ID: nht92-3.26

DATE: October 5, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Preston Golder -- Road Reflectors

TITLE: None

ATTACHMT: Attached to letter dated 4/21/92 from Paul Jackson Rice to Allan Schwartz (Std. 108) and letter dated 9/14/92 from Preston Golder to Legal Counsel, NHTSA (OCC-7747)

TEXT:

This responds to your letter of September 14, 1992, asking about the legality under Federal law of your "Auto Neon System", an accessory which reflects a glow from under the vehicle.

We answered an inquiry from Mr. Allan Schwartz about a similar device, in a letter dated April 21, 1992. I enclose a copy of our response to Mr. Schwartz for your information.

ID: nht92-3.27

DATE: October 5, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: William G. Rosoff -- Chief, Entry Rulings Branch, Department of Treasury, U.S. Customs Service

TITLE: None

ATTACHMT: Attached to letter dated 9/18/92 from William G. Rosoff to Chief Counsel, NHTSA (OCC-7748)

TEXT:

This responds to your letter of September 18, 1992, forwarding a letter and documentation from Dr. Irina Elovaara. Dr. Elovaara imported a nonconforming motor vehicle into the United States around October 9, 1991, pursuant to 49 CFR 591.5(d), and is requesting permission to keep it here longer than the one year that the regulation permits. You inform us that Customs does not have the authority to grant an extension or exception.

Paragraph 591.5(d) permits nonresidents of the United States to temporarily import a nonconforming motor vehicle into the United States for a period not to exceed one year, provided that the importer will export it not later than the end of one year after entry. Dr. Elovaara, who holds a visiting fellow appointment at the National Institutes of Health, apparently must export her vehicle not later than October 9, 1992. However, her one-year appointment has been extended for three months, through December 31, 1992, and she wishes to keep her car here until that time. In the meantime, according to Dr. Elovaara, her car has been insured, inspected, and titled in Maryland, as well as passing an emission test.

Paragraph 591.5(d) reflects this agency's attempt to accommodate the terms of the Customs Convention on the Temporary Importation of Private Road Vehicles, to which the United States has subscribed. Under the Convention, a contracting state shall allow nonresidents to import a motor vehicle for their private use on the occasion of a temporary visit without payment of import duties and import taxes and free of import prohibitions and restrictions, and the importation shall be covered by temporary importation papers. However, the period of validity of the temporary importation papers shall not exceed a year from the date of issue. Thus, under the Convention, a "temporary" importation would appear to be one that does not exceed a year. This is the genesis of our regulatory requirement that a nonresident, upon importing a nonconforming vehicle for private use, declare that the vehicle will be exported not later than a year after its entry, and the reason why the regulation contains no provisions for extension of a period beyond one year.

Given the existence of the Convention, we believe you are correct in your conclusion that Customs has no authority to provide an extension or exception, and we have drawn the same conclusion as to the authority of this agency. The question becomes whether, in the absence of timely export of the vehicle, either agency effect to implement the remedies available to it. This is a matter within the general discretionary authority of each agency. The primary concern of this agency, as you know, is motor vehicle safety. Given the fact that Dr. Elovaara's vehicle has already been

subjected to local registration, inspection, emissions and insurance laws, we do not believe that there would be any adverse impact upon safety if her vehicle remains in the United States for three additional months, even if that would constitute a technical violation of the National Traffic and Motor Vehicle Safety Act.

We hope that this resolves Dr. Elovaara's concerns.

ID: nht92-3.28

DATE: 10/05/92

FROM: ROBERT F. GAYER -- EQUIPMENT COORDINATOR, TRANSPORTATION SERVICES, SALT RIVER PROJECT

TO: CHIEF COUNSEL -- NHTSA

COPYEE: TOM LANGENFELD -- GREAT DANE TRAILER

ATTACHMT: ATTACHED TO LETTER DATED 12-14-92 FROM PAUL J. RICE TO ROBERT F. GAYER (A40; STD. 121)

TEXT: Salt River Project, Transportation Services requests an interpretation of FMVSS 121 in regard to compliance of the brake systems on four (4) semi-trailers owned and operated on public streets and highways by Salt River Project. The manufacturer of the four trailers, Great Dane Trailer of Savannah Georgia has stated to Salt River Project that these trailers do not need to comply with "121", because they are "Heavy Haul Trailers". Salt River Project does not agree with Great Dane Trailer, and thus the request for the interpretation. All four (4) trailers are as follows:

Semi Trailer, flatbed, extendable - 40 feet to 65 feet.

