Interpretation ID: aiam2348
Vice President
Public Responsibility and Consumer Affairs
Chrysler Corporation
P. O. Box 1910
Detroit
MI 48231;
Dear Mr. Terry: This is in response to your March 16, 1976, request for assurance tha paragraph S4.3(f) of Standard No. 209, *Seat Belt Assemblies*, does not apply to the mechanism in a continuous loop seat belt system that limits (prevents) transfer of belt webbing from the shoulder to the pelvic portion of the belt when the buckle is engaged. Your letter recommended that Standard No. 209 be amended to specifically exempt such adjustment mechanisms from the requirements of paragraph 4.3(f) or that separate, appropriate requirements for those mechanisms be established.; The National Highway Traffic Safety Administration (NHTSA) ha determined that the adjustment mechanism described in your letter is not a tilt lock' within the meaning of paragraph S4.3(f) of the standard, although the two mechanisms are superficially similar. Therefore, this mechanism does not have to comply with the requirements of paragraph S4.3(f).; We would like to emphasize our comments to you of June 13, 1975 regarding the requirement that a continuous loop assembly have a sufficiently low level of friction at the buckle mechanism to ensure that the lap portion of the belt is automatically adjustable. The friction in the buckle must be low enough that the normal motion of the occupant against the shoulder belt tightens the lap portion of the belt to prevent excessive slack and possible submarining of the occupant.; The NHTSA has also considered Chrysler's petition to amend Standard No 209 to establish separate appropriate requirements' for the adjustment mechanism in question and decided that it should be granted. A notice proposing such modifications of the standard is anticipated in the near future.; As you are aware, the commencement of a rulemaking proceeding does no signify that the rule in question will necessarily be issued. A decision concerning the issuance of a rule is made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;