Interpretation ID: nht91-2.9

DATE: March 5, 1991

FROM: Binichi Doi -- NSK Representative, NSK Corporation

TO: Mr. Kratzke -- NHTSA, Office of Chief Counsel

TITLE: Re Safety Belt Labelling

ATTACHMT: Attached to letter dated 4-9-91 from Paul Jackson Rice to Binichi Doi (A37; Std. 209)

TEXT:

This request for ruling is per our telephone communication on March 1, 1991. On March 1, you were kind enough to listen to my rather poorly composed explanation of the situation. Briefly, the problem is as follows:

1. NSK's safety belts which in this subject case are symmetrical in construction for LH and RH seats of vehicles in that both are made of the same material/part composition.

2. If these belts go into regular passenger cars for export to this market, the belt for LH seats would have a switch for restraint system display whereas RH belts have no switch, however, the subject vehicle type is that it sometimes is used for mail delivery. In such case RH belts should have the switch also.

3. Model nos. of LH belts and RH belts are different from each other because of presence/nonpresence of the switch. Therefore, if we are to cover the limited case of "mail delivery" applications separately from regular passenger cars we need to prepare two separate labels for RH belts, one showing a model no. indicating a belt with a switch and another without although these belts are exactly the same in all aspects other than the switch.

4. We would like to receive your ruling whether one type label showing both belt model nos. with and without switch can be attached to all RH seat belts shipped from us to our customer, auto manufacturer, who produces this subject model vehicles.

5. As for the necessary identification of belts for mail delivery vehicle applications the presence of a switch on a belt for RH seats should clearly indicate to car manufacturers that it be installed in mail delivery vehicles and as for the test report for certification, which in our case is prepared by the US Testing Lab, it would indicate that the subject RH seat belt would carry a label with two belt model nos., one for a belt with the switch and the other without the switch.

Hoping that the above explanation is sufficient in explaining the reason for our request for your ruling and looking forward to hearing from your office as soon as possible.

P.S. - If further clarification is needed please contact me at 1-800-521-0605 in Ann Arbor, Michigan.