ID: nht78-2.26

DATE: 04/05/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: C. S. Ullman

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 28, 1978, to Mr. A. P. Uccello, regarding Federal Motor Vehicle Safety Standard No. 202, Head Restraints (copy enclosed).

In this Standard, under section 4(b)(1), the minimum height of the head restraint shall not be less than 27.5 inches above the seating reference point which is determined with a three-dimensional H Point Machine per SAE Standard J826B placed on the seat. Thus, we have specified a minimum dimension that the car builder must comply with, but we have no limit on the maximum dimension of the head restraint. This latter dimension is set by the builder to suit his requirements.

Certainly your height is a problem in this case and for future rulemaking actions along this line we are placing your letter and the Buick reply in the appropriate docket.

SINCERELY,

February 28, 1978

A.P. Uccello Transportation Dept.

Dear Sir:

You are impossible to get on the phone so I will resort to writing.

I have nothing but plaudits for my '77 Buick but I have written to them about the height of the head restraint (head rests). I am 6' 7" tall and the head rest probably would not prevent whip lash in my case. Previously the head rest was made so it could lock in at least three positions-the highest position was correct for me. Now the head rest only tranerses about 1 inch and does not lock so people getting in the back seat could depress the head rest.

Enclosed please find copy of my reply from Buick. I call your attention to the second paragraph. I would like to know what safety standard effects the head rest? If there is such a standard, then it should be corrected.

I welcome your comment and advice.

THANK YOU.

Charles S. Ullmann

BUICK MOTOR DIVISION, GENERAL MOTORS CORPORATION January 31, 1978

S. C. Ullmann Associates, Inc. 94 Highland Road Scarsdale, NY 10583

Att: Mr. Charles S. Ullmann

Dear Mr. Ullmann:

Thank you for your recent note of January 23, 1978 addressed to our Zone Manager, Mr. R. G. Royer, and we appreciate the interest you have shown in bringing to our attention the characteristics of the front seat head rest supports in your 1977 Buick Electra Limited.

As you probably realize, your car was manufactured in compliance with many vehicle safety standards, and one of these considerations is the head rest suitability throughout the range and size of the car occupants.

However, since we welcome comments from all of our owners, it is with this thought that we are forwarding your letter to the attention of those parties responsible for these design caracteristics.

Thank you again for writing, and please be assured of our interest.

K. J. Mariano Manager, Zone Service Operations

ID: nht87-3.46

TYPE: INTERPRETATION-NHTSA

DATE: 12/12/87

FROM: Erika Z. Jones -- NHTSA

TO: Edwin C. Silverstein

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Edwin C. Silverstein 108 Mayfair Lane Mt. Laurel, NJ 08054

Dear Mr. Silverstein:

Thank you for your letter of August 16, 1986, concerning how our standards apply to a product you have invented. According to the literature you provided us, your product, "Limo Leash" is a harness system used to secure an animal in a vehicle. The system consists of a piece of webbing which can be attached at either end to the "clothes hooks" installed in a vehicle. A snap hook, which can be attached to the animal's collar, slides along the webbing to allow the animal to move back and forth.

There are no Federal motor vehicle safety standards that apply to a harness system used for animals. However, since your product is sold as an accessory for use in a motor vehicle, we would consider it an item of motor vehicle equipment. Thus, the manufa cturer of your product would be covered by the agency's regulations on safety-related defects that would pose a hazard to other vehicle occupants. I have enclosed an information sheet which describes those regulations.

Since there may be state regulations governing the manufacture or use of your product, I suggest you check with state transportation officials in the jurisdictions in which you intend to market your product.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

SIZE Associates

LIMO-LEASH

A vehicle animal safety harness for the protection of your pet and the safety of the driver.

This Animal Safety Harness is adjustable. can be made shorter or longer by the use of the Cam-Buckles at each end of the webbing. D-Rings with Bar can be hooked on the existing clothes hooks that have been installed by the Car/Truck Manufacturer. The Sna p-Hook and Tri-Ring can be move back and forth on the webbing. Enclosed for your convenience are two (2) Suction Disks with Hooks. They will be used Only if you want your pet further to the rear of your vehicle. (Suggestion : Any type of adhesive can be used on the suction disks for a stronger hold) Attach Suction Disks On the rear side windows of your vehicle at the same height.

