Smart Kid Belt

Some thoughts on the "Smart Kid Belt"

Author: Andrew Aylett

Version: 1.0Status: liveLast Revised: 2020/09/05Expires: 2025/09/05

Research notes on the Smart Kid Belt, a controversial child restraint that is just a strap holding the seatbelt down. Despite Polish type approval, multiple countries have called for its withdrawal as it falls outside UN Regulation No. 44. ^?

https://smartkidbelt.com/en/
A child restraint that’s just a strap to hold the shoulder belt down.
Does actually have a type approval: E20 44R-04 4013, linked from their website: https://smartkidbelt.com/img/cms/smart-kid-belt-swiadectwo-homologacji-ece.pdf
Harmonised by [[UNECE]].
The Russians — in WP.29 session 181 — are unconvinced:
- https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29/ECE-TRANS-WP29-1153e.pdf
- https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29/WP29-181-09e.pdf
  - “cannot be considered as a child restraint system”
  - “The mentioned certificate had been cancelled”
    - [[GRSP]] session 66 report: https://www.unece.org/fileadmin/DAM/trans/doc/2019/wp29grsp/ECE-TRANS-WP.29-GRSP-66e.pdf
    1. The expert from EC introduced ECE/TRANS/WP.29/GRSP/2019/28 aimed at clarifying the types of belt-guides and sitting devices that would not be allowed by means of an explanation in the scope of the UN Regulation. The expert from Poland argued that the proposal from EC was restrictive and requested a facts-based discussion on this proposal or a simple rejection in full. He introduced a presentation GRSP-66-19,showing that one of the devices in ECE/TRANS/WP.29/GRSP/2019/28 was fully compliant with UN Regulation No. 44 and safer compared to other type approved CRS. The expert from Spain introduced GRSP-66-30 which provided counter evidence that belt-guide devices would not comply to a number of relevant requirements of UN Regulation No. 44. The expert from Japan introduced a presentation (GRSP-66-38) showing the sled test conducted on Q dummies to check safety-belt penetration according to UN Regulation No 129 requirements. He concluded that the abdominal pressure on the belt-guide device was found to be rather high compared to CRS type approval according to UN Regulation No. 129, but that it satisfied the requirements of the UNRegulation.
    2. Finally, the majority of GRSP experts, with the exception of the expert from Poland, adopted ECE /TRANS/WP.29/GRSP/2019/28, not amended. The secretariat was requested to submit the proposal as part of (see para. 26)Supplement 18 to the 04 series of amendments to UN Regulation No. 44, for consideration and vote at the June 2020sessions of WP.29 and AC.1.
The Dutch — in the Working Party on Passive Safety ([[GRSP]]) also unconvinced, entering documents into the 67th session:
- https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29grsp/GRSP-67-05e.pdf
- While the Poles say it’s OK:
  - https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29grsp/GRSP-67-32e.pdf
- Report of the session:
  - https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29grsp/ECE-TRANS-WP.29-GRSP-67e.pdf
  1. The expert from Poland requested deferral of discussion on the belt-guide, that was type approved by the authority of her country, to the December 2020 session of GRSP due to the research test results on the belt-guide, which had not yet been made available by the expert of EC. The experts from the Netherlands and ANEC/CI argued that discussion was needed on this subject since they considered this type of CRS as dangerous. The expert from the Netherlands introduced GRSP-67-05 explaining that the belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn. “Finally, with reference to the procedure of the 1958 Agreement, Revision 3,Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement.” The expert from ANEC/CI, introduced GRSP-67-10 and GRSP-67-36 showing the high risk of abdominal injuries in both cases due to severe submarining. In anticipation of the above-mentioned test results, the expert from Poland introduced GRSP-67-32, showing some results of tests demonstrating the performance of this belt-guide type under laboratory conditions. She also clarified that the belt-guide was type approved according to Supplement 10 to the 04 series of amendments. However, she added that according to some stakeholder opinions,this belt-guide type should had been tested according to Supplement 11, thus making the device subject to different criteria. However, she stated that in her opinion there was a clear legal basis which demonstrated that the type approval granted under Supplement 10 was the correct one. The expert of the Netherlands responded by stating that, apart from the fact that this device does not comply with several requirements of UN Regulation No. 44, a supplement only clarifies existing requirements or test procedures and does not introduce new requirements. Even when Supplement 10 was in force, it was evident that a belt guide could not be approved as a child restraint.
  2. The expert from EC recalled to GRSP, that the group had agreed to his former proposal (ECE /TRANS/WP.29/GRSP/2019/28) to amend the scope of UN Regulation No 44 (Child Restraint Systems) with clarification that a belt-guide cannot be approved under Regulation 44 without being part of a child restraint system (see ECE/TRANS/WP.29/GRSP/66, paragraphs 27 and 28). However, he explained that EC had reconsidered the document submission to WP.29, since the interpretation that a “guide strap”and similar devices cannot be separately approved as a child restraint system, had already been endorsed by WP.29 at its March 2012 session (see ECE/TRANS/WP.29/1095, paragraph 35). Therefore, he introduced GRSP-67-31, that was only on the phase out of UNRegulation No. 44.
  3. The Chair of GRSP referred to Schedule 6 of the 1958 Agreement, and stressed full consideration of the different opinions of the Type Approval Authorities of the concerned contracting parties, and of contracting parties applying UN Regulation No. 44. “Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement.” The experts also noted that the Chair encouraged the expert of the Netherlands to continue discussions with the Type Approval Authority of Poland to seek cooperation with Poland in the aim to avoid the arbitration process according to Schedule 6 of the 1958 Agreement, which would start in the November 2020 session of WP.29.
I’m pretty sure the important paragraph is this one:
- “Finally, with reference to the procedure of the 1958 Agreement, Revision 3,Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement.”
- So the type certification remains while the Poles object, until and unless arbitration concludes. But:
  - “Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement.”
- I am, therefore, not minded to use the device.
#Product #Safety

