Interpretation ID: aiam1525
Manager
Emissions
Safety & Development
Volkswagen of America
Inc.
Englewood Cliffs
NJ 07632;
Dear Mr. Kennebeck: This responds to your May 22, 1974, question whether Volkswagen' passive belt system may be equipped with a 'comfort clip,' and whether an optional Type I lap belt may be offered in conjunction with the passive system. Your passive system consists of an upper torso restraint and, in place of a lap belt, knee padding under the dashboard.; A vehicle which satisfies Standard No. 208, *Occupant cras protection*, may be equipped, at the option of the manufacturer, with additional safety belts which conform to Standard No. 209, *Seat belt assemblies*. Additional belts, like any required belt, must conform to the S7.2 requirements for latch mechanisms.; >>>S7.2 *Latch mechanism*. A seat belt assembly installed in passenger car shall have a latch mechanism --; (a) Whose components are accessible to a seated occupant in both th stowed and operational positions,; (b) That releases both the upper torso restraint and the lap bel simultaneously, if the assembly has a lap belt and an upper torso restraint that require unlatching for release of the occupant, and; (c) That releases at a single point by a push-button action.<<< This requirement assures that the occupant crash protection provide under Standard No. 208 is not diminished by a complicated and slow series of belt latch mechanisms which could otherwise be introduced into the vehicle.; Volkswagens' passive upper torso restraint and a separate active la belt do not violate S7.2(b) in combination. Simultaneous release is required only 'if the assembly has a lap belt and an upper torso restraint that require unlatching for release of the occupant.' As described, Volkswagen's upper torso restraint does not require unlatching for release of the occupant.; With regard to our regulation of 'comfort clips', we approved the us of a clip in a March 9, 1973, letter to General Motors, to relieve belt tension in limited circumstances. A copy of that letter is enclosed. In that case, the lap belt provided could be independently and firmly adjusted to limit occupant movement, providing protection in the event of lateral and rollover crashes. Until we have further details on the functioning of the Volkswagen clips, however, which we urge you to submit, we are unable to determine whether it would conform to the adjustment requirements of S7.1.1 of Standard No. 208, *Occupant crash protection*.; Sincerely, Lawrence R. Schneider, Chief Counsel