Edwin C. Silverstein 108 Mayfair Lane Mt. Laurel, N. Joseph

Aug 16, 1986

Erika Z. Jones Chief Council NHTSA

Ref: LIMO LEASH

My Dear Erika Z. Jones

A Mr. William Smith advised me to send you a letter in reference to the "LIMO LEASH", an animal harness for the safety of the driver of a car/truck and the safety of the animal.

Please advise me what I shall do so I can get your opinion on the invention of mine.

Respectfully,

Ed Silverstein

ID: nht88-1.54

TYPE: INTERPRETATION-NHTSA

DATE: 02/24/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Captain Robert W. Barthelmess

TITLE: FMVSS INTERPRETATION

TEXT:

Captain Robert W. Barthel Box 5744 APO, NY 09633

Dear Captain Barthelmess:

This is in reply to your letter of December 30, 1987, to this agency with respect to the requirements for importing tires without the DOT symbol.

You have asked whether the DOT symbol must still appear on the tires of vehicles that conform to the U.S. Federal motor vehicle safety standards. The answer is yes; there has been no change in the requirement that the DOT symbol appear on the sidewall of tires manufactured as either original or replacement equipment. The DOT is the manufacturer's certification of compliance with all applicable Federal motor vehicle safety standards. In your letter, you stated that one individual at the Army Air Force Ex change Service indicated that the DOT symbol had been replaced by a series of numbers. This individual may have confused the requirement for the DOT symbol with a different Federal requirement for an identification number to appear on tires. The tire ide ntification number, along other things, assists in the tracing and recalling of tires which may prove to be noncomplying or defective. The requirement for the tire identification number is in addition to, not in place of, the requirement for the DOT symb ol.

You have also asked (with reference to service personnel like yourself who recently bought non-DOT marked tires for your U.S. type automobiles) whether there is a technical possibility of denial of entry to vehicles certified as meeting U.S. safety speci fication but equipped with tires not bearing the DOT symbol. The general procedure is that when a motor vehicle arrives at the port of entry it will be inspected to see whenever it bears the manufacturer's certification of compliance (generally in the dr iver's door post area). We do not know whether Customs makes it a practice to inspect vehicles of U.S. origin for this certificate when a serviceman is returning to the States. If an inspection occurs and the vehicle bears the certification, the vehicle is admitted without further inspection. It is possible, of course, that a Customs inspector could happen to notice in passing the lack of the DOT symbol on the tires. In this instance, as the vehicle would not be in conformity with all applicable standar ds, the Customs inspector could require entry of the vehicle under bond, which would be released upon the importer's production of a statement to this agency that the noncompliance had been corrected. Although we are not aware of any instance in which th is has actually happened, you may wish to contact Customs with respect to its inspection procedures. You may also wish to write GoodYear asking for a statement that the Vector tires comply with Standard NO. 109, which could be presented to Customs should questions arise.

I hope that this answers your questions.

Sincerely,

Erika Z. Jones

Chief Counsel

ID: nht93-6.15

DATE: August 16, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7/2/93 from Ron Marion to Marvin Shaw (OCC 8838)

TEXT:

This responds to your inquiry about the applicability of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1381, "Safety Act") requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. S 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm "on the left side of the bus." (S5.4) The purpose of this standard is "to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus." (S2)

When NHTSA specified that the stop arm must be placed on "the left side of the bus," the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, "the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window." (Emphasis added).

This provision indicates that the agency assumed that the "left" side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle.

Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the DRIVER'S side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side.

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

ID: nht78-1.28

DATE: 01/26/78

FROM: AUTHOR UNAVAILABLE; Howard J. Dugoff; NHTSA

TO: Howard Sturtz, M.D.

COPYEE: RALPH NADER

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Ralph Nader forwarded to me your letter dated November 23, 1977, concerning your difficulty in determining whether your 1977 Ford Econoline van is equipped with an energy absorbing steering column.

