For a few months now, the parenting world has been abuzz with confusion over these new LATCH limits. We at CarseatBlog have been trying to explain things in clear language so people don’t have to read through volumes of government documents to understand it all. Our recent post, New Federal Regulations Regarding LATCH Weight Limits – What Parents Need to Know gives a general summary of what most people need to know.
But what about those of you who want to know more? The nitty-gritty behind the why’s of the whole thing, and the small changes that have occurred since the time the new amendment was first proposed? That’s where this post comes in.
Changes to Labeling
First, let’s talk about a couple small changes.
Initially the new rule stated that after February 27, 2014, car seats would have to come with a label stating, “Do not use the lower anchors of the child restraint anchorage system (LATCH system) to attach this child restraint when restraining a child weighing more than “*.” The asterisk would be a child weight that, when combined with the weight of the car seat, would not be greater than 65 lbs. For example, if a seat weighs 20 lbs, the label would say, “Do not use the lower anchors of the child restraint anchorage system (LATCH system) to attach this child restraint when restraining a child weighing more than 45 lbs.”
But some people raised concerns that the wording was unclear and might cause people to think they had to discontinue harness use at that weight, rather than simply switch to a seatbelt installation.
NHTSA listened to those concerns and has created a new solution that will be required starting February 27, 2015, or can be implemented sooner for manufacturers who want to. That solution is a diagram that is supposed to eliminate confusion.
The idea is that the drawing shows lower anchors, and therefore makes it clear that it’s the lower anchors that are supposed to be discontinued at a certain weight (implying that it’s fine to keep using the seatbelt).
I applaud their effort, but I’m not sure the diagram will eliminate confusion, and I suspect it might even increase it. Yes, it says “lower anchors,” but a lot of parents don’t really understand what that means (as opposed to a top tether, or as opposed to a seatbelt which does, after all, anchor in the child seat). I think it’s very likely that people will look at the diagram, see webbing (of some sort) and assume that it’s no longer safe to install with LATCH or the seatbelt or top tethers. A better illustration might have been a drawing of a LATCH connector itself, but it’s probably too late now. Hopefully the new labeling won’t cause too much confusion.
Rounding the Weight
The second change in the final ruling about LATCH limit labeling is that manufacturers will have the option of rounding the maximum forward-facing child weight up to the next 5 lbs. The idea behind this was to make the numbers “cleaner.” For example, instead of saying that LATCH should be discontinued at 42 lbs, the label could state 45 lbs.
NHTSA did concede that in some cases, this could make the total weight of the child plus seat exceed 65 lbs. Say a seat weighs 37 lbs. 65 minus 37 is 28 lbs, but to keep things simple, the manufacturer could state a child weight of 30 lbs. That means that the actual total weight would be 67 lbs (and feasibly a combination could get as high as 69 lbs.) but NHTSA believes anchors will be strong enough to allow for that slight variation.
It is important to note that the rules are slightly different (and slightly more confusing) for rear-facing. NHTSA is ok with allowing the total forward-facing weight to go a bit over 65 lbs because the top tether helps reduce some of the force on the lower anchors. Rear-facing, though, the lower anchors take all the force. In that situation, NHTSA doesn’t want the LATCH weight to exceed 65 lbs at all. So if manufacturers want to round the weights to nice numbers they can, but they need to assume a 60-lb total when they do. That ensures that the total weight will not be more than 65 lbs, even if they round up.
Let’s take the Graco Smart Seat as an example. It weighs just under 34 lbs. That means the total child weight would be 31 lbs. (65-34=31) Graco has two choices for listing the forward-facing LATCH limit. They can put 31, or they can round up to 35, which puts the actual limit at 69, but that’s still considered compliant. (Graco can also put a lower number if they’d like.) For rear-facing, they can use the actual 31-lb weight or a lower number, but they cannot round up since the total rear-facing LATCH weight must not exceed 65 lbs.
That means that a seat could have different LATCH limits rear-facing and forward-facing. (In cases where the weight limit is different, manufacturers will either have to take the lower of the two weights and include one limit and diagram, or they can provide two separate ones. In the situation above, Graco could choose to list a 30-lb weight limit regardless of which direction the seat faces.)
Background behind the Decisions
So what logic is behind this madness? Believe it or not, it actually makes some sense.