Interpretation ID: nht87-1.45

TYPE: INTERPRETATION-NHTSA

DATE: 03/06/87

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: BINICHI DOI -- NSK REPRESENTATIVE OFFICE

TITLE: NONE

ATTACHMT: LETTER DATED 11/14/86, TO STEPHEN L OESCH, FROM BINICHI DOI; OCC - 1437

TEXT: Dear Mr. Doi:

Thank you for your letter of November 14, 1986, to Stephen Oesch of my staff concerning how our regulations would apply to a device intended to make it easier to reach the belt or latchplate of a safety belt system. I hope the following discussion answe rs your questions.

You enclosed a sketch with your letter that shows that the device would be attached to the vehicle by the anchorage bolt for the upper torso portion of a lap/shoulder safety belt. You explained that the device, called an "arm" or "belt reacher", is made of material which "does not interfere with the general safety/comfort of passenger and is installed semi-rotationally around the shoulder-anchor point so that it can hold the tongue in a convenient position" for the occupant to reach the belt.

There are no safety standard that directly apply to the device described in your letter. However, if the device is installed as an item of original equipment on a new vehicle, then the vehicle's safety belt system would have to continue to comply with a ll of the requirements of Standard No. 208. Thus, for example, if the device is installed on a vehicle that must comply with the comfort and convenience requirement of S7.4 of the standard, it must continue to meet those requirements, such as the the re traction requirements of S7.4.5, with the device in place. Likewise, the safety belt anchorage would have to continue to comply with all of the performance requirements of Standard No. 210.

There is one further issue associated with the device shown in your letter that I want to address. The agency supports the use of equipment that will make safety belts easier and more comfortable to use. However, it is equally important that those devi ces not introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of that belt. You stated in your letter that the device is made of a material that makes it compliant so that it moves with the belt and does not

interfere with the "original protective function" of the safety belt. If you should implement the design depicted in your letter we encourage you to continue to make sure that the device will not introduce excessive slack in the belt.

If you have any further questions, please let me know.

Sincerely,