Fake CPS products are not limited to counterfeit CRs. The online availability of aftermarket LATCH systems is also a growing problem posing a danger to children. Multiple sellers are offering systems to add to CRs (LA attachment straps with connectors), as well as systems for vehicles (plates with LAs and TAs). When it comes to these aftermarket parts, no extra sleuthing is needed to conclude that they are unsafe: LATCH hardware should only be acquired directly from a vehicle or CR manufacturer.
CPSTs should be on the lookout for these LATCH parts and warn caregivers that they are extremely unsafe. As CPSTs know, parts that do not come with a specific vehicle or CR are always suspect; they do not meet regulations, and their use is never allowed by vehicle or CR manufacturers. Given that these parts are used to anchor a CR, the potential danger from subpar materials, workmanship, and installation techniques is especially great.
Despite these dire safety concerns, the likelihood that CPSTs will see these retrofit LATCH kits in the field is growing. While they are not new, they are being marketed more effectively compared to just three or four years ago. Several are now available on sites like Amazon and Walmart, which may legitimize them in the minds of many consumers (although the fact that the sellers are actually third-party vendors should send major red flags). Availability on mainstream sites also expands their market visibility, making it more likely than ever that caregivers will see them advertised. Since sellers promote them in a misleading but appealing way—saying they are safe, inexpensive, and easy to use—many caregivers are likely to be taken in.
Add-on LA Attachments for CRs
A big challenge of monitoring for aftermarket LA attachment systems sold online is that they may look a lot like systems that come with CRs. However, since they are not governed by regulations, there is no guarantee they are as strong. In fact, it is likely they are made of inferior materials.
One clue that a CR’s LA attachment system may be an aftermarket part is if the full assembly can be easily removed from the CR. FMVSS 213 requires a CR’s legitimate LA attachment system to be affixed to the CR in a way that would require a tool to remove it. So, if this isn’t the case, it’s possible the caregiver did something (like cut an attaching strap), but it could also be a sign of an aftermarket assembly.
If an otherwise usable CR is missing its LATCH parts, it can be installed using a seat belt instead. But, if the owner wants a replacement LATCH system, the system should be acquired directly from the CR manufacturer. (Years ago, some manufacturers sold replacement LATCH systems through retailers, but even those were only for CRs of their own brand. SRN is unaware of any that are sold legitimately that way today.)
Retrofit LATCH systems for vehicles
Retrofit LATCH kits for vehicles tempt caregivers because their advertising deceptively claims that they are an acceptable way to upgrade a pre-LATCH vehicle or add LATCH to additional seating positions of newer vehicles. Each kit includes LA bars and a TA, so caregivers may be motivated by the desire to add either or both types of anchors.
Retrofitting TAs is acceptable only in vehicles made before LATCH was introduced and only if the kit is acquired through the manufacturer. (See Chapter 6 of the LATCH Manual.) In newer passenger vehicles, adding more TAs generally isn’t an option.
When it comes to lower anchors, there is no safe and appropriate way to retrofit any vehicle of any age.* ((Exceptions include a small number of VW and Audi models from the early 2000s, which may be retrofitted only through a dealer (see the LATCH Manual), and FMVSS 210-compliant school bus seating.))
Risks abound with these aftermarket systems. First, there is no regulation governing them and, therefore, no assurance that they meet the strength requirements of a LATCH system.
But, even if the device were made of strong materials, also consider that proper attachment of the hardware to the vehicle is critical to crash performance. There’s simply no way that a do-it-yourself approach can ensure the requisite system strength.
For one thing, add-on kits are generic, but vehicles are definitely not all alike. In fact, though the kits claim to be “universal,” they can only be used as intended on seating that has an ample opening at the bight. Caregiver efforts to force installation of such a system onto other types of seating would introduce further problems.
Also, lacking pre-engineered attachment points, it is very unsafe to attempt installation, even onto the intended type of vehicle seating. The kits being marketed most aggressively sidestep the need to securely weld or bolt in the parts by relying instead on a bracing plate(s) that runs horizontally or vertically behind the vehicle seatback from which the LAs stick out and emerge through the bight (as shown in the image on page 1).
When SRN asked Jennifer Pelky, National CPS Board member and senior engineer at Toyota, about this device and its installation technique, she was shocked. She said that there are many potential issues with this product, but the most troubling is that there is little chance that the brace would engage the correct part of the vehicle or vehicle seat to provide the same level of protection as an original-equipment LATCH system. Added Pelky, “Toyota, of course, warns against the use of any product like this in our vehicles.”
It is especially worrisome that the easy installation method that makes these systems extremely unsafe is the very thing that’s likely to appeal to potential buyers. Also, a CR that’s attached and tightened to the LAs and TA of such a system could properly pass the 1-inch test for tightness, setting up a false sense of security.
Recently, a caregiver in Montana who had purchased one of these LATCH retrofit kits online was fortunate to receive education from CPST-I Tracie Kiesel. Kiesel immediately recognized that the product was unsafe, and, importantly, listened to the caregiver’s reasons for purchasing the device in the first place. It turned out that the mother had resorted to this option after she couldn’t get a tight CR installation in her 1998 SUV using the vehicle’s seat belt. During a thorough checkup, Kiesel came to realize that the caregiver didn’t understand that her car was equipped with switchable retractors and didn’t know how they functioned. She walked the caregiver through the vehicle owner’s manual, demonstrated how to switch the seat belt to locked mode for CR installation, and ensured that the caregiver could follow the steps for a tight installation. Through education, the caregiver was convinced that the aftermarket product was neither safe nor necessary, since she was empowered with the skills to use her vehicle systems properly for her child’s safety.
Like nearly all caregivers, this mother was very committed to doing the right thing for her child, despite having a lot to learn. It is important to note that she had carefully checked the product’s online comments before buying it and was reassured by positive reviews. Although CPSTs understand that these commenters are not safety authorities, it is very common for online shoppers to consider checking comments and reviews to be a valid form of due diligence. Therefore, adding warnings—in a professional, accurate, and compassionate manner—to the comment areas of listings for unsafe products that are spotted online is another important way CPSTs can help protect the public.