Interpretation ID: 86-2.40
TYPE: INTERPRETATION-NHTSA
DATE: 04/24/86
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: I. Levy -- B.P.T. Leisure International Ltd.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. I. Levy B.P.T. Leisure International Ltd. 3/4 Portland Street London, WIN 56G ENGLAND
Thank You for your letter of January 11, 1984, concerning the effect of our regulations on a product you may export to the United States. I hope the following discussion answers your questions.
The product, which you call a "Klunk-Klip" safety belt comfort device, consists of a plastic device which attaches to the upper torso belt anchorage. A belt user can then pull the webbing through the open wedge and close the 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 or the agency discover in your product. Those responsibilities are set out in sections 151-160 of the National Traffic and Motor Vehicle Safety Act. I have enclosed an information sheet on our defect and other regulations for your review.
If you have any further questions, please let me know.
Sincerely,
Original Signed By
Erika Z. Jones Chief Counsel Enclosure
Your Ref.
Our Ref. IL/MN
Date: 14th January 1986
Department of Transportation 400 7th Street, SW Washington D.C., 20590 United States of America
Dear Sirs,
We are endeavouring to export to the United States an attachment which fits into the seatbelt of a motor vehicle and provides the possibility of the adjustment to heighten the comfort level of the wearer.
In order that you may understand exactly what is meant by the above, we enclose herewith a diagram together with the instructions for this item.
We should be most obliged if you could confirm to us that his item would not be excluded from use and does not violate any present Federal Safety Regulations which are in force.
We look forward to hearing from you in this matter.
Yours faithfully, for BPT LEISURE INTERNATIONAL LTD.
I Levy
The KLUNK KLIP* attachment can be used on most cars fitted with automatic (self-retracting) seat belts, where the seatbelt anchor point on the door pillar is similar to the above diagram. (It is not suitable for cars with recessed mountings).
It is designed to provide a personal adjustment which was previously only possible with static-type belts.
KLUNK-KLIP is designed for those who find seatbelts uncomfortable or even claustrophobic to wear. The use of KLUNK-KLIP avoids the tightness and tension so disliked by the users of automatic seatbelts. Ladies in particular appreciate the improved comfort when using KLUNK-KLIP.
KLUNK-KLIP does not effect the efficient working of the automatic seat belt.
TO FIT (see above illustration)
Remove the rotary wedge (A) by easing the two lugs (B) apart. Fit the hook part over the anchor bolt (C) on door pillar. Refit the wedge (A) as shown in diagram. The wedge should now lift freely to grip the belt.
TO USE
Fasten seat belt in the usual way.
Place one hand flat on chest beneath belt. This will extend the belt sufficiently to relieve the tension.
Lift wedge to lock belt.
You may now drive freely without tension. Any movement of the body or slight pull will release the KLIP and the belt will return to its retracted position.
Each time the belt is used the KLUNK-KLIP should be set as advised above, being careful to avoid introducing excessive slack.