Federal Motor Vehicle Safety Standards; Child Restraint Systems; Denial of Petition for Rulemaking

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This document denies a petition for rulemaking from The Booster Seat Company Ltd., Hamilton, New Zealand, requesting that NHTSA amend the structural integrity requirement of its Federal motor vehicle safety standard on child restraint systems so as to allow its product, a belt-positioning booster seat made entirely of polystyrene, to be manufactured and sold in the United States. The petitioner believes polystyrene has ``superior cushioning qualities'' compared to a blow molded plastic, yet acknowledges that the material may fracture or crack in a crash. This potential would make it likely that a polystyrene child seat would fail the structural integrity requirement in a compliance test. NHTSA is denying the petition because the loss of structural integrity of a restraint could negatively affect the performance of the system by allowing injurious forces to be imposed on the child occupant. Further, because damage to polystyrene may not be easily detected, there is a concern that consumers could mistakenly use damaged polystyrene seats, putting the child occupant at risk. Not enough is known about these potential concerns to warrant reducing the system integrity requirement as reque