Interpretation ID: nht90-4.13

TYPE: Interpretation-NHTSA

DATE: September 18, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Nelson Behar -- National Marketing Director, LooPo

TITLE: None

ATTACHMT: Attached to NHTSA information sheet dated 9-85 entitled Where To Obtain Motor Vehicle Safety Standards and Regulations (text omitted); Also attached to letter dated 7-11-90 from N. Behar to S. Kratzke

TEXT:

This responds to your fax to Steve Kratzke of my staff, in which you asked whether LooPo, which you described as "a seatbelt slacking device," complies with current regulatory and statutory requirements. I am pleased to have this opportunity to provide you with the following information.

It is not entirely clear how your company's "slacking device" would work. One type of "slacking device" is the comfort clip, in which a device is attached to the safety belt and can be positioned by an occupant to introduce and maintain slack in the safe ty belt system by physically preventing the belt slack from being taken up by the belt's retractor. We have explained how our regulations apply to comfort clips in a February 7, 1986 letter to Mr. Lewis Quetel (copy enclosed). Another type of "slacking device" is one that clips the shoulder belt to the lap belt nearer the middle of the wearer's abdomen. We have explained how our regulations apply to these belt positioning devices in a February 11, 1988 letter to Mr. Roderick Boutin (copy enclosed). I have also enclosed an information sheet for new manufacturers of motor vehicle equipment, such as this product.

As our previous letters explain, aftermarket sales and installation of these devices by individual vehicle owners are not prohibited by any Federal statutory or regulatory requirements. Nevertheless, the use of these devices raises some serious safety c oncerns if the devices result in the introduction of excess slack into the shoulder belt or otherwise reduce the safety protection afforded by the safety belts.

I hope that this information is helpful. If you have any further questions or need some additional information, please feel free to contact Mr. Kratzke at this address or by telephone at (202) 366-2992.