ID: nht76-4.42

DATE: 02/25/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Byron A. Crampton

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 16, 1976, concerning crew cab doors for use on fire trucks, and the interpretation of Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components.

You asked two questions in your letter:

(1) Is it the intent of FMVSS 206 to actually address door hardware for doors that are adjacent to a walkway and not a seat?

Standard No. 206 is applicable to the type of vehicle that you described. Paragraph S4 of the standard states that "component on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard". The standard does not require the door to be directly adjacent to a seat. The door on your vehicle leads directly "into a compartment that contains one or more seating accommodations," so the standard is applicable. The presence of a walkway is irrevelant.

(2) If the standard does apply would not the installation of an untested conventional door structure in place of a folding door result in a safer vehicle?

The NHTSA hopes that manufacturers would install conventional hinged door structures instead of folding doors on fire trucks, if the hinged doors would result in producing safer vehicles. The cost of testing the components of hinged doors for purposes of Standard 206 should not be determinative of whether the manufacturer will install hinged doors or folding doors on the fire trucks. Rather, the safety of the firemen who must use the trucks should be the determinative factor.

You should be aware that the tests in Standard No. 206 are laboratory tests of the components, and do not involve the vehicle as a whole. These component systems are generally available from suppliers and are already warranted as being in compliance with Federal standards. Therefore, the cost of using conventional hinged doors might not be as prohibitive as you had supposed.

Please contact us if we can be of any further assistance.

YOURS TRULY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, INC.

January 16, 1976

Richard B. Dyson, Asst. Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

The Fire Apparatus Manufacturers Division (FAMD) of the Truck Body and Equipment Association (TBEA) represents more than fifty manufacturers of fire apparatus, who in turn account for approximately 85% of the pieces of equipment sold within the United States.

Recently several FAMD members have questioned this office as to specific requirements of FMVSS 206 as applicable to fire apparatus equipped with crew cabs. The vehicles in question (see sketch) are generally produced on a commercial truck chassis by adding fire fighting equipment, a fire apparatus body, and finally - a crew cab which allows the vehicle to carry additional personnel.

From the sketch, it can be seen, that the crew cab doors open up to a walkway to the passenger compartment and not onto a designated seating position. The three designated seating positions furnished with the crew cab are set back into the compartment to allow personnel clothed (Illegible Words) and breathing apparatus to walk to their seat.

Section S4 of FMVSS 206 states that the standard does not apply to folding doors or doors that are designed to be easily attached and removed, and therefore when faced with the high costs of testing a few completed vehicles to FMVSS 206 or installing either folding doors or quick release hinges, the decision is simple - but inconsistent with our aim toward developing the best piece of fire apparatus possible.

With this dilema in mind, our questions are as follows:

1. Is it the intent of FMVSS 206 to actually address door hardware for doors that are adjacent to a walkway and not a seat?

2. If the standard does apply, would not the installation of an untested conventional door structure in place of a folding door result in a safer vehicle?

We would appreciate any additional comments that you may have concerning this situation.

Byron A. Crampton Manager of Engineering Services

* Notes

1. Crew cab doors are presently the folding type or equipped with quick disconnect hinges.

FIRE APPARATUS with CREW CAB

(Graphics omitted)

ID: nht76-4.43

DATE: 09/02/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Nissan Motor Company's June 2, 1976, question whether a passenger car rear seat cushion assembly which is hinged to rotate forward about its lower front corner is subject to the requirement of S4.3 of Standard No. 207, Seating Systems, for a self-locking restraining device with certain dynamic characteristics. If a restraining device is required, you request to know the test procedures appropriate for it under S4.3.2.1(a).

Section S4.3 of Standard No. 207 states, with two exceptions, "a hinged or folding occupant seat or occupant seat back shall be equipped with a self-locking device for restraining the hinged or folding device." The NHTSA does not consider the words "occupant seat or occupant seat back" to refer to the seat cushion alone, and therefore a restraining device for the cushion alone is not required. The requirement of S4.2(a) in the case of seating systems with separate backs and cushions is considered a sufficient test of the seat cushion retention characteristics. In the case of the seat cushion assembly you describe, our estimate of the cushion center of gravity in relation to the hinge point indicates that some form of restraint is probably necessary to comply with the requirement for application of a 20g force in the forward direction.

