ID: 6952

Mr. Arthur J. Kuminski
Design Engineer
Eberhard Manufacturing Co.
21944 Drake Road
Cleveland, Ohio 44136-6697

Dear Mr. Kuminski:

This responds to your letter of February 3, 1992 concerning Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components. You asked about the standard's test requirements for sliding doors on cargo vans (sections S4.3 and S5.3). Your three questions and the response to each follow.

1. I will need specifications on how to perform this test on a test fixture using the striker assembly and the door latch only.

Standard No. 206 "specifies requirements for side door locks and side door retention components including latches, hinges, and other supporting means, to minimize the likelihood of occupants being thrown from the vehicle as a result of impact." The standard's requirements for sliding doors are set forth in sections S4.3 and S5.3.

Section S4.3 specifies that the track and slide combination or other supporting means for each sliding door shall not separate when a total transverse load of 4,000 pounds is applied, with the door in the closed position. Section S5.3 states, "(c)ompliance with S4.3 shall be demonstrated by applying an outward transverse load of 2,000 pounds to the load bearing members at the opposite edges of the door (4,000 pounds total). The demonstration may be performed either in the vehicle or with the door retention components in a bench test fixture."

Under section S5.3, the same basic procedure is conducted whether the test is conducted in a vehicle or with the door retention components in a bench test fixture, i.e., an outward transverse load of 2,000 pounds is applied to the load bearing members at the opposite edges of the door (4,000 pounds total). The details of the procedure using a bench test fixture will necessarily vary for different designs of sliding doors, since the door retention components themselves vary. The test should be conducted in such a manner that the same loads are applied to the door retention components as would occur in a vehicle test.

You specifically asked about how to perform the test on a test fixture using the striker assembly and door latch only. I note that since the requirement in section S4.3 applies to the "track and slide combination or other supporting means" for a sliding door, the striker assembly and door latch of a sliding door are tested only if they are part of the supporting means for the door. I also note that the entire supporting means for a sliding door is tested under section S5.3 and not merely one part.

I have enclosed for your information a copy of a May 13, 1975 interpretation letter to Toyota (including the incoming letter) which discusses various demonstration test fixtures which might be used to test sliding doors under Standard No. 206.

2. What load must the system withstand in the primary locked position to pass the test?

3. Is there a load requirement that the system must withstand in the secondary locked position to pass the test?

Section S4.1.1 of Standard No. 206 requires hinged doors, other than cargo-type doors to have both a fully latched position and a secondary latched position. There is not a similar requirement for sliding doors. Section S4.3 requires only one test, with a total load of 4,000 pounds, for sliding doors. This test would be performed with the door latched.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosures ref:206 d:3/30/92

ID: 6953

Mr. Robert Salton
Performance Friction Corp.
83 Carbon Metallic Highway
P.O. Box 819
Clover, S.C. 29710-0819

Dear Mr. Salton:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 105, Hydraulic Brake Systems (49 CFR 571.105). You stated that you are unclear about the pedal force requirements during the first fade and recovery test baseline check stops, and that an interpretation would make it clear exactly what calculation of pedal effort is used to verify compliance during the fade and recovery check stops. You also asked what values of pedal effort would be "considered non-compliance," i.e., whether peak, average or sustained control force must be within the specified limits under section S5.1.4.1. You indicated in a telephone conversation with Edward Glancy of my staff that you are primarily interested in the requirements for vehicles with a GVWR less than 10,000 pounds. Your questions are addressed below.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. A manufacturer then certifies that its vehicles or equipment comply with the applicable standards.

Standard No. 105's fade and recovery requirements are set forth in S5.1.4. These requirements must be met under the conditions prescribed in S6, when tested according to the procedures set forth in S7. See S5.1.

The standard specifies two fade and recovery tests, each of which consists of three parts: (1) baseline check stops or snubs, (2) fade stops or snubs (the heating cycle), and (3) recovery stops or snubs. The pedal force requirements for the baseline check stops or snubs are set forth in S5.1.4.1, which reads as follows: The control force used for the baseline check stops or snubs shall be not less than 10 pounds, nor more than 60 pounds, except that the control force for a vehicle with a GVWR of 10,000 pounds or more may be between 10 pounds and 90 pounds.

S5.1.4.1 must be read in conjunction with S7.11.1, which sets forth the procedure for the baseline check stops or snubs. S7.11.1.1 provides the following procedure for vehicles with a GVWR of 10,000 pounds or less:

Make three stops from 30 mph at 10 fpsps for each stop. Control readings may be terminated when vehicle speed falls to 5 mph. Average the maximum brake control force required for the three stops.

The baseline check stops or snubs are thus made at a constant deceleration (10 fpsps), with the control force varying as necessary to maintain that constant deceleration. Under S5.1.4.1, the control force is required to stay within a prescribed range (10 pounds to 60 pounds for vehicles with a GVWR less than 10,000 pounds) throughout the entire stop or snub (from the time in which application is started until the vehicle speed falls to 5 mph, other than the initial momentary period it takes to go from 0 to 10 pounds). Thus, compliance with S5.l.4.1 is not determined based on peak, average or sustained control force. Instead, for a vehicle to comply with this test, the control force must never fall below 10 pounds or be above 60 pounds during any part of the test (for the period described above).

Your other question concerned how calculation of pedal effort during the baseline check stops or snubs is used to verify compliance during the fade and recovery check stops. As indicated above, S7.11.1.1 specifies that an average is taken of the maximum control force for the three stops. The term "maximum" refers to the peak control force for each of the stops. I note that this average is not related to whether the vehicle complies with S5.1.4.1. Instead, as discussed below, this average establishes a baseline control force, which is used to derive certain of the control force limits for the recovery stops.

