Interpretation ID: aiam3711
Manager of Engineering
Isuzu Motors America
Inc.
21415 Civic Center Drive
Southfield
MI 48076;
Dear Mr. Tokunaga: This responds to your letter of May 26, 1983, asking whether continuous loop seat belt system you are considering would comply with the requirements of Safety Standard No. 208, *Occupant Crash Protection*.; Continuous seat belt systems are permissible under Safety Standard No 208 if certain conditions are met. Paragraph S7.1.1 of that standard requires adjustment of the lap belt portion of Type 2 belts 'by means of an emergency locking or automatic-locking retractor' and adjustment in most cases of the upper torso portion 'by means of an emergency-locking retractor.' The language permits some single retractor, continuous loop systems if the single retractor does 'automatically adjust' the tension of the lap belt portion to prevent excessive slack. Because of the danger of submarining due to a slack lap belt, the agency has restricted the acceptability of continuous loop systems under S7.1.1.; To conform to the requirements, the buckle of the assembly must b designed by the manufacturer with a sufficiently low level of friction to qualify the lap portion as automatically adjusting. This means that when the belt is buckled by the vehicle occupant, the retractor must be capable of cinching the lap belt tightly around the occupants, pelvic area (regardless of where the buckle tongue is located along the belt webbing when the belt is fastened). The friction in the buckle tongue cannot be so high that the occupant must manually pull the belt webbing through the tongue to tighten the lap belt.; We note your statement that the one-way frictional bar included in you contemplated belt design 'permits the wearer to fasten the lap belt more tightly than the tension from the ELR usually achieves.' This is certainly permissible, provided the ELR does tighten the belt sufficiently for the lap belt to be considered automatically adjustable. You will have to make this determination, however. Please note that it is the manufacturer's responsibility to determine whether or not its belt design complies with the standard. The agency does not offer advance approval of any motor vehicle or piece of motor vehicle equipment. Further, the agency does not make determination of compliance of a vehicle or item of equipment prior to the manufacturer's certification of that vehicle or equipment.; I hope this clarification will be of help to you in your design plans. Sincerely, Frank Berndt, Chief Counsel