This interpretation supersedes our November 27, 1972, letter to the Recreational Vehicle Institute to the degree that its discussion of seat cushion restraint is inconsistent with this interpretation.

YOURS TRULY,

NISSAN MOTOR CO. LTD.

June 2, 1976

Frank A. Berndt Acting Chief Counsel National Highway Traffic Safety Administration

We would like to take this opportunity to ask you for your interpretation regarding the application of S.4.3 in FMVSS 207 "Seating Systems".

1) Is S.4.3 applied to the hinged seat cushion which is shown in the attachment No. 1? In other words, should the hinged seat cushion be equipped with a self-locking device for restraining itself and a control for releasing that restraining device? Should its restraining device meet the requirements of static force and acceleration stated in S.4.3.2.1 (a) and S.4.3.2.2 respectively?

2) If the answer of the above question is yes, in which direction of (X) or (Z) described in the attachment No. 2 should the restraining device be subjected to an acceleration of 20 g when tested in accordance with S.4.3.2.2?

Thank you for your attention to this matter. We look forward to hearing your interpretation of the above in the near future.

Tokio Iinuma Staff, Safety

CC: ROBERT E. NELSON

Condition of using seat

Condition of folding seat

Attachment No. 1 - the hinged seat cushion installed for the rear seating system of station wagon

(Graphics omitted)

(Graphics omitted)

ID: nht76-4.44

DATE: 09/27/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Joseph G. Bishop -- U.S. Coach Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your July 7, 1976, request for information regarding the applicability of Federal motor vehicle safety standards to "rumble seat kits" for installation in passenger cars. The answers to your questions are as follows:

(1) "Is there any Federal Motor Vehicle Safety Standards or Regulations that would preclude the installation of rumble seats in passenger cars?"

The answer to your question is no.

(2) "What are the current Federal Motor Vehicle Safety Standards and Regulations that would be specifically applicable to the installation of rumble seats in passenger cars?"

Installation of the rumble seats could affect compliance of the vehicle with the following safety standards: Standard No. 207, Seating Systems; Standard No. 208, Occupant Crash Protection; Standard No. 209, Seat Belt Assemblies; Standard No. 210, Seat Belt Assembly Anchorages; and Standard No. 110, Tire Selection and Rims.

We are assuming that the rumble seats would be installed in completed vehicles that are already certified, in which case the alterer would be required to meet the requirements of 49 CFR Part 567. Section 567.7 requires one who alters a previously certified vehicle, prior to its first sale, (by other than readily attachable components) to affix an additional label to the vehicle, stating that the vehicle remains in compliance with all applicable safety standards after the alteration. It should be noted that any additional weight created by the rumble seats or a change in the distribution of weight could also affect the vehicle's compliance with other safety standards whose test procedures require a barrier crash test.

We also would point out that 49 CFR Part 575 requires manufacturers to provide consumer information regarding vehicle stopping distance, tire reserve load, and acceleration and passing ability, at the point of first sale of the vehicle and along with the purchased vehicle. The increased weight created by the rumble seats could require modification of the information that would have to be provided.

(3) "Is there any State or Local Motor Vehicle Safety Standards that to your knowledge may preclude the installation of rumble seats in passenger vehicles?"

We are not aware of any State or local regulations that would preclude installation of rumble seats in passenger vehicles.

(4) Can you furnish a list of Government approved independent testing facilities for FMVSS compliance testing?" The National Highway Traffic Safety Administration (NHTSA) does not approve independent testing facilities, nor will it recommend that any particular testing center be utilized. You might wish to contact the American Association of Motor Vehicle Administrators concerning this subject, at 1201 Connecticut Avenue, N.W., Washington, D.C.

(5) "Can the NHTSA make any design recommendations related to the installation of rumble seats in passenger vehicles?"

The NHTSA does not provide engineering expertise regarding the manufactuer of motor vehicles or motor vehicle equipment. However, the agency will answer specific questions that a manufacturer might have concerning the basis for a particular performance requirement.

(6) "Is there any future or pending legislation that may be related to the installation of rumble seats in passenger vehicles?"

At the present time there is no pending Federal legislation relating to the installation of rumble seats in passenger vehicles, nor is any such legislation anticipated by the NHTSA in the immediate future.

