• Advisory Circular (AC) No. 605-003 - Transport Canada
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After spending years protecting your children from all sorts of dangers on the road and off, you now face the prospect of handing them the keys to the family car

arise regarding the placement of safety appliances on these car ..

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ensure an adequate level of overall safety and to minimise the risk of the car ..
(2) In accordance with the Canadian Motor Vehicle Restraint Systems Standard and Booster Seats Safety Regulations, restraint systems that are manufactured or sold in Canada must be affixed with the National Safety Mark, which indicates the number of the standard or standards to which the restraint system conforms, namely CMVSS 213 in the case of a child restraint system or 213.1 in the case of an infant restraint system.

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The Federal railroad safety appliance standards encompassed in part 231 serve the purpose of increasing railroad safety by identifying the applicable safety appliance requirements for various individual railcar types. See e.g. , box and other house cars built or placed into service before October 1, 1966. While these regulations continue to serve their purpose, FRA recognizes the railroad industry has evolved over time. The industry has created and continues to create new railcar types to satisfy the demands for transporting freight as well as passengers on the present-day railroad. Many of the modern railcar types that are presently being built to handle railroad traffic do not fit neatly within any of the specific car body types identified in the existing regulations and ambiguities sometimes arise regarding the placement of safety appliances on these car types.


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Because modern designs often cannot be considered a railcar type that is explicitly listed in part 231, they are typically treated as cars of special construction. See . The “cars of special construction” provision does not identify specific guidelines that can be used by the railroad industry to assist it in the construction and maintenance of the safety appliances on modern railcar designs. Instead, § 231.18 directs the industry to use the requirements, as nearly as possible, of the nearest approximate car type. Problems arise because modern designs are often combinations of multiple car types, and the design of any particular car may appear to be one type or another depending on the position of the individual viewing the car. As an example, a bulkhead flat car appears to be a box car when viewed from the A-end or B-end of the car, but appears to be a flat car when viewed from either side. As a result, the industry is forced to use bits and pieces from multiple sections of part 231 in an effort to ensure compliance with the Federal railroad safety appliance standards on bulkhead flatcars and other modern rail equipment.

(1) Paragraph 605.28(1)(c) of the CARs requires that each child restraint system to be used on board the aircraft have a legible label indicating the applicable design standards and date of manufacture. The following sections provide examples of labels indicating that the child restraint system meets the design standards to be acceptable for use on board a Canadian aircraft.

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Another problem for modern railcar designs is that part 231 defines the location of many safety appliances by reference to the side or end of the railcar. While this worked well for the car types that were in existence when the ICC issued its March 13, 1911 order, it often is difficult to define exactly what parts on modern railcars constitute the side or end. This results in ambiguity regarding what is the appropriate location for certain safety appliances, such as handholds and sill steps.

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(4) However, some Canadian child restraint systems cannot be used in aircraft as a result of designs that make them easier to install in motor vehicles. Because their designs make them incompatible with an aircraft seat, these restraint systems will contain a label limiting its use to motor vehicles. Although these restraint systems will have the National Safety Mark, they will also have a label containing the following text: “This Restraint is Certified for Use in Motor Vehicles. This Restraint is Not Certified for Use in Aircraft,” in red lettering. The following is an example of this labelling:

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Moreover, the requirements in part 231 sometimes allow for spatial relationships between safety appliances that can result in the placement of appliances in less than optimal locations to ensure the safety of a person working in and around the railcar. For example, in § 231.21, Tank cars without underframes, the center of the tread of the sill step can be up to 18 inches from the end of the car while the outside edge of the horizontal side handhold over the sill step can be up 12 inches from the end of the car. Consequently, a car built using these requirements may be compliant with the regulation even though the sill step and horizontal handhold are not aligned in a manner that maximizes the safety of a person working in and around the car.

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(5) Canadian Technical Standard Orders (CAN-TSO) C-100b and C-100c contain minimum performance standards for the testing and evaluation of a child restraint system or aviation child safety device intended to provide proper restraint of children in the aircraft environment and that would be suitable for use during all phases of flight. A system or device manufactured in accordance with CAN-TSO must be permanently and legibly marked with at least the manufacturer’s name, subassembly part number, and the CAN-TSO number (e.g. CAN TSO C100b or CAN-TSO-C100c).