Interpretation ID: nht88-2.82

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88

FROM: WILLIAM E. LAWLER -- SPECIFICATIONS MANAGER INDIANA MILLS AND MANUFACTURING INC

TO: ERICA Z. JONES, -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 EST TO WILLIAM E. LAWLER FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 208, STANDARD 209

TEXT: Dear Chief Counsel:

The publication of the final rule (53FR25337) pertaining to seat belts in trucks, buses, and multipurpose passenger vehicles over 10,000 pounds GVWR (FMVSS 208) on July 5, 1988, has prompted us to write to you.

Our discussions with engineers in the Crashworthiness Division since August 1985 have centered around our product called the "Komfort-Lok." This patented device has been used in the field for over two years with good customer satisfaction. Unlike the wor ding of the recent final rule, the Komfort-Lok is not a retractor but rather a mechanism external to the retractor itself but integral with the retractor but which eliminates webbing movement and thus eliminates cinching. The Komfort-Lok works in conjunc tion with an automatic locking retractor (ALR) regardless of the amount of webbing retracted between locking points at 75 percent webbing extension.

Because the Komfort-Lok is designed to work effectively with any ALR, we are writing to your office to request an official opinion permitting the use of any FMVSS 209-compliant-ALR in conjunction with the Indiana Mills Komfort-Lok as a complete retractor system to satisfy the requirements of FMVSS 208, Paragraphs S4.3.2.2 and S4.4.2.2 as stated in the 7-5-88 final rule.

We appreciate your attention to our request.

If you have any questions, please contact me. Thank you.

Sincerely,