Interpretation ID: 86-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 02/07/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Lewis Quetel

TITLE: FMVSS INTERPRETATION

TEXT:

February 7, 1986 Mr. Lewis Quetel PMI Inc. 1391 Wright Blvd. Schaumburg, IL 60193 Dear Mr. Quetel: This is in response to your telephone call on October 22, 1985, to Robert Nelson of this agency asking how our regulations would affect a product you intend to sell. The product, which you call a "Kumfi-Klip" safety belt comfort device, consists of a plastic device which attached to the upper torso belt anchorage. A belt user can then pull the webbing through the open wedge to introduce slack into the shoulder portion of the belt. As background information, let me explain that the agency does not have the authority to approve or endorse items of motor vehicle equipment, such as your device. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards. Your particular aftermarket product is not covered by any of our safety belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your product. Those responsibilities are set out in sections 152-160 of the National Traffic and Motor Vehicle Safety Act. I have enclosed an information sheet on our defect and other regulations for your review. The agency is concerned that a belted occupant could inadvertently use your product to introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of the belt. The instructions you provide with the "Kumfi-Klip" do warn users not to introduce excessive slack, but the instructions provide no information to guide a user on what is an excessive amount of slack. We encourage you to provide more detailed guidance. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosure