Interpretation ID: aiam2106
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 October 1, 1975, questions whether Type 2 seat belt assembly with non-detachable shoulder belt (1) may be labeled in accordance with S4.1(k) of Standard No. 209, *Seat Belt Assemblies*, in only one location on either the upper torso or pelvic portion (A-I), (2) must be submitted (with the labeling modification) to a test laboratory or other facility as the basis for continued certification to the standard (A-II), (3) must be retested after a change is made to webbing length as the basis for continued certification to the standard (B-I), and (4), if testing is not required, must be submitted to a test laboratory or other facility as the basis for continued certification to the standard (B-II).; One label on either portion of a Type 2 seat belt assembly wit non-detachable shoulder belt may be used to satisfy the requirement of S4.1(k) of Standard No. 209.; The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 e seq.) requires manufacturers,(sic) to produce products covered by standards in compliance with those standards, as set by the National Highway Traffic Safety Administration (NHTSA), and to certify the products. It leaves the choice of testing methods up to the manufacturers. The NHTSA does not require retesting or submission to test laboratories as a basis for certification. A company like yours is free to choose any method that assures you that your products will conform if they are tested by the NHTSA as specified in the standard. This may take the form of tests, engineering calculations, or other means necessary to provide this assurance.; The answers given above pertain only to the Federal requirements fo seat belts. It may be necessary to contact other regulatory authorities as to the effect of these changes under their regulations.; Sincerely, Frank A. Berndt, Acting Chief Counsel