Interpretation ID: 1982-1.35

TYPE: INTERPRETATION-NHTSA

DATE: 03/30/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of January 5, 1982, concerning Standard No. 209, Seat Belt Assemblies. You are correct that my letter of June 1, 1981, should have referred to S5.1(d) rather than S5.2(d). Likewise, I assume that where you have referred to sections 4.1(d), (e), and (f) in your letter, you mean sections 4.2(d), (e), and (f).

My letter of June 1, 1981, was not meant as a definitive statement of what specific action the agency intends to take on Standard No. 209, but rather to acknowledge that the standard's provision on abrasion needs modification. The notice of proposed rulemaking for this action will allow you and other interested parties to comment on what precise changes you think should be made to the standard. I am placing a copy of your letter with its current suggestions in the public docket.

Sincerely,

ATTACH.

January 5, 1982

FRANK BERNDT -- CHIEF COUNSEL, US Department of Transportation, NHTSA

Dear Sir

With reference to your letter to us of June 1 1981, I assume that where you have referred to Clause 5.2(d) in your letter you mean 5.1(d).

You state in your letter that Clause 5.1(d) will be amended and that strength after abrasion will be compared to the breaking strength specified in Clause 4.2(b). For consistency, Clause 5.1(e) and 5.1(f) would also need to be altered.

I would suggest that it is not Clause 5.1(d) that needs changing, it is 4.1(d) to bring it into line with 4.1 (e) and (f). Clauses 5.1(d)(e) and (f) need no change. Additionally I feel sure that the minimum breaking strengths listed in 4.2(b) should remain, even after abrasion, light or micro-organisms test and that clause 4.2(d) might finish . . . . shall have a breaking strength of not less than 75% of the strength before abrasion and greater than the appropriate strength listed in @@ 4.2(b). Clause 4.2(e) might read . . . . have a breaking strength of not less than 60% of the strength before exposure to the carbon arc and greater than the appropriate strength listed in Clause 4.2(b). Clause 4.2(f) might finish . . . . have a breaking strength not less than 85% of the strength before subjected to micro-organisms and greater than the appropriate strength listed in @@ 4.2(b).

Yours faithfully

J E BINGHAM -- SENIOR TEST ENGINEER, BRITISH STANDARDS INSTITUTION