Interpretation ID: aiam1458
Vice President
Corporate Development
American Safety Equipment Corporation
16055 Ventura Boulevard
Encino
CA 91316;
Dear Mr. Bradford: This is in reply to your letter of August 3, 1973, petitioning fo amendment to paragraphs S4.9 and S5.3.1 of Motor Vehicle Safety Standard No. 213 which would allow the use of a buckle release mechanism design that requires, before release, some foreshortening of the belt system to reduce the load on the release mechanism. This design cannot meet the existing requirements of S4.9 of Standard No. 213 with the device under load. We wrote to you on August 20, 1973, and on December 17, 1973, requesting additional data. We have not received a response from you to either letter.; We have decided that your petition should be denied. Our objection t the design you wish to employ is that it cannot be released when the belt restraint system is under load. The NHTSA believes, and has adopted its position in Standard No. 213, that a fundamental safety requirement for any occupant restraint release mechanism is the ability to release when it is under a load imposed by the weight of the occupant. In many vehicle crashes restraint systems may be loaded in this fashion when occupants must be removed.; We do not disagree with your argument that mechanisms which releas under load may more readily be released by children when release is undesirable. We believe the greater safety problem, however, is presented by designs which are difficult to operate because they require a prior unloading of the release mechanism. These systems may not be able to be released, even by adults, in crash situations. Data we have received indicates substantial difficulty in the ability of adults to release a child from a child seat in situations (total darkness) simulating emergencies. The study in question has been conducted by the National Swedish Road and Traffic Research Institute and is on file in Docket No. 2-15.; Moreover, we believe buckle release mechanisms should be operable b older child occupants, particularly in situations such as in upside-down configurations where a load is imposed on the mechanism. This purpose is met by the existing requirements of the standard but would not be met were we to grant your petition.; In your petition you argue that even a lower release force does no necessarily mean that the occupant will be able to escape easily from the restraint system. While this may be true, as no requirements are specified in Standard No. 213 regarding ease of belt removal, it is not a justification for increasing the difficulty of operating the buckle release mechanism.; Sincerely, James B. Gregory, Administrator