GVWR - 68,000 lb.

Length - 45 to 65 feet

Width - 96 inches

Deck Height - 59 inches

Overall Height - 119 inches at Headboard

Axles - 20,000 lb. Rockwell, two (2) each

Service Brakes - Full Air, S-cam, with one Bendix No.

RE-6 Relay Emergency Valve only.

Note: There is no trailer spring brake valve installed on these trailers, of any kind; and only one (1) air reservoir.

Parking Brakes - MGM Spring Applied, Air Released

Trailer Serial Nos: 1GRDM8025KM013401

1GRDM8027KM013402

1GRDM8029KM013403

1GRDM8020KM013404

Attached is a copy of the SRP Vehicle Data Record for one of the trailers, and a "line set" sheet supplied by Great Dane Trailer for one of the trailers.

These four trailers are identically equipped.

Specifically, SRP is concerned that these trailers do not comply with the law, and leaves SRP open to litigation should an accident and resulting lawsuit arise, because of noncompliance in the area of S5.2.1.1 that trailers must have a reservoir that "is capable, when pressurized to 90 p.s.i., of releasing the vehicle's parking brakes at least once and that is unaffected by loss of air pressure in the service brake system"; and S5.2.1.5 that states "be protected against loss of air pressure due to failure or leakage in the system between the service reservoir and its source of air pressure by check valves or equivalent devices". We are aware of Docket 90-3 Notice 2 (corrected to Notice 3 by Notice 4) which revises a portion of FMVSS 121, but do not know the affect it will have on our concerns.

Attachments: SRP Vehicle Data Record

Great Dane Line Set Sheet (TEXT AND PHOTOS OMITTED)

ID: nht92-3.29

DATE: October 2, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Dale E. Dawkins -- Director, Vehicle Compliance and Safety Affairs, Chrysler Corporation

TITLE: None

ATTACHMT: Attached to letter dated 9/4/92 from D. E. Dawkins to Paul Jackson Rice (OCC-7714)

TEXT:

This responds to your September 4, 1992 letter, in which you notified the agency of your intention to modify the Hybrid III dummies to be used in your company's certification testing for Standard No. 208. You stated your opinion that the Hybrid III test dummy currently specified in 49 CFR Part 572 Subpart E is unacceptable for determining whether vehicles equipped with two-point automatic belt systems comply with the injury criteria in Standard No. 208. This opinion is based on the chest deflection measurements you have obtained, which you characterize as "erroneous, erratic, and nonsensical."

You indicated your belief that the inaccurate measurements arise because the ball on the end of the slider rod of the chest deflection transducer "frequently" will pop out of its guide track. According to Chrysler, this occurs because the rubber bump stops on the dummy's sternum act as a fulcrum to pry the ball on the end of the slider rod out of its guide track during crash tests, during which the two-point torso belt deflects the dummy chest in both the fore-aft and lateral directions.

Chrysler believes that this problem can be solved simply by modifying the thorax of the Hybrid III dummy by moving the rubber bump stops from the specified location on the sternum to the spine box of the dummy. Your letter indicates your belief that such a modification will not affect the calibration or measurement accuracy of the chest deflection transducer or the biofidelity of the Hybrid III thorax. You indicated that Chrysler intends to make this modification to the Hybrid III dummy thorax and use the modified dummy for Chrysler's certification testing of a 1994 model year vehicle for purposes of Standard No. 208.

NHTSA's position on the issue of what steps manufacturers must take before certifying that their vehicles or equipment comply with an applicable safety standard has been often stated and applies with equal force in this situation. The compliance test procedures set forth in Standard No. 208 must be followed by this agency during our compliance testing. In this instance, that means that NHTSA's compliance testing will be conducted using the Hybrid III test dummy specified in Part 572, Subpart E, with the rubber bump stops in the location specified therein.

