Interpretation ID: aiam2029
Chief of Development & Control Department
Takata Kojyo Co.
Ltd.
No. 10 Mori Bldg. 28
Sakuragawa-Cho Nishikubo Shiba
Minato-Ku Tokyo
Japan 105;
Dear Mr. Masada: This responds to Takata Kojyo's July 28, 1975, question whethe Standard No. 208, *Occupant Crash Protection*, or Standard No. 209,; Seat Belt Assemblies*, prohibits on a 'continuous loop' three-poin belt system the use of a clip between the outboard attachment point of the lap belt portion and the sliding buckle tongue which engages the inboard attachment hardware. The clip is used to prevent the sliding buckle tongue from falling to the floor when the belt system is retracted after use.; Standard No. 209 contains no provision which prohibits use of the clip Section S7.1.1 of Standard No. 208 requires adjustment of the lap belt portion of seat belts 'by means of an emergency-locking or automatic-locking retractor.' In continuous loop systems, the single retractor must meet this adjustment requirement as well as that for the upper torso portion. At this time, the NHTSA has interpreted S7.1.1 to permit the use of clips which restrict movement of the webbing, but a proposal is outstanding that would restrict the use of certain clips to seat belt assemblies that have 'an individually adjustable' lap belt. The language of that proposal is intended to strictly limit the use of clips which restrict webbing movement. In any case, Standard No. 208 does not at this time prevent use of the clip you describe.; It is noted that the clip could be misadjusted so that slack i introduced in the lap belt, permitting submarining in the event of a crash. This problem could be avoided by permanently attaching the clip at a low enough position so that the belt would be automatically adjustable even for a 50th percentile 6 year old child without possibility of misadjustment. This permanent location could presumably still be high enough on the belt to provide for convenient stowage of the belt tongue after use.; Sincerely, Frank A. Berndt, Acting Chief Counsel