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 How to Deal With FMVSS 213 LATCH Use Changes?
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Good news—the answer is simpler than you might think!

  Over the past couple of years, we’ve run several articles in SRN—some rather long and complicated—that discuss recent industry changes affecting LATCH weight limits.  So, as February 27, 2014, nears—the effective date for changes to FMVSS 213 that prompted some of this discussion—the message I’d like to convey in this editorial may seem surprising:  That date will not mark a significant change in how we educate caregivers about using CRs.

  By saying this, I don’t mean to downplay or oversimplify the situation.  My point is that the arrival of February 2014 will not change how we determine the maximum child weight for using LATCH.  As always, we must continue to determine the LATCH weight limit requirements of both the vehicle and CR manufacturers; for the CR that means we check and follow CR instructions.  Yes, CRs will have new information on labels and in instruction booklets by or before February 2014, but for us it’ll be business as usual:  Follow the instructions for the particular CR unit being used.

  But, you may ask, what about all that math we’ve been hearing about?  What about needing to know the weight of the CR?  And subtracting that from 65 pounds?  Sure, that’s how the new regulation will require the CR’s child-weight limit to be calculated, but remember: FMVSS 213 addresses the CR manufacturers.  Therefore, it’s the manufacturers who will have to do the weighing, do the math, and provide clear labels and instructions that state the maximum child weight for using the lower attachment system. (NOTE:  This will not change instructions regarding tethering!)


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  For us, this situation is just another reminder of how important it is to read the instructions.  In fact, keep your eyes open, as some new labels are already among us, having been added ahead of the deadline.  And, since the changes are not retroactive, don’t worry about applying these weight limit changes to CRs made prior to the new labeling.  Regardless of the date, just read and follow instructions.

  If it is so simple, what’s all the fuss been about?  Well, as noted above, we must know not only the CR lower LATCH limit, but also the vehicle manufacturer anchor limit. Back in 2012, when NHTSA mandated the changes currently being phased in for CRs, many of the vehicle manufacturers also began changing their anchor weight limits.  Making sense of these two different changes has caused some of the confusion.

  For many vehicle brands (31, as of 2014), the lower-anchor weight limits have changed to follow the same formula that NHTSA will soon require for using LATCH to install CRs (child weight limit = 65 pounds minus CR weight).  Since the vehicle manufacturer doesn’t know the weight of the CR being installed, the anchor weight limit is stated as the formula above rather than a child weight, leaving it up to the caregiver or CPST to find out the CR weight and do the math.  Unlike the CR LATCH weight limit changes, these vehicle changes were not mandated by NHTSA standards.  In most cases, therefore, updated vehicle LATCH limits went into effect when announced (over a year ago in most cases), and the vehicle manufacturers do consider them to be retroactive.

  As we’ve expressed often in this newsletter, there are pros and cons to the LATCH changes we are experiencing, but we are hopeful the path will ultimately lead us to LATCH’s full potential. Surely this will someday mean a system with only one definitive source of LATCH weight limit information.   Until then, we sincerely hope you will use the 2013 LATCH Manual as a helpful guide for using LATCH safely and properly.  In particular, find manufacturer-provided information about CRs in Appendix A (including convertible and combination CR model weights) and about vehicles in Appendix B.
©Safe Ride News November/December 2013

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