Interpretation ID: aiam3908
Ms. Estelle Friedman
Uncanny Products
5904 Edinger Avenue
Huntington Beach
CA 92649;
Dear Ms. Roger: This responds to your letter of January 21, 1985, concerning a aftermarket product you manufacture. The product, which you call the 'Uncanny Seat Belt Comfort Control Belt,' consists of a strap which can be fastened around the shoulder and lap webbing of a lap- shoulder safety belt near the buckle. A belt user can then slide the strap along the webbing, thus causing the shoulder portion of the belt to move away from the person's neck and make the belt more comfortable to wear. You asked for the agency to approve, disapprove, or endorse your product so that it can be advertised in certain magazines.; No such agency action is necessary before you advertise your product Further, the agency does not have the authority to approve or endorse items of motor vehicle equipment, such as your device. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards.; Your particular aftermarket product is not covered by any of our safet belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your products. Those responsibilities are set out in sections 1411-1420 of the National Traffic and Motor Vehicle Safety Act, a copy of which is enclosed.; The agency is concerned that a belted occupant could use your produc to reduce the effectiveness of the upper torso belt by moving the belt so close to the edge of the shoulder that the occupant could rotate out of the upper torso belt in a crash. Likewise, your product could be used to introduce excessive slack in the upper torso belt, which would also reduce its effectiveness. We urge you to include a warning in your instructions to advise belt users about the proper use of your product.; I am returning the sample of your product that you enclosed with you letter. If you have any further questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel