Interpretation ID: nht92-2.11

DATE: 11/23/92

FROM: HARRY CAMERON -- PRESIDENT, SAFETY, LTD.

TO: PAUL JACKSON RICE -- CHIEF COUNCIL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 2-22-93 FROM JOHN WOMACK TO HARRY CAMERON (A40; STD. 209; VSA 108)

TEXT:

November 23, 1992 I am writing you at the suggestion of Mr. Jim Gilkey of the Vehicle Safety Office.

This letter is to inquire into the procedure to obtain certification for the repair and recertification of motor vehicle passenger restraints to comply with DOT 206-3206.

We have a request for a branch of the Defense Department to provide this service as they have a problem replacing belts which have worn and frayed webbing when new belts are not available or over priced.

This is a normal function for us as we are certified by the Federal Aviation Administration to repair, inspect and recertify aircraft belts. This is accomplished as FAA Repair Station FY5R9874M, with repairs complying with our operation specifications manual, "Repairs to aircraft seat belts per manufacturers recommendations, TSO and AC 43.13-1A Chapter 8, Section 3, Paragraph 361".

I understand this requirement has not surfaced in the past, but I believe there will be a need in the future resulting from the increased use of restraints in high milage vehicles and responsible procedures should be extablished.

Thank you.