https://smartkidbelt.com/en/
A child restraint that’s just a strap to hold the shoulder belt down.
Does actually have a type approval: E20 44R-04 4013, linked from their website: https://smartkidbelt.com/img/cms/smart-kid-belt-swiadectwo-homologacji-ece.pdf
Harmonised by [[UNECE]].
The Russians — in WP.29 session 181 — are unconvinced:
- https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29/ECE-TRANS-WP29-1153e.pdf
- https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29/WP29-181-09e.pdf
  - “cannot be considered as a child restraint system”
  - “The mentioned certificate had been cancelled”
    - [[GRSP]] session 66 report: https://www.unece.org/fileadmin/DAM/trans/doc/2019/wp29grsp/ECE-TRANS-WP.29-GRSP-66e.pdf
    1. The expert from EC introduced ECE/TRANS/WP.29/GRSP/2019/28 aimed at clarifying the types of belt-guides and sitting devices that would not be allowed by means of an explanation in the scope of the UN Regulation. The expert from Poland argued that the proposal from EC was restrictive and requested a facts-based discussion on this proposal or a simple rejection in full. He introduced a presentation GRSP-66-19,showing that one of the devices in ECE/TRANS/WP.29/GRSP/2019/28 was fully compliant with UN Regulation No. 44 and safer compared to other type approved CRS. The expert from Spain introduced GRSP-66-30 which provided counter evidence that belt-guide devices would not comply to a number of relevant requirements of UN Regulation No. 44. The expert from Japan introduced a presentation (GRSP-66-38) showing the sled test conducted on Q dummies to check safety-belt penetration according to UN Regulation No 129 requirements. He concluded that the abdominal pressure on the belt-guide device was found to be rather high compared to CRS type approval according to UN Regulation No. 129, but that it satisfied the requirements of the UNRegulation.
    2. Finally, the majority of GRSP experts, with the exception of the expert from Poland, adopted ECE /TRANS/WP.29/GRSP/2019/28, not amended. The secretariat was requested to submit the proposal as part of (see para. 26)Supplement 18 to the 04 series of amendments to UN Regulation No. 44, for consideration and vote at the June 2020sessions of WP.29 and AC.1.
The Dutch — in the Working Party on Passive Safety ([[GRSP]]) also unconvinced, entering documents into the 67th session:
- https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29grsp/GRSP-67-05e.pdf
- While the Poles say it’s OK:
  - https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29grsp/GRSP-67-32e.pdf
- Report of the session:
  - https://www.unece.org/fileadmin/DAM/trans/doc/2020/wp29grsp/ECE-TRANS-WP.29-GRSP-67e.pdf
  1. The expert from Poland requested deferral of discussion on the belt-guide, that was type approved by the authority of her country, to the December 2020 session of GRSP due to the research test results on the belt-guide, which had not yet been made available by the expert of EC. The experts from the Netherlands and ANEC/CI argued that discussion was needed on this subject since they considered this type of CRS as dangerous. The expert from the Netherlands introduced GRSP-67-05 explaining that the belt-guide was not in the scope of the UN Regulation and could not be type approved; as such, the type approval should be withdrawn. “Finally, with reference to the procedure of the 1958 Agreement, Revision 3,Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement.” The expert from ANEC/CI, introduced