Interpretation ID: nht91-6.51

DATE: November 1, 1991

FROM: William E. Kenyon -- Mr. K's Original Headsaver, Patented Restraint Systems

TO: Chief Counsel, NHTSA

TITLE: Mr. K Headsaver (A Head Restraint System for Pickup Trucks)

ATTACHMT: Attached to letter dated 1/15/92 from Paul Jackson Rice to William E. Kenyon (A39; Std. 202)

TEXT:

Pursuant to a phone discussion with Dr. Carl C. Clark, NRD-12, I was advised to send this letter and Affidavit to your attention. We are the manufacturers of a universal, retrofit head restraint system for pickup trucks with bench seats.

Our head restraint has been on the market for four years and meets or exceeds the federal Standard 202 as shown in the enclosed Affidavit of Testing. We would like our product to be federally approved as an after-market safety product.

Please advise us at your earliest convenience if we have not met all requirements.

Attachment

AFFIDAVIT Confirmation of Test Results of Mr. K HeadSaver (A head restraint system for pickup trucks)

COUNTY OF MARICOPA) ) STATE OF ARIZONA )

I, William E. Kenyon, the undersigned, being first duly sworn, under oath, depose and say:

1. That I am the inventor and patent holder of US Patent #4,869,448, a Head Restraint for Vehicles.

2. That on the 29th day of October, 1991, a test was conducted of the Mr. K HeadSaver in the presence of your affiant and two witnesses.

3. That the head restraint used in the test is, in fact, the head restraint known as the Mr. K HeadSaver; that the manufacturer has warranted to your affiant that the head restraint does comply with Standard 202.

4. That this test is being conducted to show that the product known as the Mr. K Headsaver is in compliance with the 202 Standard and that said headrest meets the qualifications to be a federally approved aftermarket safety product.

5. That when installed, the headrest is 27.5 inches in height; the two end pads are 11" x 8-1/2"; pads are filled with extra- firm, high-density impact foam and covered with fabric.

6. That the following test was conducted:

US49, S571.101 Standard No. 202; Head restraints, S4.3(b):

(1) The top of the head restraint is 27.5 inches above the seating reference point.

(2) When measured either 2.5 inches below the top of the head restraint or 25 inches above the seating reference point, the lateral width of the head restraint is not less than 10 inches for use with bench seats.

(3) There was no displacement of the rearmost portion of the head form.

S5.2 Compliance with S4.3(b):

a. A test device was placed in accordance with (a).

b. A reference line was established.

C. A 9 inch diameter, 16 lb. spherical head form was used in producing a moment greater than 3,300 in.

lbs.

d. A Load was gradually increased to exceed 200 pounds.

The Mr. K HeadSaver was installed in a 1985 S10 Chevrolet pickup cut-a-way, with bench seats, for testing purposes.

Inspection of the headrest after testing found it to be in the same condition as before testing.

DATED this 29 day of October, 1991.

William E. Kenyon (Notary information is omitted)