Ford Econoline vans are equipped with conventional steering columns that are not energy absorbing. Federal Motor Vehicle Safety Standards No. 203, Steering Control Impact protection, and No. 204, Steering Control Rearward Displacement, are currently only applicable to passenger cars, so manufacturers are not required to have energy absorbing steering columns on van vehicles. Ford has not voluntarily equipped its vans with such steering systems.

The National Highway Traffic Safety Administration shares your concern in this subject. As a matter of fact, the agency has initiated high priority rulemaking proceedings to extend the applicability of several passenger car standards, including Standards 203 and 204, to both vans and light trucks.

Please let me know if you would like further information on automotive safety matters.

Sincerely,

ATTACH.

November 23, 1977

Ralph Nader -- Washington, D.C.

Dear Mr. Nader:

I am an orthopedic surgeon and am most interested in automobile safety. I belong to various organizations regarding automotive safety. Recently, I bought a Ford Van after prolonged investigation, believing that it was safer because of a supposed impact absorbing front end. However, the brochure did not indicate whether the steering column was energy absorbing. I have checked with the dealer, a local assembly plant, as well as "Ford Listens Better." A copy of this latter letter is enclosed. I have not to date received a reply. I have also checked with various organizations, none of which will provide me with an answer. I was hoping that perhaps you could "stimulate" the Ford Motor Company to provide me with some concrete information. I suspect that vans, being considered trucks, do not have the safety features such as an energy absorbing steering wheel that automobile drivers enjoy. Apparently, the automotive industry believes that truck drivers are expendable.

Any help that you can give me in this matter would be most appreciated.

Sincerely,

Howard Sturtz, M.D.

Enclosure

October 11, 1977

Ford Listens Better P.O. Box 1973 Dearborn, Michigan

Gentlemen:

I own a 1977 Ford Econoline Van in the 250 series. I have been most unsuccessful in determining whether the van has an energy absorbing steering wheel. I have been unable to get an answer from Ford other than the usual brochure on the van which does not include this information. I have also inquired from the National Safety Council and other agencies without success. I would appreciate it if you can inform me as to the type of steering column in the van and what the results might be in a front-end collision.

Sincerely,

Howard Sturtz, M.D.

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

ID: nht76-5.16

DATE: 05/19/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: R. A. Olsen, Ph.D.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 26, 1976, question whether Federal motor vehicle safety standards would apply to the replacement of seat belt webbing in seat belt assemblies to refurbish deteriorated portions of the webbing.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, et seq.) authorizes the National Highway Traffic Safety Administration (NHTSA) to regulate the manufacture, but not the repair, of motor vehicle equipment such as seat belt assemblies. The NHTSA has issued a standard that applies to the manufacture and sale of seat belt assemblies (Standard No. 209, Seat Belt Assemblies (49 CFR 571.209)). In enforcement of this standard, the agency must, therefore, distinguish between what is "repair" and what is "manufacture" of a seat belt assembly.

You intend to accept existing seat belt assemblies from vehicle owners and to replace the webbing portions, reusing the hardware that is recovered from the existing assembly. From this description, the agency considers that the operation would constitute the manufacture of a seat belt assembly subject to the requirements of Standard No. 209. The majority of the assembled product would be new material, and the manufacturing operations involved in cutting and sewing constitute significant factors in the construction of the finished product.

SINCERELY,

RICHARD A. OLSEN, Ph.D. Engineering Psychologist

Licensed Psychologist: Pa. #PS0235 Member: APA, PPA, HFS, IEEE, SAE

March 26, 1976

Robert L. Carter Associate Administrator for Motor Vehicle Programs National Highway Traffic Safety Admin. U.S. Department of Transportation

We have been considering establishing a mail-order firm specializing in replacement of the webbing of seat belt assemblies. As you may know, belt replacements through automobile dealers may cost $ 15-20 per assembly, while the webbing, which is the only component that deteriorates, could be supplied for about $ 1-2. By reuse of the hardware and quick turnaround times, stocking only the most common assemblies and allowing trade-ins, this service could expand as the demand increases and keep the cost low.

