California: Must I Connect to the Parking Brake?
We have discussed this at length with the California Highway Patrol (CHP). The following information represents our best understanding of CHP's intent. To be clear, CCM does not represent CHP nor is CCM able to provide legal or regulatory advice. This article must be read in full for complete context. If you have additional questions, CCM recommends contacting your local CHP representative.
Questions CCM Posed to CHP
- CCM asked CHP if Child Check systems in California (as set forth in Title 13) are required to connect to the parking brake or monitor the state of the parking brake.
- CHP stated that the specification does not explicitly require that the electronic systems connect to the parking brake or monitor the state of the parking brake.
- CCM asked CHP if a driver may deactivate a Child Check system (as set forth in Title 13) without having engaged the parking brake before turning ignition off.
- CHP stated that the specification requires that drivers set the parking brake before turning ignition off.
CCM's Understanding of CHP Intent
CCM believes that CHP requires that system must not be deactivated unless the parking brake was set before ignition was turned off. There are three possible ways that this could be accomplished:
- One could assume that each driver is following this procedure consistently (i.e. each driver always sets the parking brake before turning ignition off). If it is reasonable to make this assumption, CCM believes this would satisfy CHP's intent. CCM cannot offer any guidance on whether this is a reasonable assumption.
- One could rely on another system (e.g. an existing safety system that requires the parking brake to be set when ignition is turned off). If the function of this other system restricts the driver from deactivating the Child Check-Mate System unless the parking brake has been set before ignition has been turned off, then CCM believes this would satisfy CHP's intent.
- One could install the appropriate Child Check-Mate parking brake connection. When installed correctly, the system cannot be deactivated (and will begin to sound an alarm) if the parking brake is not engaged before ignition is turned off. CCM believes this would satisfy CHP's intent.
CCM's Opinion
To the best of our understanding, all 3 of the above options may satisfy CHP's intent. Based on our understanding, CCM believes that option 3 (i.e. using Child Check-Mate system to monitor the state of the parking brake) is the option that most closely follows the performance description and intent as set forth by CHP in Title 13.
How the system complies with the CHP specification is at the discretion of the customer.
Again, this information is provided "as is". It does not constitute legal or regulatory advice, and CCM always encourages that customers read specifications themselves. The CHP specification is performance-based. In the event that you have a different interpretation, we encourage you to reach out to CHP directly for clarification.
