Interpretation ID: aiam4193
NSK Representative Office
P.O. Box 1507
Ann Arbor
MI 48106;
Dear Mr. Doi: Thank you for your letters concerning the automatic safety belt warnin requirements of Standard No. 208, *Occupant Crash Protection*. You explained in your letters and in conversations with Stephen Oesch of my staff that NSK-Warner is developing a motorized automatic belt system that would be equipped with an emergency release buckle. You also plan to provide voluntarily a manual lap belt with the system. I regret the delay in our response and hope the following discussion answers your questions.; You first asked whether you can use an automatic belt warning syste for your motorized belt system which would activate an audible signal under the following conditions: (1) the vehicle ignition is moved to the 'on' or 'start' position, (2) the motorized automatic belt is not fastened and (3) the motorized belt has not reached its locked protective position. As explained below, such a system is permissible, but is not required by the standard.; S4.5.3 of the standard sets forth the requirement for automatic bel systems. S4.5.3.3(b) requires a motorized automatic belt system to have a warning system that sounds an audible signal for between 4 and 8 seconds if the automatic belt latchplate is not fastened or the emergency release is activated and the ignition is in the 'on' or 'start' position. However, S4.5.3.3(b) does not require the audible signal to be activated until a motorized belt has reached its locked protective mode. Your system would activate the audible signal while the motorized belt is moving to its locked position and it would sound again once it has reached its locked position. Thus, NSK is voluntarily providing a warning that is not required by the standard. As stated in the preamble to the November 6, 1985 notice (50 FR 46063) adopting the new warning system requirements for automatic safety belts, a manufacturer is free to provide additional features as long as the features required by the standard still continue to comply with all the applicable performance requirements. Thus, as long as the warning system provides the warning required by S4.5.3.3(b), NSK may voluntarily provide additional warnings as well.; You also said that NSK is planning to provide an automatic belt warnin system for both the driver's and right front passenger's seating position. S4.5.3.3(b) requires an automatic belt warning system only at the left front designated seating position. Thus, the agency would consider the passenger side warning system as a voluntary system, which you may install as long as the driver's warning system will continue to meet all applicable requirements.; You also asked several questions about when and how long the audibl and light warning are to be activated. Specifically you asked whether the warnings must be reactivated when the tongue of an emergency release buckle (referred to as an ERB in your letter) is inserted into the latch mechanism and then removed again within a few seconds. You also asked if the warnings can be de-activated by insertion of the tongue of the emergency release buckle before expiration of the 4-8 seconds specification for the audible warning and the 60 second specification for activation of the warning light. As explained below, if the emergency release buckle has been fastened and then unfastened after a few seconds, the warning does not have to be re-activated until after the ignition switch has been turned 'off' and then turned again to the 'on' or 'start' position. Also if the warning begins to activate and then the emergency release buckle is fastened, the warning may immediately be cancelled and thus does not have to be activated for the full time period specified in the standard.; S4.5.3.3(b) provides that the audible warning and the warning light ar to be activated only under certain conditions. Thus, the standard provides that the warnings are to be activated when condition A (the ignition switch is in the 'on' or 'start' position) *exists simultaneously* with one of the other conditions, such as condition B (the emergency release buckle not being fastened). Thus, if the emergency release buckle is unfastened and, at the same time, the ignition is in the 'on' or 'start' position, the warnings must activate. However, if the ignition is not in the 'on' or 'start' position and the emergency buckle is released, then the warnings do not have to be activated. The agency has previously said, such as in a June 17, 1981, letter to Chrysler, that the warning is not to activate if the safety belt is buckled. Thus, the warning may be cancelled once the emergency release buckle is fastened.; Again, I regret the delay in our response. If you have any furthe questions, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel