional tool to properly lock the safety belt with an ELR and sliding latchplate.
There are now more than 20 child restraints available with harnesses to higher weights (50, 65, 80 or more pounds) that accommodate younger, heavier children and children with special health care needs. Current recommendations from manufacturers and child safety organizations urge caregivers to continue harness use to the highest weight allowed by the manufacturer. Because of an incompatibility between lower anchor and tether weight limits and child restraint weight allowances, current instructions call for the discontinuation of LATCH systems in car seats after 40-48 pounds based on individual vehicle manufacturer’s instructions. Caregivers are guided to use the vehicle safety belt with the car seat instead. Without the lockability standard, many safety belts will require use of a locking clip to secure the child restraint properly. Locking clip misuse is historically well documented.
Submitted by Safe Kids Buckle Up

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