Interpretation ID: nht94-3.38

TYPE: INTERPRETATION-NHTSA

DATE: June 15, 1994

FROM: Reidar Brekke -- Market Analyst, Norwegian Trade Council

TO: Chief Council, NHTSA

TITLE: Legal Interpretation on "Belly Safe" a safety device used by pregnant women

ATTACHMT: Attached to letter dated 7-14-94 from John Womack to Reidar Brekke (A42; STD 208)

TEXT: The Norwegian Trade Council- New York (NTC-NY) is currently representing the Norwegian companies, HTS and Loyd's Industri, in their effort to introduce Belly Safe to the US market.

Belly Safe is a safety device made to protect the "unborn life". Belly Safe forces the car lap belt under the bulge of the stomach, and ensures that in the event of an emergency stop or a collision, that the "damaging" pressure will be concentrated on t he hip bone and not on the stomach where the fetus is situated.

We were recommended by Mr. Dan Orden, Chief of Import Division, Office of Vehicle Compliance, to contact you for a legal interpretation of this safety device. He felt that this was important even though there are no applicable standard for this type of products in the US.

As you will se from the information enclosed, the product has been tested and approved in both Sweden and in Germany. The product is made of Polyester and Acetal (see Constructional data form).

The product is currently sold in several European countries and in Australia. Belly Safe is patented in Europe and in the US.

We hope this information will be sufficient for you to give Belly Safe an legal interpretation.

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Pleas contact us if you have any questions or if you need more information.

Enclosed: German approval of Belly Safe under ECE R 16 rules and regulations Constructional data form from TUV Rheinland e.V. Preliminary translation of instructions Test results from the Swedish National Testing Institute Advertisement with references