GRSP-67-10 and GRSP-67-36 showing the high risk of abdominal injuries in both cases due to severe submarining. In anticipation of the above-mentioned test results, the expert from Poland introduced GRSP-67-32, showing some results of tests demonstrating the performance of this belt-guide type under laboratory conditions. She also clarified that the belt-guide was type approved according to Supplement 10 to the 04 series of amendments. However, she added that according to some stakeholder opinions,this belt-guide type should had been tested according to Supplement 11, thus making the device subject to different criteria. However, she stated that in her opinion there was a clear legal basis which demonstrated that the type approval granted under Supplement 10 was the correct one. The expert of the Netherlands responded by stating that, apart from the fact that this device does not comply with several requirements of UN Regulation No. 44, a supplement only clarifies existing requirements or test procedures and does not introduce new requirements. Even when Supplement 10 was in force, it was evident that a belt guide could not be approved as a child restraint.
  2. The expert from EC recalled to GRSP, that the group had agreed to his former proposal (ECE /TRANS/WP.29/GRSP/2019/28) to amend the scope of UN Regulation No 44 (Child Restraint Systems) with clarification that a belt-guide cannot be approved under Regulation 44 without being part of a child restraint system (see ECE/TRANS/WP.29/GRSP/66, paragraphs 27 and 28). However, he explained that EC had reconsidered the document submission to WP.29, since the interpretation that a “guide strap”and similar devices cannot be separately approved as a child restraint system, had already been endorsed by WP.29 at its March 2012 session (see ECE/TRANS/WP.29/1095, paragraph 35). Therefore, he introduced GRSP-67-31, that was only on the phase out of UNRegulation No. 44.
  3. The Chair of GRSP referred to Schedule 6 of the 1958 Agreement, and stressed full consideration of the different opinions of the Type Approval Authorities of the concerned contracting parties, and of contracting parties applying UN Regulation No. 44. “Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement.” The experts also noted that the Chair encouraged the expert of the Netherlands to continue discussions with the Type Approval Authority of Poland to seek cooperation with Poland in the aim to avoid the arbitration process according to Schedule 6 of the 1958 Agreement, which would start in the November 2020 session of WP.29.
I’m pretty sure the important paragraph is this one:
- “Finally, with reference to the procedure of the 1958 Agreement, Revision 3,Articles 4.2., 10.4 and Schedule 6 (paragraphs 2 and 3), he stated that through GRSP-67-05 he sought support from other contracting parties and cooperation from the expert of Poland to avoid starting the arbitration process – according to Schedule 6 of the 1958 Agreement.”
- So the type certification remains while the Poles object, until and unless arbitration concludes. But:
  - “Therefore, the experts from France, Germany, Italy, Russian Federation, Spain, Switzerland and United Kingdom explicitly endorsed the request of the expert from the Netherlands to withdraw the type approval granted by Poland on the belt-guide, while none of the other present delegates indicated abstention or disagreement.”
- I am, therefore, not minded to use the device.
#Product #Safety