Five Years Later: How CR Types Are Affected by NHTSA LA Attachment Limits

This article originated in the November/December 2018 issue of Safe Ride News.

In the past couple of years, the introduction of such LA adjusters as Evenflo’s EasyClick and Graco’s EZ Tight is an encouraging sign that NHTSA’s requirements for LA attachment weight limits have not squelched CR manufacturers’ interest in innovating to improve LATCH ease of use.  Now that five years have passed since the regulation went into effect, it is a fitting time to reflect on how the regulation has affected CR types, in general.

As a reminder, the rule, an amendment to FMVSS 213, standardizes two important aspects of LATCH use:

  • It requires a consistent and conservative way to calculate LA attachment limits:  CR manufacturers must derive a child weight limit for use of the LA attachment such that the combined CR-plus-child weight does not exceed 65 pounds.  Manufacturers may opt to round to the nearest number ending in 0 or 5 (although they may only round down when adjusting the LA attachment limit for RF mode).
  • It specifies uniform and easy-to-spot placement for limit information:  If the LA attachment limit is less than the harness use limit, the LA attachment limit must be stated in a place located near the belt path diagram on the CR label and expressed as a maximum child weight.  (No math involved!)

Because the formula for calculating the limit is sufficiently conservative for any CR/vehicle situation, it’s no longer necessary to find and compare CR limits with vehicle LA limits, a task that caused much confusion in the years before the standard was amended. Note, however, that some CRs are not required to state a limit for LA attachment use.  For these, permission to use the LA attachment for installation at all allowed usage weights is implicit, but typically not stated.  For instance:

  • Boosters with an LA attachment are exempt from the requirement.
  • Even among models of CR types that aren’t exempt, some don’t exceed 65 pounds when the CR weight is combined with the maximum harness use weight.

In these cases, the CR user must understand that, while the CR does meet all standards, there is no requirement for an LA attachment weight limit to be stated on the label nor mentioned in instructions. (Also important to note:  Standardized weight limits are imposed only on LA attachment use, never tether use.)

To make it easier to remember when to check LA attachment weight limits, it may help to consider how these limits have applied to the various CR types, as follows:

RF-only CRs

Despite the fact that many rear-facing-only CRs allow use by children up to fairly high weights (as much as 40 pounds), none of these models, whether made before or after the 2014 amendment to FMVSS 213, has a limit for LA attachment use.  For all RF-only models, the weight of the CR plus the harness use weight is less than 65 pounds. Therefore, all RF-only models maybe be installed using the LA attachment at all allowed usage weights.  (Of course, it is prudent to always check new models, especially heavy and/or high-usage-weight CRs.  However, since consumers value lightweight RF-only designs, it is very unlikely that one with an LA attachment limit will ever be introduced.)

Convertible and all-in-1 CRs used RF

When installing a convertible or all-in-1 model made since February 2014, it is always important to check for limits for both FF and RF modes.  Since the current rule went into effect, there have been more than 20 convertible and all-in-1 models from nearly a dozen manufacturers that have NHTSA-mandated labels stating a weight limit for use of the LA attachment in rear-facing mode.  For these models, a seat belt must be used for rear-facing installation at a specified child weight that is lower than the maximum RF usage weight.  When an LA attachment limit is stated for RF mode, it is usually different (and lower) than the limit for FF mode.

CRs used FF with FF harness-use limits of 40 to 50 pounds

With very few exceptions, CRs currently on the market that may be used forward facing by children who weigh 50 pounds or less may be installed using the LA attachment at all usage weights.  This means that nearly all CRs with a 40- or 50-pound usage maximum are lightweight enough that the usage maximum plus the CR weight is less than 65 pounds. Despite the lack of a NHTSA-mandated label on these models, if the CR was made since February 2014, the implied LA attachment limit is the same as the harness-use limit; like models with labels, there is no requirement to also consider the vehicle LA limit.

CRs used FF with FF harness-use limits over 50 pounds

There are roughly 100 CR models for sale in the U.S. with harness use limits of 65 to 90 pounds, and all have a label limiting the use of the LA attachment to a child weight of 65 pounds minus the CR’s weight (typically resulting in a child weight maximum of 40 to 50 pounds).  Among models that have been on the market since before 2014, many limits set to comply with the current regulation are slightly lower than what was stated in instructions before the FMVSS 213 amendment took effect, but several models have limits that are either the same or slightly higher.  Overall, other than for a few model outliers, limit changes caused by the revised regulation are minor.  (Remember:  Because the regulated limits are not applied retroactively, follow whatever LA attachment instructions are provided for the particular CR in use.)

When children who are heavier than the LA attachment limit continue to use these CRs, caregivers should be reminded that the LA attachment limit does not apply to the tether, which can also be used when the CR is installed using a seat belt.

Belt-positioning boosters (BPBs)

When LA attachment use is allowed for combination CRs in BPB mode, or when dedicated BPBs include an LA attachment, the LA attachment may be used at any approved child usage weight.  For BPBs, the seat belt absorbs the major crash forces, and a minimal amount of force is applied to LAs.  Therefore, LATCH weight limits don’t apply to BPBs.