Interpretation ID: aiam0311
2134 Springdale Drive
Columbus
GA 31906;
Dear Mrs. Rothschild: This is in response to your letter of January 29, 1971, in which yo inquired whether a particular safety belt system, described in a patent application, would qualify as a 'passive restraint' within the meaning of the Occupant Crash Protection standard. We have delayed an answer to your inquiry, pending issuance of amendments to that standard that were made on March 10, 1971 (36 F.R. 4600), in response to petitions for reconsideration.; You describe your system as one in which 'you have to manually pivo the belt in order to take your seat in the car'. From that point on, however, everything is automatic . . .' The issue, then is whether such a system is a 'means that require[s] no action by vehicle occupants,' in the words of the standard.; Our position is that such a system would not meet the above requiremen of the standard, since it is a system that does require action by the occupant, *i.e.*, pivoting the belt. By 'no action' is meant just that--no action by occupants other than would be required if the protective system were not present in the vehicle. We recognize that in some cases, the action that is required may be relatively slight. In terms of regulatory categories, however, we consider it important to distinguish 'no-action' systems from 'forced-action' systems, of which the most commonly discussed example is the seat belt with an ignition interlock. Your system appears clearly to come within the forced-action category.; Please note that although we are glad to provide interpretations i response to specific questions such as yours, the National Highway Traffic Safety Administration generally does not issue overall 'approvals' of any vehicle or motor vehicle equipment, with respect to conformity with the standards.; Sincerely, Douglas W. Toms, Acting Administrator