We would like an opinion from NHTSA on the standards which might be involved in such a service. Specifically, if webbing, assembly, and sewing are comparable to original equipment, would any testing for final assembly strength be required? We assume that reasonable workmanship would be sufficient if standard components and procedures are used. Any extensive testing or certification requirements would preclude initiation of this service firm since very small initial volumes would be anticipated, and cost must be kept low to cover labor, postage, and supplies.

We feel that the public is beginning to appreciate the value of seat belts, partly as a result of the interlock which demonstrated that the belts themselves "weren't so bad after all." Now there needs to be a way to replace frayed belts at a price that is not a strong deterrent.

Richard A. Olsen

ID: nht73-1.4

DATE: 08/10/73

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

TO: Dow Corning Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 27, 1973, asking if there is a conflict between S5.4.3 of Motor Vehicle Safety Standard No. 105a and S5.2.1 of Standard No. 116.

There is no conflict. S5.4.3 of Standard No. 105a requires a label to be affixed to a new motor vehicle with the warning to use brake fluid from a sealed container. S5.2.1 of Standard No. 116 requires containers to be provided with resealable closures. A container with a resealable closure is "sealed" within the meaning of S5.4.3 if it is resealed after initial opening.

I enclose copies of both notices as they appeared in the Federal Register.

Yours truly,

Enclosure

July 27, 1973

National Highway Traffic Safety Administration -- Office of Chief Council,

Attention: Larry Schneider

Dear Mr. Schneider:

I am a member of the Transportation Products Division Executive Board of the Chemical Specialties Manufacturers Association. As a member also of the Brake Fluid Committee, I have been asked to determine the following information from your office. We need an interpretation of the specific meaning of the wording of the Federal Register, Volume 38, Friday, May 18, 1973, page 13017, paragraph S 5.4 regarding master cylinder reservoirs specifically where the reservoir "must be filled from sealed containers."

There is an apparant conflict with Federal Register Volume 36, June 24, 1971, paragraph S 5.2.1 in the 116 motor vehicle brake fluid standards in brake fluids. This states. "contents of six ounces or more must be in containers with resealable closures."

The conflict with many of our members is if the 116 motor vehicle brake fluids standards requires that the material be packaged in a container with a resealable closure, how does this then fit the wording of the previous Register, Volume 38, that it must be filled from sealed containers?

Is it possible that the Federal Register, Volume 38, is referring to fill from original containers or containers that have been immediately resealed after they are opened and when reused are the same condition as a sealed container?

It is very necessary that our CSMA group have an interpretation from you as to the seeming conflict. Our members need to know exactly how we can comply properly with both of these Federal Register issues.

For my own records, may I please have a copy or a xerox copy of the total wording of each of these Federal Register numbers for presentation to the CSMA Brake Fluid Committee. I would appreciate an early response to this request.

Very truly yours,

C. W. Todd -- Market Supervisor, Fluids, Emulsions and Compounds, Dow Corning

cc: Grace Fay -- National Highway Traffic Safety Admin. Motor Vehicles Program;

Mike Baldwin -- Dow Chemical Company

ID: nht73-3.11

DATE: 01/15/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Eastman Chemical Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 15, 1972, requesting an opinion as to whether certain identification marks and certification statements Eastman Chemical plans to use in marketing Uvex plastic sheet will conform to Standard No. 205, "Glazing Materials", as amended November 11, 1972 (37 F.R. 24035), and to section 114 of the National Traffic and Motor Vehicle Safety Act, which requires the certification of motor vehicles and equipment as conforming to applicable standards. You submit two sample markings: one for use by Eastman when it sells that material to further manufacturers, whom you refer to as "fabricators", and one for use by persons other than Eastman. Similarly, you submit two certification statements, one for use by Eastman, and the other for use by its customers.

