Interpretation ID: 86-5.12

TYPE: INTERPRETATION-NHTSA

DATE: 09/04/86

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for Erika Z. Jones; NHTSA

TO: Mr. Binichi Doi

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Binichi Doi NSK Representative Office P.O. Box 1507 Ann Arbor, MI 18106

Dear Mr. Doi:

Thank you for your letters concerning the automatic safety belt warning requirements of Standard No. 208, Occupant Crash Protection. You explained in your letters and in conversations with Stephen Oesch of my staff that NSK-Warner is developing a motorized automatic belt system that would be equipped with an emergency release buckle. You also plan to provide voluntarily a manual lap belt with the system. I regret the delay in our response and hope the following discussion answers your questions.

You first asked whether you can use an automatic belt warning system for your motorized belt system which would activate an audible signal under the following conditions: (1) the vehicle ignition is moved to the "on" or "start" position (2) the motorized automatic belt is not fastened and (3) the motorized belt has not reached its locked protective position. As explained below, such a system is permissible, but is not required by the standard.

S4.5.3 of the standard sets forth the requirements for automatic belt systems. S4.5.3.3(b) requires a motorized automatic belt system to have a warning system that sounds an audible signal for between 4 and 8 seconds if the automatic belt latchplate is not fastened or the emergency release is activated and the ignition is in the "on" or "start" position. However, S4.5.3.3(b) does not require the audible signal to be activated until a motorized belt has reached its locked protective mode. Your system would activate the audible signal while the motorized belt is moving to its locked position and it would sound again once it has reached its locked position. Thus, NSK is voluntarily providing a warning that is not required by the standard. As stated in the preamble to the November 6, 1985 notice (50 FR 16063) adopting the new warning system requirements for automatic safety belts, a manufacturer is free to provide additional features as long as the features required by the standard still continue to comply with all the applicable performance requirements. Thus, as long as the warning system provides the warning required by S4.5.3.3(b), NSK may voluntarily provide additional warnings as well.

You also said that NSK is planning to provide an automatic belt warning system for both the driver's and right front passenger's seating position. S4.5.3.3(b) requires an automatic belt warning system only at the left front designated seating position. Thus, the agency would consider the passenger side warning system as a voluntary system, which you may install as long as the driver'a warning system will continue to meet all applicable requirements.

You also asked several questions about when and how long the audible and light warning are to be activated. Specifically you asked whether the warnings must be reactivated when the tongue of an emergency release buckle (referred to as an ERB in your letter) is inserted into the latch mechanism and then removed again within a few seconds. You also asked if the warnings can be de-activated by insertion of the tongue of the emergency release buckle before expiration of the 4-8 seconds specification for the audible warning and the 60 second specification for activation of the warning light. As explained below, if the emergency release buckle has been fastened and then unfastened after a few seconds, the warning does not have to be re-activated until after the ignition switch has been turned "off" and then turned again to the "on" or "start" position. Also if the warning begins to activate and then the emergency release buckle is fastened, the warning may immediately be cancelled and thus does not have to be activated for the full time period specified in the standard.

S4.5.3.3(b) provides that the audible warning and the warning light are to be activated only under certain conditions. Thus, the standard provides that the warnings are to be activated when condition A (the ignition switch is in the "on" or "start" position) exists simultaneously with one of the other conditions, such as condition B (the emergency release buckle not being fastened). Thus, if the emergency release buckle is unfastened and, at the same time, the ignition is in the "on" or "start" position, the warnings must activate. However, if the ignition is not in the "on" or "start" position and the emergency buckle is released, then the warnings do not have to be activated. The agency has previously said, such as in a June 17, 1981 letter to Chrysler, that the warning is not to activate if the safety belt is buckled. Thus, the warning may be cancelled once the emergency release buckle is fastened.

Again, I regret the delay in our response. If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

March 10, 1986

NHTSA Room 5219 400 Seventh Street, S.W.

Washington, DC 20590

Stephen L. Oesch Deputy Assistant Chief Counsel For Rulemaking

Subject: Questions Regarding FMVSS 208, 4.5.3.3(b).

Dear Mr. Oesch:

It was nice meeting with you the other day although I walked into your office without prior notice.

Below is a few questions NSK-Warner would like to ask your office, in addition to the previous request for interpretation of rules stated in my letter of February 4, 1986.

1. When conditions A and B exist simultaneously the audible and light warnings are activated. Under the existance of such conditions (say for two seconds), when a tongue of ERB is inserted into and removed from a buckle within a short time.

a) Are warnings (or one of two types of warning) required to be re-activated?

b) Are warnings required for the initially set time, that is, 4-8 seconds for audio-warning and not less than 60 seconds for light-warning after a tongue is inserted into and removed from a buckle during the initial warning activation time periods?

In other words, are the warning(s) needs to be re-activated for a certain length of time after a tongue is inserted into a buckle (this action would eliminate both types of warning) and removed immediately afterward as long as this sequence of events occurs within 4-8 seconds and not less than 60 seconds of initial activation of warnings?

Yet in other words, can the warnings be de-activated before expiration of 4-8 seconds and not less than 60 seconds by insertion of a tongue, for example, and not required to be reactivated at all until ignition switch is turned off once and turned on again?

2. NSK-Warner is considering the implementation of 'Condition B Warning' on the passenger side, also.

In such case, depending on the timing of anchor point reaching protected-mode at anchor-point, audible warning could last for a total of 16 seconds, 8 seconds on drivers side and 8 seconds on passenger side. Does this cause any rule-related problem?

I only hope that above questions sufficiently are clearly stated so that we can receive your kind consideration and response.

Very truly yours,

Binichi Doi NSK Representative

BD/mt

P.S. We would appreciate it if you could combine above with our previous set of questions for your consideration.