Interpretation ID: 1985-01.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Binichi Doi NSK Representative Office

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Binichi Doi NSK Representative Office 3861 Research Park Drive P.O. Box 1507 Ann Arbor, Michigan 48106

This responds to your letter of December 21, 1984, concerning several questions about Standard No. 209, Seat Belt Assemblies.

In all of your questions, you in essence asked whether automatic safety belts are required to meet the marking requirements of section 4.1(j) of Standard No. 209. The answer is that automatic belts complying with the frontal crash protection requirements of Standard No. 208 are not required to meet the marking requirements of Standard No. 209.

As explained in detail in the enclosed agency interpretation letter of August 7, 1981, to Volkswagen, automatic safety belts that meet the perpendicular frontal crash protection requirements of section S5.1 of Standard No. 208 are only required to meet the requirements of Standard No. 209 that are incorporated by reference in section S7.1 of Standard No. 208. Section S7.1 of Standard No. 208 only incorporates provisions directly related to retractor performance and does not incorporate the marking requirements of S4.1(j) of Standard No. 209.

If you have further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

December 21, 1984 NHTSA Room 5219 400 7th Street S.W.

Washington, D.C. 20590 Mr. Frank Berndt, Chief Counsel Interpretation of Marking Requirement for Passive Seat Belts

Dear Mr. Berndt:

I am writing this request for NHTSA's opinion on this subject on behalf of NSK-Warner Co. Ltd. (NWC) of Japan, which is a producer of automotive seat belts and is one of NSK's subsidiaries.

Question 1) Are the passive seat belts required to have the identification marking label sewn or glued on the belt similar to the active seat belts, for ever-ready viewing of such? or is ever-ready viewing of the identification label not required although the I.D. label must be on the seat belt?

2) Is it sufficient to have the identification marking on components other than the belt, such as the retractor or buckle frame, where ever-ready viewing of such could not be practical?

3) Are there other interpretations of the marking requirement than the above?

Background information:

1) NWC needs to know NHTSA's interpretation on the above subject matter for planning the production of its passive seat belts which would be somewhat similar in external appearance to the Toyota Cressida type or the diagonal belt of the VW Rabbit.

2) NWS's customer auto-manufacturers are indicating their dislike far sewing the identification label onto the belt webbing.

3) The probable alternate method would be gluing the I.D. seal label or mark-stamping it onto the retractor frame or the mounting bracket. In this case, the retractor or bracket might be hidden under some form of cover or be located in the center console box, for which ever-ready viewing of such I.D. marking is not practical.

Your kind attention to this request for NHTSA's interpretation of the marking requirement for passive seat belts would be appreciated by us.

Very truly yours,

Binichi Doi NSK Representative

BD/lgc