Based upon our previous dealings with Eastman regarding this product, it does not seem to us that a person other than Eastman Chemical can be considered the "fabricator" of Uvex sheet. The term "fabricate", which is used along with "laminate and temper" to distinguish prime glazing material manufacturers from other manufacturers, is used in the standard in its ordinary dictionary meaning, which we consider to be "manufactures" or "creates". Accordingly, we have assumed Eastman to be the prime manufacturer of the material in answering the questions you raise.

The markings which you indicate will be used by Eastman will conform to the requirements of paragraph S6.1 of Standard No. 205 (assuming the letters and numbers conform to the size requirements of Section 6 of ANS Z26). If the material is to be used as a component of a specific motor vehicle or camper Eastman would be required, after April 1, 1973, to conform to paragraph S6.2 as well, by including in the mark Eastman's assigned DOT code number.

The label stamp you will supply to your customers will conform to the requirements of S6.4.

With respect to the statements you plan to use for certification purposes, we believe them to be unnecessarily ambiguous, and therefore to be of doubtful legal effect in meeting the certification requirement. It is the responsibility of Eastman to certify the conformity of the product to the standard. The basis for that certification is the manufacturer's entire process from design to final production. Tests which show that the material conforms are only one factor in the situation, and reference to them in the certification statement is inappropriate. We feel similarly with respect to your statement that you certify the material as meeting "high manufacturing standards". We recommend you certify with the statement, "This material conforms to all applicable Federal motor vehicle safety standards." In cases where the material will be altered by other manufacturers, they can, where possible, allow this label to remain in place, or affix a new label with the same statement.

ID: nht75-6.15

DATE: 10/29/75

FROM: AUTHOR UNAVAILABLE; John G. Haviland; NHTSA

TO: Laird E. Johnston -- General Motors Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Free Sliding Latch With Tension Relieving Feature

Laird E. Johnston ASE - Engineering Staff

The following comments are in reference to your question concerning whether existing safety standards allow a shoulder belt tension relieving feature on a single loop three point belt system having a free sliding (non-cinching) latch.

GM Legal Staff has been consulted concerning interpretation of the present wording in MVSS 203, Section S7.1.1 (Attachment 1) and proposed amendment Docket 74-32 Notice 1 (Attachment 2). Legal Staff and ASE agree that:

a) The current MVSS 203 does not clearly prohibit the use of a free-sliding latch plate with a shoulder belt tension relieving device but the NHTSA interprets MVSS 208 as prohibiting such a system (see Attachment 3), and

b) A proposed amendment to MVSS 208 Docket 74-32 Notice 1, does clearly limit the use of comfort devices to the upper portion of the seat belt assembly - the lap belt portion must remain individually adjustable (i.e. introducing slack into the shoulder belt should not affect the lap portion of the assembly).

In our response to Docket 74-32 Notice 1 (Attachment 4), General Motors agreed that devices to relieve tension should not be used on systems permitting inadvertent misadjustment.

ASE also has reservations about the impact performance of such a system both for adult occupants and when used in conjunction with child seats. Although limited sled tests of one such system resulted in no submarining with up to three inches of slack in the lap belt, there is no assurance that occupants would wear these systems correctly or that all similar belt configurations would perform in this manner. Additionally, GM only recommends the use of the child seat in 1968-1975 domestic made vehicles. All of these vehicles have a lap belt that permits lap belt tension independent of the shoulder belt. Present thoughts are that a separate lap belt tension holding clip will have to be supplied with the child seat if GM were to recommend its usage with a free-sliding latch single loop system.

One compromise you may wish to consider is the use of a friction device on the free sliding latch that would allow free belt transfer from the lap belt to the shoulder but hold minimal lap belt tension, possibly five to ten pounds. This should satisfy the NHTSA but would still pose some problem with improper child seat usage. Another solution, which you are aware of, is providing low shoulder belt tension thus reducing the need for a tension relieving device. A one-way cinching latch is the ideal solution to the performance and compliance questions.

If we can be of any further assistance, please let us know.

(original signed by) John G. Haviland Collision Protection/Restraints Automotive Safety Engineering JGH/rk

Attachments (4)

cc: G. F. Ball E. E. Conner T. G. Wingblad