Interpretation ID: aiam2301
Ph.D.
Engineering Psychologist
304 Hill Drive
State College
PA 16801;
Dear Dr. Olsen: This responds to your March 26, 1976, question whether Federal moto vehicle safety standards would apply to the replacement of seat belt webbing in seat belt assemblies to refurbish deteriorated portions of the webbing.; The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381, e seq.) authorizes the National Highway Traffic Safety Administration (NHTSA) to regulate the manufacture, but not the repair, of motor vehicle equipment such as seat belt assemblies. The NHTSA has issued a standard that applies to the manufacture and sale of seat belt assemblies (Standard No. 209, *Seat Belt Assemblies* (49 CFR 571.209)). In enforcement of this standard, the agency must, therefore, distinguish between what is repair' and what is manufacture' of a seat belt assembly.; You intend to accept existing seat belt assemblies from vehicle owner and to replace the webbing portions, reusing the hardware that is recovered from the existing assembly. From this description, the agency considers that the operation would constitute the manufacture of a seat belt assembly subject to the requirements of Standard No. 209. The majority of the assembled product would be new material, and the manufacturing operations involved in cutting and sewing constitute significant factors in the construction of the finished product.; Sincerely, Frank Berndt, Acting Chief Counsel