Interpretation ID: aiam1799
Administrative Engineer
TRW
Inc.
23555 Euclid Avenue
Cleveland
OH 44117;
Dear Mr. Multhaup: This responds to TRW's January 24, 1975, question whether S4.1(k) o Standard No. 209, *Seat belt assemblies*, requires separate labeling of both parts of a Type II seat belt assembly in those cases where webbing is used on both the 'tongue' and 'receptacle' sides of the assembly. You enclose a photograph of the seat belt assembly in question.; Section S3. defines 'Seat belt assembly' as 'any strap, webbing o similar device designed to secure a person in a motor vehicle in order to mitigate the results of any accident, including all necessary buckles and other fasteners...' The use of the word 'assembly' and the reference to 'buckles and other fasteners' makes clear that a seat belt assembly can be composed of more than one part.; Section S4.1(k) specifies that 'Each seat belt assembly' shall b permanently and legibly marked or labeled with certain information. This means that one label is required on each assembly, regardless of the number of components which constitute the assembly.; Therefore, so long as the two portions of a seat belt assembly are i fact designed for use in combination to secure a person in a motor vehicle in order to mitigate the results of any accident, one label satisfies the requirements of S4.1(k).; Yours truly, Richard B. Dyson, Assistant Chief Counsel