Interpretation ID: nht73-5.42

DATE: 11/02/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Porsche

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 2, 1973, to Mr. James Hofferberth of my staff, inquiring if a particular safety belt system which is illustrated in your enclosures meets the criteria for a passive restraint system.

The interpretation of a passive restraint system published in the Federal Register on May 4, 1971 (36 F.R. 8296) was:

"The concept of an occupant protection system that requires 'no action by vehicle occupants' as used in Standard No. 208 is intended to designate a system that requires no action other than would be required if the protective system were not present in the vehicle."

With respect to your belt system, a requirement for placing the belt in the storage holder when leaving the car would be considered "action" and not permitted under the above interpretation of a passive system. However, if the belt system could be entered and exited with essentially no action, in the event the storage holder was not used, automatically releasing "convenience" holder would not compromise the belt's qualification as a passive system.

SINCERELY,

Jim Hofferberth NHTSA

9/2/73

Dear Mr Hofferberth.

This is in ref. to our tel. conversation of last week re passive restraint system. The picture are self explanatory, and show the sequence of locking and unlocking. Would you please let me know if this meets the standard or if any changes are needed.

Very truly yours Kurt Meier