Manufacturers certifying compliance with the safety standards are not required to follow exactly the compliance test procedures set forth in the applicable standard. In fact, manufacturers are not even required to conduct any actual testing before certifying that their products comply with applicable safety standards. However, to avoid liability for civil

penalties in connection with any noncompliance that may be determined to exist, the National Traffic and Motor Vehicle Safety Act (the Safety Act) requires that the manufacturer exercise "due care" to assure compliance and in making its certification. It may be simplest for a manufacturer to establish that it exercised "due care" if the manufacturer has conducted testing that strictly followed the compliance test procedures set forth in the standard. However, "due care" might also be shown using modified test procedures if the manufacturer could demonstrate that the modifications were not likely to have had a significant impact on the test results. In addition, "due care" might be shown using engineering analyses, computer simulations, and the like.

In this case, then, the relevant issue is not whether Chrysler uses a modified version of the Hybrid III test dummy for its certification testing. Instead, the issue is whether Chrysler can show that it would exercise "due care" despite using a modified Hybrid III test dummy for its certification testing. This agency does not make any determinations as to whether "due care" has been exercised except in the context of an enforcement proceeding. Hence, Chrysler will have to make the initial decision as to whether a certification based on the modified Hybrid III dummy could be made in the exercise of "due care." Your letter states that Chrysler's modifications to the test dummy "will not affect the calibration or measurement accuracy of the chest deflection transducer or biofidelity of the Hybrid III thorax." If Chrysler can demonstrate that these statements are correct, Chrysler may be able to show that it exercised "due care" in connection with the use of the modified Hybrid III dummy.

Of course, a manufacturer that can show it exercised due care would still be subject to the statutory obligation to notify owners and remedy any vehicles that are determined not to conform to Standard No. 208. However, this same obligation would apply even to manufacturers that had conducted testing using an unmodified Hybrid III test dummy.

Turning from Chrysler's particular question to the standard in general, NHTSA notes that it has undertaken research examining the issue of chest deflection measurements by the Hybrid III test dummy. An extensive discussion of the agency research and analysis of this issue may be found in the interim final rule postponing the use of the Hybrid III dummy in vehicles that do not use either seat belts or air bags (55 FR 39280; September 26, 1990; copy enclosed). In that notice, NHTSA indicated that it had received significant data from sources outside the agency, including General Motors, Mercedes-Benz, Toyota, INRETS (a French government research and development group), and the Motor Industry Research Association (a British group).

The agency would be very interested in examining any data or test results that Chrysler may have on this subject, especially the assertion that the ball on the end of the chest deflection rod comes out of its track during crash test conditions. Please send all such information to: Barry Felrice, NHTSA Associate Administrator for Rulemaking, Room 5401, 400 Seventh Street, S.W., Washington, D.C. 20590.

I hope this information is helpful. Please let me know if you need any

further information or have some further questions on this subject.

ID: nht92-3.3

DATE: 10/28/92

FROM: WOLFGANG W. KLAMP

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, DOT

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO WOLFGANG W. KLAMP (A40; PART 591)

TEXT: I was referred to you as the result of a conversation with Mr. Ken Weinstein of your office.

My wife and I are both U.S. citizens working in Vancouver, Canada on Temporary Work Permits issued by Canada Immigration. My wife works as a Branch Manager for Crawford & Co., responsible for providing medical case management services for her company in British Columbia and Alberta. When my wife was hired we temporarily resided in Canada moving back to the U.S. during the past month. Crawford & Co., a registered Canadian company provides my wife with a company car, in fact, the company requires that she drive a company owned vehicle because of the nature of her work and the fact that she does not go directly to her office on a daily basis. The company issued her a Canadian made 1992 Ford Tempo which is licensed and insured in British Columbia. The company pays for all insurance, registration and license fees. When and if she leaves the company's employ, the car would remain in Canada.

The issue is that several times now we have been stopped and she was most recently detained by Customs officials at the Douglas (Peace Arch) Border Crossing to be told that the Tempo did not meet DOT requirements and therefore could not be "imported" to the U.S. and that the next time we attempted to cross the border in this vehicle we would not be allowed to enter the U.S. with it. Customs officials stated that the vehicle would have to go through a formal entry process which would include; posting a bond of 1 1/2 times the value of the vehicle (approximately US$ 20,000 - US$ 25,000); the vehicle would have to be sent to a conversion facility in Concord, California (at a cost of approximately US$ 4,000 to US$ 5,000 plus transportation charges to and from the conversion facility) to be brought up to DOT and EPA standards for "imported" vehicles, all because we are U.S. nationals who choose to live in the U.S.

It is our contention that; since my wife has no ownership interest in the vehicle; the vehicle will remain the property of Crawford & Co. and will never be sold or transferred to a resident of the U.S.; and the fact that the vehicle is not used for business purposes at any time in the U.S., and while we clearly understand that U.S. customs has a responsibility to carry-out DOT regulations, we feel that the ruling based on their interpretation of DOT regulations is patently unfair and arbitrary. Other Canadian owned vehicles freely enter the U.S. and are not subject to the same restrictions placed on this vehicle, including those Canadians who reside in the U.S. six months out of each year.

We are not trying to circumvent DOT or Customs regulations, but, we are hopeful that good judgement and fairness will be considered in this appeal to you. We respectfully request your determination on our unusual circumstance, and further, should you decide in our favor that a letter be directed to: Mr. Art Morgan, district Director, U.S. Customs Service, 1000 - 2nd Avenue, Seattle, WA 98104 advising him of your determination.

Your expeditious reply would be appreciated since this whole situation has serious implications with regards to my wife's employment situation. Should you have any questions, please call me at the numbers above. Thanking you in advance for your kind consideration, I remain,

ID: nht92-3.30

DATE: October 2, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Dan Trexler -- Thomas Built Buses

TITLE: None

ATTACHMT: Attached to letter dated 9/14/92 from Paul Jackson Rice to Lyle Walheim (Std. 131) and letter dated 8/10/92 from Dan Trexler to Paul Jackson Rice (OCC-7641)

TEXT:

This responds to your letter requesting an interpretation of the requirements set forth in Federal Motor Vehicle Safety Standard No. 131, School Bus Pedestrian Safety Devices. I am pleased to have this opportunity to respond to your questions about requirements addressing the activation of a stop signal arm and the permissibility of a manual override device. In addition, I am enclosing a September 14, 1992 interpretation letter from this agency to the Wisconsin Department of Transportation, which explains these requirements.

As your letter indicates, there are two different types of lamp systems on school buses: a four lamp system with four red lamps and an eight lamp system with four amber and four red lamps. You asked several questions about the stop arm's activation and the manual override device.

You first ask whether the stop arm is required to extend every time the signal lamps in a four lamp system are activated. (emphasis in original). As a general rule, S5.5 of Standard No. 131 requires that the stop arm be automatically extended at a minimum whenever the red signal lamps are activated. Nevertheless, Standard No. 131 includes an exception to this general rule which permits the installation of an override device. If the override device were activated, then the stop arm would not extend.

Your second question addresses the operation of the stop arm on buses with an eight lamp system. Specifically, you ask whether the stop arm is required to extend only after the red signal lamps have been activated by opening of the bus entrance door or is the stop arm required to extend at any time the red signal lamps are activated. (emphasis in original).

As stated above, Standard No. 131 includes provisions addressing the activation of the stop signal arm. Standard No. 131 requires the stop arm to be automatically extended whenever the red signal lamps are activated, whether those lamps are activated by opening the bus door or for some other reason. Of course, the stop arm may be extended for a longer period of time than when the red signal lamps are activated, given that Standard No. 131 includes the phrase "at a minimum" in explaining when the stop arm must be extended. In the final rule establishing Standard No. 131, the agency addressed methods of stop arm activation used by Washington State, Illinois, and Florida in which the stop arm was activated to control traffic before the door was opened. (56 FR 20363, 20368, May 3, 1991).

Your third question asked whether a device may be used that is capable of remaining in the "override" position with only a one time activation by the driver. The override would have an audible signal that would automatically

sound for at least 60 seconds and would automatically recycle each time the service door was opened, with the engine running. As mentioned above, Standard No. 131 permits a device that prevents the automatic extension of the stop signal arm. In our September 14, 1992 letter to Mr. Lyle Walheim from the State of Wisconsin, we explain a situation in which an override would be permissible. Based on S5.5 of Standard No. 131 and the September 14, 1992 interpretation to Mr. Walheim, it would appear that the override device you describe also would be permissible.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht92-3.31

DATE: 10/02/92

FROM: MARK W. STEVENS -- CHAIRMAN, SEATMORE

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-13-92 FROM PAUL J. RICE TO MARK W. STEVENS (A40; STD. 207; STD. 208; STD. 209; STD. 210; STD. 302; VSA 108

TEXT: We are in the process of designing and manufacturing a after market 3rd rear facing seat for the Ford Taurus and Mercury Sable station wagons 1986-1993.

