Interpretation ID: nht88-1.70

TYPE: INTERPRETATION-NHTSA

DATE: MARCH 15, 1988

FROM: CARL C. CLARK -- INVENTOR CONTACT, NHTSA

TO: CLAIRE HAVEN--QUADWEST, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 11-22-88 TO CLAIRE HAVEN, QUADWEST, FROM ERICKA Z. JONES, NHTSA; REDBOOK A33; STDS. 209, 208, 302; VSA108 (A)(2)

TEXT: Thank you for sending your "Joyride" Seatbelt Pad, which you propose to sell as a comfort rather than a safety feature. This nylon covered foam pad device fits inside of the shoulder belt and is attached to the shoulder belt by nylon babs running the le ngth of the pad (about 16 inches) with velcro along the entire length. You have asked for my comments on its design prior to your writing to Ms. Erika Jones, Chief Counsel of this agency, for a formal letter as to whether the device would be expected to take a shoulder belt out of compliance with any applicable Federal Motor Vehicle Safety Standard.

The pad has a thickness of about one inch of moderately soft foam, sufficient to spread the load of the retractor force over its width of about 3.5 inches but not sufficient to spread the load under crash conditions, which would require a much stiffer pa d. In the model sent to me, the nylon tabs were closer together than the one and seven eights inches width of the belt, and so did not wrap around the belt to allow complete overlapping of the velcro. You advised me that this was an early model and lat er models had the proper clearance for the belt. Once the pad is in place from the shoulder across the chest, it does make the belt a little more comfortable, particularly if the retractor has a continuous pull, without the "windowshade" feature.

On getting out of the car, the pad must either be removed from the belt or slid toward the latch plate, or it prevents the retractor from reeling up the belt completely or in part, so that the belt may become tangled and less easy to use on the next entr y. We have tried the pad with an automatic motorized passive belt, which has a motor that moves the belt along a track around the door when the door is closed, automatically positioning the shoulder belt across the body; since the retractor is near the center of the car, the pad simply slid along the belt and caused no jamming.

When the pad is in place, it does introduce a slight amount of additional shoulder belt length, but within the one inch or so of acceptable slack, expectedly similar to wearing a coat under a belt.

We do not provide certification tests for showing compliance with standards, nor do we endorse products. A manufacturer, in selling an automotive product, is by the National Traffic and Motor Vehicle Safety Act "self-certifying" that the product meets a ll aplicable federal safety standards. Your product is used in association with the belts, covered under Federal Motor Vehicle Safety Standards 208 and 209, but such a product is not specifically mentioned in these standards. Your device, if left on th e shoulder belt, retards or inhibits retraction, and so may inhibit subsequent belt use if the belt becomes tangled. But for those troubled by the slight retractor load on the shoulder (in some car models), the pad would expectedly increase the comfort o f using the belt. And for short people for whom the shoulder belt may rest flat on the neck, your pad may provide sufficient stiffness to hold the shoulder belt on the shoulder rather than on the neck, a potential safety benefit.

I see no technical safety objection to its use, but you should also request the formal review by the Chief Counsel as to whether there is any implication of interference of your device with an applicable standard.