The statements made above are directed primarily to the situation in which rumble seats would be installed prior to first sale of the vehicle, and in which the vehicle would have to be certified as being in compliance with all applicable motor vehicle safety standards. Please note, however, that the aftermarket installation of rumble seats might also be subject to Federal requirements.

Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 provides that, with one exception, "no manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . ." Therefore, no manufacturer, distributor, dealer, or repair business may install the rumble seats in a motor vehicle if he knows that such installation would alter the vehicle's compliance with any safety standard. For example, installation of rumble seats could possibly affect components of the vehicle that are subject to the requirements of safety standards such as Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, or Standard No. 301, Fuel System Integrity.

SINCERELY,

U.S. COACH CORP.

July 7, 1976

Robert L. Carter Associate Administrator - Motor Vehicle Programs National Highway Traffic Safety Administration

Re: Request for FMVSS Information Covering Automotive Accessories

U.S. Coach Corporation designs, engineers and manufactures automotive accessory items for installation on passenger car vehicles at distribution centers throughout the United States. Several of our products are installed on vehicles prior to sale to the original owner at the dealer level and are therefore considered O.E.M. products requiring our certification that structural modifications are in compliance with all applicable Federal Motor Vehicle Safety Standards.

We are currently designing and developing a "Rumble Seat Kit" that will accomodate two passengers in a seat located in the trunk or luggage compartment of passenger vehicles. My review of the National Traffic and Motor Vehicle Safety Act of 1966 as amended, did not reveal any preclusion of the use of a 'Rumble Seat Option' in passenger vehicles.

It is our intent to proceed with our program to meet the passenger restraint requirements of Standards 208, 209 and 210 with Type 1 seat belts and installed in a manner that compliance with all Federal Motor Vehicle Safety Standards is preserved.

Since our Corporate intent is to manufacture and sell products that not only meet or exceed all existing Federal Safety Standards but will also afford the highest level of protection to the consumer, we are very interested in any recommendations the N.H.T.S.A. may offer pertaining to occupant protection in open vehicle passenger accomodation specifically in the "Rumble Seat" application.

Would you please respond to the following questions as well as making any comments or suggestions relating to our program:

1. Is there any Federal Motor Vehicle Safety Standards or Regulations that would preclude the installation of rumble seats in passenger vehicles?

2. What are the current Federal Motor Vehicle Safety Standards and Regulations that would be specifically applicable to the installation of rumble seats in passenger vehicles?

3. Is there any State or Local Motor Vehicle Safety Standards that to your knowledge may preclude the installation of rumble seats in passenger vehicles?

4. Can you furnish a list of Government approved independent testing facilities for FMVSS compliance testing?

5. Can the N.H.T.S.A. make any design recommendations related to the installation of rumble seats in passenger vehicles?

6. Is there any furture or pending legislation that may be related to the installation of rumble seats in passenger vehicles?

We sincerely appreciate any assistance you may provide in the above matter.

Joseph G. Bishop President

ID: nht76-4.45

DATE: 01/12/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Bureau of Standards

TITLE: FMVSS INTERPRETATION

ID: nht76-4.46

DATE: 04/21/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 15, 1976, question whether a passenger car is considered a convertible for purposes of compliance with motor vehicle safety standards if its roof includes a "sun roof" or has two removable sections fitted into the roof over the outboard front designated seating positions in such a fashion that they do not join each other (Hurst Hatch Roof). You also request confirmation that convertibles are excluded from the requirements of Standard No. 216, Roof Crush Resistance, and are required to meet S4.1.2.3.2 of Standard No. 208, Occupant Crash Protection.

The answer to your first question is no. The National Highway Traffic Safety Administration considers a convertible to be a vehicle whose "A" pillar or windshield peripheral support is not joined with the "B" pillar (or rear roof support rearward of the "B" pillar position) by a fixed, rigid structural member. Passenger cars equipped with a "sun roof" or a "Hurst Hatch Roof" do not qualify as convertible, because they have a fixed, rigid structural member in the described location.

With regard to your other question, passenger cars manufactured from September 1, 1973, to August 31, 1976, inclusive, are required to meet one of three options specified in Standard No. 208. If a manufacturer chooses to meet the third option listed (S4.1.2.3), separate requirements are specified for convertibles in S4.1.2.3.2. Convertibles are excluded from Standard No. 216, although a manufacturer may choose to meet the standard in place of certain requirements of Standard No. 208 that are not presently mandatory.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

March 15, 1976

Frank A. Berndt Acting Chief Counsel National Highway Traffic Safety Administration

Re: Hurst Hatch Roof and FMVSS No. 216

I would like to take this opportunity to ask you a few questions regarding your interpretation of the word "Convertible", which can be seen in FMVSS No. 216, S3.

In the recent model cars, there have been passenger cars equipped with a new type of roof called "Hurst Hatch Roof", which is shown in the picture in the attachment to this letter (No.1). The structure of the Hurst Hatch Roof Body is completely different from the conventional sun roof, which is also shown in the attachment (No.2). It seems to show a different performance if tested to FMVSS No. 216.

My questions are as follows:

1) Is the Hurst Hatch Roof car defined as a convertible?

2) Is the conventional sun roof car defined as a convertible?

3) If the convertibles are manufactured in the production line, those cars do not have to comply with FMVSS No. 216. However, they have to meet the requirement of S4.1.2.3.2 of FMVSS No.208. Is my understanding correct?

It would be greatly appreciated if your clear interpretation would be given to me by letter as soon as possible.

Naoyoshi Suzuki Staff, Safety

ATTACHMENT

(NO.1)

(NO. 2)

(Graphics omitted)

ID: nht76-4.47

DATE: 01/08/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: American Safety Equipment Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to American Safety's December 5, 1975, question whether a state or local government agency such as a municipal police department may modify Type II seat belt assemblies to permit detachment of the upper torso restraint, and whether a seat belt manufacturer may "participate in the modifications of the vehicle and seat belt assemblies."

Section 108(a)(2) of the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. @ 1397(a)(2) prohibits a manufacturer, distributor, dealer, or repair business from "knowingly [rendering] inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard [except during a repair]." This prohibition applies to changing a non-detachable upper torso restraint to a detachable upper torso restraint.

Under this language of the Act, the police department would not be prohibited from modification of the seat belts. A manufacturer could not actively participate in the modification of the vehicles. Sale of a seat belt assembly to the police department would not of itself, however, constitute a violation of the Act.

YOURS TRULY,

American Safety

December 5, 1975

Mr. Frank Berndt, Chief Counsel Office of Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration

This will acknowledge receipt of your letter dated November 18, 1975, reference N40-30, which was in response to our letter of October 10, 1975.

Apparently there has been a misunderstanding as to the question(s) raised by our October 10th inquiry, as your letter makes reference to seat belt assembly installations in newly manufactured vehicles. The first paragraph of our October 10th letter is addressed to the question of modification of seat belt assemblies in existing vehicles; this modification would result in the shoulder belt portion of the assembly being a "detachable" belt.

In any event, your letter of November 18, 1975 advised that Standard No. 209 does not prohibit the manufacture of seat belt assemblies with detachable upper torso restraints. However, while your letter does state that a municipal government could not specify Type 2 seat belt assemblies with detachable upper torso restraints at the front outboard designated seating position, it is silent in the question of whether the government agency is still free to alter the vehicle after delivery to the agency. You will note that our letter of October 10, 1975 included a copy of an NHTSA letter of May 15, 1974 addressed to Los Angeles County Sheriff, Peter J. Pitchess wherein it was stated that the sheriff was free to alter the department vehicles after delivery. We are again including a copy with this letter for your information.

Accordingly, we would appreciate hearing from you with regard to the questions:

(a) are states and their political subdivisions free to alter their vehicles after delivery by modifying the seat belt assembly wherein the shoulder belt portion of the assembly is "detachable".

(b) assuming that states and their political subdivision may alter their vehicles after delivery, may a manufacturer of seat belt assemblies participate in the modification of the vehicle(s) and seat belt assembly(s) wherein the shoulder belt portion of the assembly(s) is "detachable".

We hope this will correct any misunderstanding.

W. A. May Corporate Secretary

ID: nht76-4.48

DATE: 05/18/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: NSK Warner Kabushiki Kaisha

TITLE: FMVSS INTERPRETATION

TEXT: This responds to NSK Warner's April 12, 1976, question whether the release and buckle requirements of Standard No. 208, Occupant Crash Protection, and Standard No. 209, Seat Belt Assemblies, permit the use of a latch mechanism that consists of a fixed hook over which belt webbing (presumably from the upper torso and pelvic portions of a continuous loop system) is slipped by the occupant, causing a rotating catch to close the open end of the hook and secure the webbing. Release is accomplished by depression of a push button that rotates the catch away from the open end of the hook, followed by occupant action to slip the belt webbing off the hook.

