Interpretation ID: aiam4216
Executive Vice President & Chief Operating Officer
Nissan Research & Development
Inc.
P.O. Box 8650
Ann Arbor
MI 48104;
Dear Mr. Maeda: Thank you for your letter of July 30, 1986, concerning the safety bel contact force provision of the comfort and convenience requirements of Standard No. 208, *Occupant Crash Protection*. You explained that Nissan is concerned about the requirements of S10.6 contained in the final rule published on March 21, 1986. You noted that a sentence contained in the notice of proposed rulemaking was not included in the final rule and asked whether this sentence had been inadvertently omitted.; In addition, you asked the agency to clarify the effect of the omitte sentence on belt systems which have less than 12 inches of webbing stored in the retractor once the belt is placed around the test dummy. You explained that Nissan considers the purpose of the requirement in the omitted sentence to be elimination of belt drag before measuring the belt contact force. You explained that requiring a manufacturer to pull 12 inches of webbing from the retractor before the belt contact test would require redesign of Nissan's belt systems, even though those systems meet the safety belt adjustment requirements of the standard. You asked the agency to provide that a manufacturer can pull the maximum allowable length of the belt stored on the retractor, rather than 12 inches, prior to conducting the belt contact force test.; As explained in the enclosed Federal Register notice, the sentenc contained in the notice of proposed rulemaking was inadvertently omitted from the final rule. NHTSA agrees that the purpose of the belt webbing pull requirement can be adequately met by pulling out the maximum allowable amount of the belt, when the belt has less than 12 inches of available additional webbbing (sic). Pulling the belt in this way will ensure that the belt retractor is working and webbing drag is reduced. Thus, the agency has modified the requirement to provide that prior to measuring the belt contact force the agency will pull out 12 inches of webbing or the maximum amount of webbing available when the maximum amount is less than 12 inches.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel