I was recently asked whether our SRN Fact Sheets were updated to reflect the recent changes to FMVSS 213. While I assured the customer that we had reviewed all sheets and made any edits needed, I also noted that the changes were minor. Our fact sheets are meant to provide caregivers with easy-to-read information about best practice, so technical details about subjects like regulations are not appropriate and would in fact detract from the key safety messages.
However, this hints at broader questions that others might share: What do caregivers need to know about the recent update to LATCH weight limits and CR labeling? And, exactly how should our parent information be changed so it’s current?
You might be surprised to know that our opinion on both of these questions is “not a whole lot.” Yes, SRN has run at least a half dozen articles over the past two years that attempt to clarify the many complexities of the LATCH weight limit issue. However, our newsletter is meant to inform CPSTs, instructors, and other advocates—professionals who can be even more productive if they understand the backdrop of our industry. For parents, however, the main thing to be aware of is that 1) lower anchor weight limits exist, 2) the owner’s manuals are where to look for this information, and 3) they should seek help from the manufacturer and/or a CPST if they have questions.
Many reports in the media (and some even on CR manufacturers’ websites) imply otherwise. For instance, I have often read or heard misleading messages that say the changes will now require caregivers to weigh their CRs. This misinformation stems from the fact that the weight of the CR is an aspect of the new regulation. But it is CR manufacturers, not parents, that are required to weigh CRs in order to indicate a maximum child weight for LATCH use. They must assure the combined child-plus-CR weight does not exceed 65 pounds. So the new labeling requirement simplifies LATCH use, allowing us to look only at the CR instructions (booklet and labels) for a clearly stated maximum child weight. As was always the case, for models made before compliance, we (CPSTs and caregivers alike) must look at instructions from both the CR and vehicle makers (and CPSTs can also look to the SRN LATCH Manual). Still, in those cases, it would depend on the vehicle being used as to whether the stated vehicle limit would require weighing the CR.
Therefore, when reviewing or creating CPS materials meant to guide the public on the use of CRs for older children (flyers, brochures, PSAs, classroom curricula, etc.), the information should state that use of a CR’s lower attachments might be limited to a maximum child weight, and to look in the owner’s manuals for that limit.
To describe the limit further is simply too specific for materials meant for the general public. Consider:
LATCH use is not limited on all CRs. Many (including all RF-only CRs, many convertibles and combinations, and applicable boosters) can be installed with the lower attachments at all usage weights.
When a limit does come into play, owners of newer CRs can simply check the CR instructions for that child weight limit.
For older CRs that predate the revised standard, the information must be found by checking/comparing both the CR and vehicle information. Still, only owners of certain vehicle brands would discover that weighing the CR is required.
Note especially that what we’re recommending for CPS materials never involves explaining that the weight limit must now reflect a combined weight (CR plus child) or what that limit is (65 pounds). Being unaware of the basis for a limit (whether it’s one stated before or after the new regulation) will not lead caregivers to endanger children. So why complicate our public safety messages with this level of detail? Caregivers simply need to know that use of LATCH may be limited at a certain child weight, so they should look for and heed this information in CR instructions. They should also know to install using the seat belt (and tether, as appropriate) when the CR can continue to be used at higher child weights.
So, I’d say this is a good time to apply the K.I.S. approach—keep it simple! Of course, when asked, a CPST speaking one-on-one with a caregiver can always provide more detail, as he or she deems prudent.
©Safe Ride News May/June 2014