Interpretation ID: aiam1305
Porsche
Research and Development
8124 Billow Vista Drive
Playa Del Rey
CA 90291;
Dear Mr. Meier: Thank you for your letter of September 2, 1973, to Mr. Jame Hofferberth of my staff, inquiring if a particular safety belt system which is illustrated in your enclosures meets the criteria for a passive restraint system.; The interpretation of a passive restraint system published in th Federal Register on May 4, 1971 (36 F.R. 8296) was:; >>>'The concept of an occupant protection system that requires 'n action by vehicle occupants' as used in Standard No. 208 is intended to designate a system that requires no action other than would be required if the protective system were not present in the vehicle.'<<<; With respect to your belt system, a requirement for placing the belt i the storage holder when leaving the car would be considered 'action' and not permitted under the above interpretation of a passive system. However, if the belt system could be entered and exited with essentially no action, in the event the storage holder was not used, automatically releasing 'convenience' holder would not compromise the belt's qualification as a passive system.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;