Interpretation ID: nht91-3.13

DATE: April 9, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Binichi Doi -- NSK Representative, NSK Corporation

TITLE: None

ATTACHMT: Attached to letter dated 3-5-91 from Binichi Doi to Mr. Kratzke

TEXT:

This responds to your letter to Mr. Kratzke of my staff, in which you asked for an interpretation of the labeling requirements in Standard No. 209, Seat Belt Assemblies (49 CFR S571.209). You explained in your letter and telephone conversation with Mr. Kratzke that your company is providing safety belts for the right front outboard position in certain vehicles. A few of those safety belts have a switch in the attachment hardware to indicate when the belt is not fastened, but the vast majority of those safety belts do not include such a switch. Your company would like to label all of those belts with a single label showing two model numbers. One of the model numbers would be assigned to the safety belts with that switch, and the other model number would be assigned to the safety belts without the switch. You asked whether Standard No. 209 permits this type of labeling. The answer is no.

The labeling requirements are set forth in S4.1(j) of Standard No. 209, which reads as follows:

Each seat belt assembly shall be permanently and legibly marked or labeled with year of manufacture, model, and name or trademark of manufacturer or distributor, or of importer if manufactured outside the United States. A model shall consist of a single combination of webbing having a specific type of fiber weave and construction, and hardware having a specific design. Webbings of different colors may be included under the same model, but webbing of each color shall comply with the requirements for webbing in S4.2.

The use of the singular "model," instead of the plural "model or models," in this requirement suggests that the Standard was intended to require each label to list only one model number. A closer examination of the other provisions of the labeling requirement and its underlying purpose confirm this.

The second sentence of the labeling requirement specifies that a model consist of a SINGLE combination of webbing and hardware. This definition of "model" obliges your company to assign a different model number to those right front outboard safety belts that have a switch than is assigned to the same safety belts without a switch, even though the belts are otherwise identical. This requirement that each different combination of webbing and hardware be assigned a different model number is necessary to effectuate the underlying purpose of the labeling requirement. The purpose of the labeling requirement for safety belts is to ensure that one can quickly and accurately determine important safety information about the safety belt merely by consulting the permanently attached label on the belt.

If, as you suggested, your company's belts were labeled with two model numbers, the only way to determine the model number for this particular belt would be to inspect the hardware on the belt, i.e., look to see if a switch is present on the belt. Requiring persons to conduct this additional inspection would be directly contrary to the purpose of the labeling requirements, since it would decrease the ease and potentially decrease the accuracy of identifying the model number of the safety belt. Accordingly, we conclude that S4.1(j) of Standard No, 209 requires the label on safety belts to show a single model number.