Standard No. 208 specifies that a seat belt assembly installed in a motor vehicle shall have a latch mechanism "[that] releases at a single point by a push-button action" (S7.2(c)). "Release" in this context means that the portions of the belt assembly on either side of the latch mechanism disengage from one another. From your description of the hook mechanism, it would not disengage the two portions of belt assembly by a push-button action, because an additional action by the occupant is required. It therefore appears that such a mechanism would not conform to S7.2(c) of Standard No. 208.

Standard No. 209 specifies that "A Type 1 or Type 2 seat belt assembly shall be provided with a buckle or buckles readily accessible to the occupant to permit his easy and rapid removal from the assembly" (S4.1(e)). "Buckle" is defined in S4 as "a quick release connector which fastens a person in a seat belt assembly." Section S4.3 further specifies that "The buckle of a Type 1 or Type 2 seat belt assembly shall release when a force of not more than 30 pounds or 14 kilograms is applied" (S4.3(d) (1)). "Release" in this standard is also interpreted to mean that the portions of the belt assembly on either side of the latch mechanism disengage from one another. For this reason, it appears that the described device would not comply with the listed requirements of Standard No. 209.

I trust that this answer is responsive to your inquiry.

SINCERELY,

NSK WARNER KABUSHIKI KAISHA

April 12, 1976

Francis Armstrong Director Office of Standard Enforcement Motor Vehicle Programs U.S. Department of Transportation National Highway Traffic Safety Administration Re Interpretation of "buckle" for seat belt

One of our customers has developed a kind of latching device for seat belt buckle. We are obliged if you will read followings and give your opinion to us.

Structure

As illustrated in the attached sheet, the device books like a hook with a stopper and it has an arm fixed stationary to a base, a rotatable c shape catch and a pushbutton.

If a thin and not so soft article such as plastic-covered webbing enters into a slot between the arm and the base, the article pushes the right claw of the catch (Fig. 1) and rotates it. Then, the left claw of the catch shuts the entrance of the slot (Fig. 2).

Pushing the button makes the entrance open by using a mechanical linkage.

Our doubt

We have no doubt of its mechanism but there is a doubt raised after consideration of requirements of FMVSS 208 and 209 if this device should be used for the seat belt buckle.

When a passenger pushes the button and opens the entrance of the slot to release himself from a seat belt restraint, the webbing remains in the slot and it does not make him free. The device, therefor, needs one more action; "picking the webbing off the device", to release the passenger completely.

Especially in a case after a turn-over accident, we may be unable to release the passenger because the seat belt is under tension caused by his weight if the webbing has been caught by the hook.

The above is our anxiety about introducing the device to the seat belt buckle.

We would appreciate very much if you could judge and let us know whether the device could be regarded as a buckle.

A. Mita, Chief Engineering Dept.

Fig. 1 Released Position

(Graphic omitted)

ID: nht76-4.49

DATE: 07/09/76

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your March 16, 1976, request for assurance that paragraph S4.3(f) of Standard No. 209, Seat Belt Assemblies, does not apply to the mechanism in a continuous loop seat belt system that limits (prevents) transfer of belt webbing from the shoulder to the pelvic portion of the belt when the buckle is engaged. Your letter recommended that Standard No. 209 be amended to specifically exempt such adjustment mechanisms from the requirements of paragraph 4.3(f) or that separate, appropriate requirements for those mechanisms be established.

The National Highway Traffic Safety Administration (NHTSA) has determined that the adjustment mechanism described in your letter is not a "tilt lock" within the meaning of paragraph S4.3(f) of the standard, although the two mechanisms are superficially similar. Therefore, this mechanism does not have to comply with the requirements of paragraph S4.3(f).

We would like to emphasize our comments to you of June 13, 1975, regarding the requirement that a continuous loop assembly have a sufficiently low level of friction at the buckle mechanism to ensure that the lap portion of the belt is automatically adjustable. The friction in the buckle must be low enough that the normal motion of the occupant against the shoulder belt tightens the lap portion of the belt to prevent excessive slack and possible submarining of the occupant.