The Product information contained in these document is proprietary and confidential trade secret information of Seatmore. We ask that this information be kept confidential.

We have asked Johnson Safety in California to manufacture the 3rd seat described in these documents, they have contacted James Gilkey in Code Enforcement Division. Mr. Gilkey suggested that we contact you with the following questions in order to know proper testing requirements.

1. Does the aftermarket 3rd rear facing station wagon system have to be tested in compliance with FMVSS 207, 209, & 210?

2. The seat belt anchorages are Ford factory anchorages built into the car at the factory and designed specifically for the Ford factory 3rd seat and seat belts. We will be using the same anchorages with aftermarket seat belts already in compliance. Is a test required for this system?

3. If testing is required, must they be specifically Static Tested or Dynamic Crash Tested?

I have enclosed pictures with descriptions of the seat and Ford factory mountings for your review.

Please feel free to call if you have questions or need further information. We are ready to take this product to the auto aftermarket and we would appreciate your review and response as soon as possible.

ID: nht92-3.32

DATE: 10/02/92

FROM: FREDD SCHEYS -- PRESIDENT, S.C.C. CARAT INC.

TO: PAUL J. RICE -- CHIEF COUNSIL, NHTSA; TAYLOR VINSON

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO FREDD SCHEYS (A40; PART 567)

TEXT: Since our phone convertation on monday 9, 28, 1992, I would like to ask four your advice regarding the following questions.

I am the official importer for CARAT DUCHATELET from Belgium. From the accompanying literature you can see the history of our company and the kind of work we do on Mercedes Benz and Rolls Royce motorcars.

Since my first year here, I have conducted market surveys pertaining to the need for the type of convertions which we offer.

I now have a customer here in the United States who would like his cars under go our conversion process. This particular klient lives in California and has allready purchased two new Mercedes Benz cars, U.S. specs, type 600 SEL. Both cars are titled in de owners name. He would like for our company to install a stretch convertion and in this case I would send these cars to our company in Belgium. There they would be stretched by an additional thirty-nine inches and the cars would than be shipped back to the United States. My questions is, what are the regulations which we will have to follow in this case?

Also I would like to ask four your advice for the next case; An American klient can buy his U.S. spec car from a local Mercedes dealership with delivery from the Mercedes factory in Germany. When the car is ready he flyes to the factory and takes delivery of his car. After a trip in Europe he leaves his car in our company for a stretch convertion. After this convertion is done we ship the car back to the customer in the United States. . What are the regulations we will have to follow in this case?

Also I like to ask your advice for the case where we have to convert a car into a armoured car.

I would like to thank you for your help and advice in these matters.

(ATTACHMENT OMITTED.)

ID: nht92-3.33

DATE: October 1, 1992 Est.

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: C. Morris Adams

TITLE: None

ATTACHMT: Attached to letter dated 9/24/92 from C. Morris Adams to Paul Jackson Rice (OCC-7768)

TEXT:

This responds to your FAX of September 24, 1992, requesting a ruling regarding the legality of lap belts at the passenger seats on school buses. As explained below, Federal law has long required lap or lap/shoulder belts to be installed at every passenger seating position on small school buses. Federal law has also long permitted, but not required, lap or lap/shoulder belts to be installed at passenger seating positions on large school buses, provided that those belts do not adversely affect the large school bus's compliance with the applicable safety standards. This is still the agency's position.

As you know, in 1977, NHTSA issued Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection, which established minimum levels of crash protection that must be provided for occupants of all school buses. For large school buses (those with a gross vehicle weight rating (GVWR) of more than 10,000 pounds), the standard requires occupant protection through a concept called "compartmentalization" -- strong, well-padded, well-anchored, high-backed, evenly spaced seats. Small school buses (those with a GVWR of 10,000 pounds or less) must provide "compartmentalization" and be equipped with lap or lap/shoulder belts at all passenger seating positions. The agency believes that safety belts are necessary in addition to "compartmentalization" in small school buses because of their smaller size and weight, which are closer to that of passenger cars and light trucks.

Ever since 1977, NHTSA has indicated that Federal law permits lap or lap/shoulder belts to be installed at the passenger seating positions on large school buses as long as the vehicle would still comply with all applicable safety standards, including Standard No. 222. NHTSA has no information to indicate that installation of seat belts at the passenger seating positions on a large school bus would affect the bus's compliance with any safety standard.

The allegations in your FAX that using seat belts in large school buses will result in crash forces producing concentrated loading on the head, instead of being spread evenly over the upper torso as is the case without a seat belt, are nearly identical with the explanations included in a 1985 Transport Canada report on school bus safety. NHTSA carefully evaluated and considered the Canadian report and these explanations in connection with its rulemaking action considering whether to specify requirements for voluntarily installed seat belts on large school buses. 54 FR 11765; March 22, 1989. After fully considering the Canadian report, the agency stated at 54 FR 11770: NHTSA shares commenters' concerns about any implications that safety belts negatively affect the protection provided to passengers on large school buses. However, the agency is not aware of accident data showing an injury caused or made more serious by the presence of safety belts on a school bus. Furthermore, NHTSA cannot conclude from the Canadian report's findings that belts actually degrade the benefits of compartmentalization to the extent that the supplemental restraint system renders inoperative the safety of large school buses, but the possibility exists that the occupant kinematics shown in the Canadian tests could occur.

The agency then identified some possible safety benefits that could result from seat belts in large school buses, benefits that were not considered in the Canadian tests. The agency concluded that, "Although these benefits are not significant enough to justify a Federal requirement for the installation of safety belts on all large school buses, they are enough to provide a basis upon which the agency will decline to prohibit the installation of belts on large school buses." 54 FR 11765, at 11770; March 22, 1989. I have enclosed a copy of this notice for your information.

As you can see, NHTSA has carefully considered the subject raised in your FAX and reviewed all available information in this area. After that review, the agency concluded that there was no justification for changing its longstanding position that persons that wish to do so should be permitted to install seat belts at passenger seating positions in large school buses. Your letter did not provide any data that NHTSA had not already considered. Hence, there is no basis for the agency to change its longstanding position in this area.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht92-3.34

DATE: 10/01/92

FROM: MICHAEL J. VACANTI

TO: OFFICE OF THE CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM PAUL J. RICE TO MICHAEL J. VACANTI (A40; STD. 208; VSA 108)

TEXT: I, Mike Vacanti, have designed an after market seat belt accessory to help fit the shoulder strap and the lap belt properly on small children.

Information on this device is enclosed. Please evaluate this information and offer a ruling as to the compliance with current Federal standards.

Also, enclosed please find a self addressed, stamped envelope for convenience in replying. Your prompt attention will be greatly appreciated. Thank you for this consideration.

Attachment

"Embrace" - Child Safety Seat Belt Accessory

PREMISE:

At the age of four, children can legally ride in a car without a "child safety seat" (car seat). To date, auto manufacturers have not made available any device to properly fit the shoulder strap of the seat belt to small children (roughly ages 4-10 years). Without a proper fit, the shoulder strap of the seat belt will the cross the small child near the head and neck area. Therefore, parents generally will loop the shoulder strap behind the small child, or behind the passenger seat. Neither method is safe.

THE DEVICE:

"Embrace", child safety seat belt accessory will effectively fit the shoulder strap of the seat belt to a small child. (See drawing B1).

"Embrace" is a polyurethane device that latches onto the lap belt of the seat belt and also to the shoulder strap of the seat belt, changing the angle at which the belt crosses the child's upper body in front of the child. (See Drawing A1).

USAGE:

I believe this device can be widely used with any and all automobiles that employ a shoulder strap with the seat belt. This device should not be limited to children. Size variances can be developed to fit different groups, such as senior citizens, physically challenged individuals or other special needs. The first application of the device will be children.

DESIGN: This device was initially conceived by Michael Vacanti in the year 1991. After testing with mock-up and redesigning, this device if believed to be ready for production.

(GRAPHICS OMITTED)