Interpretation ID: aiam3869
Laboratory Supervisor
American Safety Equipment Corporation
Corporate Quality Assurance & Reliability
11441 Bradley Avenue
Pacoima
CA 91331;
Dear Mr. Apuzzo: This responds to your letter of September 25, 1984, to Mr William Smit which was forwarded to this office for reply. You asked several questions concerning the requirements of section 5.2(b) of Standard No. 209, *Seat Belt Assemblies*, which are answered below.; Your first question concerns the conditioning requirements of Procedur D of ASTM D756-78, which is incorporated by reference in Standard No. 209. You pointed out that the agency's compliance test procedure (document TP-209- 01) calls for conditioning for 24 hours, while ASTM D756-78 calls for conditioning for not less than 40 hours. The conditioning requirement incorporated by reference in Standard No. 209 is the correct version and is the method which will be used by the agency. The version of the agency's compliance test procedure you cite was prepared before the June 30, 1983, amendments to Standard No. 208 which adopted ASTM D756-78. The compliance test procedure will be revised to specify not less than 40 hours of conditioning.; Your second question concerned the requirement of Procedure D that par of the testing be done in a sealed container placed over water in a 176 degrees F recirculating oven. The test calls for maintaining 'a humid atmosphere' in the sealed container. You asked what percentage of humidity should be maintained.; You are correct that Procedure D does not specify the specifi percentage of humidity. However, section 6.2, *Test conditions*, of ASTM D756-78 specifies that the tests should be conducted in the Standard Laboratory Atmosphere of 23 plus or minus 2 degrees C and 50 plus or minus 5% relative humidity 'unless otherwise specified in the test methods or in this practice.' Since Procedure D does not specify a humidity level, the agency will use the humidity of 50 plus or minus 5% relative humidity specified in section 6.2.; You also asked whether a recirculating chamber can be used to conduc the test. The test equipment specified in the standard is the equipment the agency will use in its compliance tests. Manufacturers are free to use other test equipment as long as they can make a good faith certification that their product complies with the requirements set in the standard.; Your final question concerns another difference between ASTM D756-7 and the compliance test procedure. As explained above, the version of the compliance test procedure you cite was prepared before the June 1983 amendments to the standard and will be updated to cite the requirements adopted in those amendments. You asked for a description of 'dessicator'(sic) and 'uncharged dessicator'(sic) referred to in ASTM D756-78. A dessicator (sic) is a closed container that has a drying agent to absorb moisture. An 'uncharged dessicator'(sic) is a dessicator (sic) that does not have a test specimen in it.; In addition, you asked whether you could use an environmental chambe rather than a dessicator (sic). As discussed previously, the test procedures and equipment specified in the standard are the procedures and equipment which the agency will use in its compliance tests. Manufacturers are free to use other test equipment and procedures as long as they can make a good faith certification that their product complies with the requirements set in the standard.; If you have any other questions, please let me know. Sincerely, Frank Berndt, Chief Counsel