Interpretation ID: nht76-5.16

DATE: 05/19/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: R. A. Olsen, Ph.D.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 26, 1976, question whether Federal motor 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, et 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 owners 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,

RICHARD A. OLSEN, Ph.D. Engineering Psychologist

Licensed Psychologist: Pa. #PS0235 Member: APA, PPA, HFS, IEEE, SAE

March 26, 1976

Robert L. Carter Associate Administrator for Motor Vehicle Programs National Highway Traffic Safety Admin. U.S. Department of Transportation

We have been considering establishing a mail-order firm specializing in replacement of the webbing of seat belt assemblies. As you may know, belt replacements through automobile dealers may cost $ 15-20 per assembly, while the webbing, which is the only component that deteriorates, could be supplied for about $ 1-2. By reuse of the hardware and quick turnaround times, stocking only the most common assemblies and allowing trade-ins, this service could expand as the demand increases and keep the cost low.

We would like an opinion from NHTSA on the standards which might be involved in such a service. Specifically, if webbing, assembly, and sewing are comparable to original equipment, would any testing for final assembly strength be required? We assume that reasonable workmanship would be sufficient if standard components and procedures are used. Any extensive testing or certification requirements would preclude initiation of this service firm since very small initial volumes would be anticipated, and cost must be kept low to cover labor, postage, and supplies.

We feel that the public is beginning to appreciate the value of seat belts, partly as a result of the interlock which demonstrated that the belts themselves "weren't so bad after all." Now there needs to be a way to replace frayed belts at a price that is not a strong deterrent.

Richard A. Olsen