The NHTSA has also considered Chrysler's petition to amend Standard No. 209 to establish "separate appropriate requirements" for the adjustment mechanism in question and decided that it should be granted. A notice proposing such modifications of the standard is anticipated in the near future.

As you are aware, the commencement of a rulemaking proceeding does not signify that the rule in question will necessarily be issued. A decision concerning the issuance of a rule is made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria.

SINCERELY,

ATTACH.

CHRYSLER CORPORATION

March 16, 1976

James B. Gregory -- Administrator, National Highway Traffic Safety Administration

Subject: REQUEST FOR INTERPRETATION AND PETITION FOR AMENDMENT OF @ 4.3(f) OF MVSS 209 - SEAT BELT ASSEMBLIES

Dear Dr. Gregory:

Recently, the U.S. Testing Company, Inc. conducted a test on our continuous loop (unibelt) seat belt system for the American Safety Equipment Corporation (our supplier). They are questioning whether an adjustment mechanism in a unibelt system utilizing a tilt-lock design superficially similar to the tilt-lock buckle of a Type 1 lap belt assembly needs to meet the requirements of @ 4.3(f) of MVSS 209, Seat Belt Assemblies.

In our opinion, these requirements should not apply to a unibelt adjustment mechanism, since its function is quite different from that of a tilt-lock buckle in a Type 1 lap belt assembly. In a Type 1 lap belt only assembly it is important that the tilt-lock buckle hold the webbing firmly in place without excessive slippage under load. Accordingly, the tests prescribed in @ 4.3(f) of MVSS 209 are appropriate for that application. In a continuous loop system, however, it is the retractor (not the adjustment buckle) which adjusts the belt webbing to the proper length and holds the webbing at that length under load. In a loop system, the primary purpose of the adjustment mechanism is to permit easy or automatic tightening of the total belt system by the retractor. Several of the continuous loop belt systems currently being used provide for this adjustment by use of a simple slip ring design which allows free movement of the webbing between the lap and shoulder belt portion of the system. This design does not have a buckle adjustment mechanism which holds the lap belt taut. Obviously, in these cases, the requirements of @ 4.3(f) do not apply. It is our opinion that this section is equally inapplicable if the adjustment device uses a tilt mechanism superficially similar to a tilt-lock of a Type 1 lap belt assembly in place of the slip ring.

On May 16, 1975, Chrysler engineers demonstrated our unibelt system to NHTSA personnel in the garage of the NHTSA headquarters. At that demonstration we pointed out the tilt-type adjustment feature designed into our system. In addition to allowing automatic tightening of the total belt system by the retractor our tilt-type buckle adjustor holds the lap belt taut once the user has tightened it. The feature was provided for the convenience of and added safety of belt users who like a tighter fitting lap belt than can be provided by a slip ring. Coupled with our window shade tension relief mechanism for the shoulder belt, it allows the belt user to have a snug fitting lap belt and a comfortable shoulder belt. This adjustment feature is accomplished by the use of a tilt-lock mechanism superficially similar to a tilt-lock buckle used with a Type 1 lap belt assembly. As noted above the design and function are significantly different, however.

We recognize that NHTSA does not give certification approvals or otherwise prejudge the compliance of a device. However, in a letter dated June 13, 1975 to S. L. Terry from the Administrator, it was noted that NHTSA personnel saw no evidence of design deficiency related to our unibelt system. The letter gave two important requirements for such systems: (1) the level of friction in the assembly must be low enough to allow "automatic adjustment" of the lap belt portion with normal motion of the occupant against the shoulder belt, and (2) devices that limit retractive action may only be used with seat belt assemblies that have an "individually adjustable lap belt." It is our understanding from the NHTSA representatives who participated in the demonstration that our system meets both of those requirements.

In view of questions concerning our understanding and interpretation of the standard, we request that NHTSA provide us assurance that @ 4.3(f) of MVSS 209 does not apply to the adjustment mechanism of a unibelt system using a design superficially similar to a tilt-lock buckle commonly used in Type 1 lap belt assemblies.

Secondly, we recommend that the standard be modified to specifically exempt such adjustment mechanisms from those requirements or that separate appropriate requirements for these mechanisms be established.

Very truly yours, S. L. Terry -- Vice President, Public Responsibility and Consumer Affairs

ID: nht76-4.5

DATE: 01/07/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: The Leithiser Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 14, 1975, question whether an air-braked trailer that carries three spools of electric power line and is designed to pay out and tension the three lines over towers would be required to comply with Standard No. 121, Air Brake Systems.

Section S3. (Application) states in part that ". . . the standard does not apply to any trailer whose unloaded vehicle weight is not less than 95 percent of GVWR [gross vehicle weight rating] . . ." It appears from your description that the trailer in question does not have either a passenger-carrying capacity or a rated cargo load. The unloaded vehicle weight would be equal to the GVWR and the trailer would be exculded from the requirements of the air brake standard.

YOURS TRULY,

The Leithiser Company

November 14, 1975

Administrator, Dept. of Transportation National Highway Safety Administration

Reference: Standard No. 121, Air Brake Systems, 49 CFR 571.121 Tensioner - Tri-Axle Mounted

On March 15, 1974 we submitted a quotation to the Cleveland Electric Illuminating Co., Cleveland, Ohio covering the construction of a piece of special machinery for tensioning electric power lines. On April 10, 1974 we received a purchase order for the equipment.

We are enclosing a line sketch of the referenced device. The machine is mounted on a tri-axle suspension because the gross weight of 34,000 lbs. exceeds by 2,000 lbs. the legal limit in Ohio for a tandem axle.

Due to recent problems in the delivery of components, this machine will not be completed until March or April of 1976. The addition of "121" equipment to this device, particularly in view of the three axles, would increase the cost to our customer approximately $ 4,000,00.

We feel that because this is a specialized piece of equipment that the econimic burden of acquiring certification and the increase in cost to our customer, should relieve us of the necessity for installing the "121" appliances. May we have a ruling in this matter as soon as possible?

George L. Leithiser, Pres.

(Graphics omitted)

The LEITHISER Company York, Fa

THREE REEL PAYOFF TRA. DCALO 1/32 "DWO MC. DATE 11/10/75 DWN. WY M. KLINK

ID: nht76-4.50

DATE: 12/09/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your October 29, 1976, request for confirmation that a recent NHTSA interpretation regarding the buckle crush requirements of Standard No. 209 (as stated in a letter to Volvo dated August 31, 1976) is applicable to BMW seat belt buckles.

Our letter to Volvo stated that "the existing S4.3(d)(3) buckle requirements are not applicable to buckles that are located between bucket seats and attached to the console or to the end of a rigid cable or bar." This interpretation constitutes an explanation of S4.3(d)(3) as its provisions apply to all seat belt buckles regulated by the standard. The interpretation is not applicable only to Volvo belt buckles or to buckles produced by any other individual manufacturer. It is the responsibility of each manufacturer to determine, in the first instance, whether or not his products fall within any standard's provisions, including provisions that are explained by means of an interpretation.

I am enclosing a copy of our August 31, 1976, letter to Volvo for your information. As requested, we have withdrawn your petition for rulemaking.

Sincerely,

Enclosure

ATTACH.

November 16, 1976

Frank A. Berndt, Esquire -- Acting Chief Counsel, U. S. Department of Transportation NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Dear Mr. Berndt:

Thank you for your letter N40-30 of October 29, 1976, informing us that our submission of September 28, 1976, concerning the Buckle Crush Requirements of S4.3(d)(3) is currently being reviewed by your Program Division.

Meanwhile, we have searched the docket and found that an interpretation in respect to the application of the buckle crush requirements has already been given by your office to Volvo of America Corporation with letter of August 30, 1976, according to which you conclude "that the existing S4.3(d)(3) buckle requirements are not applicable to buckles that are located between bucket seats and attached to the console or to the end of a rigid cable or bar".

As we have indicated in our submission, BMW's seat belt buckle assembly is also of rigid design and is located between the front bucket seats. We, therefore, assume that our buckle, as described in our letter of September 8, 1976, would be exempted from the requirements of S4.3(d)(3). Inasmuch as you have provided a favorable interpretation on the question of buckle crush requirements to Volvo, we assume that this interpretation is also applicable to BMW's seat belt buckle. We would appreciate receiving confirmation from you that the interpretation given to Volvo is also applicable to BMW's seat belt and buckle configuration. If you agree, you may consider our September 28, 1976 submission withdrawn.

Very truly yours, Karl-Heinz Ziwica -- Manager - Safety Engineering, BMW OF NORTH AMERICA, INC.

cc: BMW-AG