Interpretation ID: nht88-1.80

TYPE: INTERPRETATION-NHTSA

DATE: 03/28/88

FROM: CLAIRE HAVEN -- VICE PRESIDENT, QUADWEST

TO: ERIKA JONES -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: LETTER DATED 11-22-88 TO CLAIRE HAVEN, QUADWEST, FROM ERIKA Z. JONES, NHTSA; REDBOOK A33; STDS. 209, 208, 302; VSA 108(A)(2)

TEXT: As You can see by the enclosed letter, I've been corresponding with Carl Clark, Inventor Contact, at the Department of Transportation, regarding the Joyride Seatbelt Pad.

We propose to sell this pad as a comfort item to be used on the shoulder strap of a standard seatbelt. By eliminating the uncomfortable pressure and chafing of some seatbelts, we believe our product will increase the use seatbelts generally, thereby inc reasing the level of driver safety.

Mr. Clark has advised us that he see no objection to the use of Joyride Seatbelt Pad. Therefore, upon his advice, I am requesting a formal letter from you, as Chief Counsel, that our product does not take the manufacturer-installed seatbelt out of compl iance with applicable federal motor vehicle safety standards. A sample of the Joyride Seatbelt Pad is enclosed for your reference.

As we wish to distribute our new product shortly, we would be most grateful for you early reply.

Thank you for your help.