The requirements for the recovery stops are set forth in S5.1.4.3, which reads as follows:

Each vehicle with a GVWR of 10,000 pounds or less shall be capable or making five recovery stops from 30 mph at 10 fpsps for each stop, with a control force application that falls within the following maximum and minimum limits: (1) A maximum for the first four recovery stops of 150 pounds, and for the fifth stop, of 20 pounds more than the average control force for the baseline check; and

(2) A minimum of--

(A) The average control force for the baseline check minus 10 pounds, or

(B) The average control force for the baseline check times 0.60, whichever is lower (but in no case lower than 5 pounds). . . .

Thus, the minimum and (for one stop) the maximum control force limits for the recovery stops are calculated using the average control force for the baseline check stops or snubs. This average control force is the one calculated under S7.11.1.1 using the maximum control force of each of the baseline check stops or snubs.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Ref:105 d:4/14/92

ID: 6960

Marc C. Gravino, Esq.
Williams & McCarthy
P.O. Box 219
Rockford, Ill. 61105-0219

Dear Mr. Gravino:

This responds to your letter of February 7, 1992, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108. Specifically, you ask whether the standard contains any requirement that the parking lamps, taillamps, and side marker lamps operate independently of the ignition switch so that when they are activated they will remain activated regardless of whether or not the ignition switch is in the on or off position. You have reviewed Standard No. 108, and reference paragraphs S5.5.3, S5.5.4, S5.5.5, and S5.5.7, copies of which you have enclosed.

The answer is no. Under paragraph S5.5.5, the vehicular hazard warning signal operating unit is required to operate independently of the ignition switch, but no other lamp is required by the standard to do so.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:3/5/92

ID: 6962

Mr. Kenneth R. Brownstein
Senior Counsel
PACCAR Inc.
P.O. Box 1518
Bellevue, WA 98004

Dear Mr. Brownstein:

This responds to your letter, requesting that the agency clarify a provision in Standard No. 120, Tire Selection and Rims for Motor Vehicles Other than Passenger Cars. (49 CFR 571.120) Specifically, you asked whether under section S5.1.3, a vehicle manufacturer could, if requested by the purchaser, install retreaded tires procured by the manufacturer on a new vehicle. You stated that allowing the vehicle manufacture to buy retreaded tires would be more efficient and would help the truck owner to avoid having to make a separate purchase. I welcome this opportunity to respond to your request for an interpretation.

Section S5.1.3 of Standard No. 120 states:

In place of tires that meet the requirements of Standard No. 119, a truck, bus, or trailer may at the request of a purchaser be equipped at the place of manufacture of the vehicle with retreaded or used tires owned or leased by the purchaser, if the sum of the maximum load ratings meets the requirements of S5.1.2. Used tires employed under this provision must have been originally manufactured to comply with Standard No. 119, as evidenced by the DOT symbol.

For the vehicle manufacturer to install retreaded or used tires on a new truck, bus, or trailer, section S5.1.3 specifies that five conditions must be satisfied. These are:

(1) the purchaser must request such a retreaded or used tire, (2) the vehicle must be equipped with the retreaded or used tire at the vehicle's place of manufacture, (3) the retreaded or used tire to be installed must be owned or leased by the purchaser, (4) the sum of the maximum load ratings of the tires on each axle must be not less than the gross axle weight rating of that axle, and (5) used tires equipped on the vehicle must have been originally manufactured to comply with Standard No. 119 (and contain the DOT certification symbol).

Your letter indicates that in buying the retreaded tires at the purchaser's request, PACCAR's actions would comply with the first condition (and presumably the second condition). However, since PACCAR and not the vehicle purchaser would supply the tire, your requested action clearly would not comply with the third condition which requires the retreaded or used tire to be owned by the purchaser. This condition permits a purchaser to order a new vehicle without any tires and install any tire it may choose. It is not clear from your letter whether the fourth condition would be satisfied. The fifth condition is not applicable to retreaded truck tires, since such tires are not required to have a DOT certification symbol on their sidewalls. Based on the above, we conclude that having a vehicle manufacturer supply a retreaded or used tire for a new vehicle would not comply with S5.1.3.

We disagree with your view that the purpose of section S5.1.3 is to allow the purchaser to choose whether the new vehicle has retread tires and to ensure it has knowledge of this fact. As discussed in the enclosed Federal Register notice, the purpose of the provision is to accommodate a practice in which fleet operators send tires from their tire banks to the vehicle manufacturer for installation on new vehicles they buy. A tire bank is composed of tires with usable tread left on them which have been taken off vehicles no longer in service. (49 FR 20822, 20823, May 17, 1984).

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel Enclosure Ref:120 d:3/23/92

ID: 6971

Mr. Frederick Harris
Frederick Harris Associates
5717 Huberville Avenue
Dayton, Ohio 45431

Dear Mr. Harris:

This responds to your letter asking about Federal motor vehicle safety standards applicable to your product, which you described as a cloth device containing plastic items useful to a baby, for use in motor vehicles. You explained that your product would be placed in a motor vehicle adjacent to, but not touching, a child in a nearby child safety seat. In particular, you were concerned about flammability resistance standards applicable to your product. I am pleased to have this opportunity to explain our requirements to you. I am also enclosing a copy of a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. Section 102(4) of the Safety Act defines, in relevant part, the term "motor vehicle equipment" as:

any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle ...

In determining whether an item of equipment is considered an accessory, NHTSA applies two criteria. The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. We determine the expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is intended to be used principally by ordinary users of motor vehicles. If the product satisfies both criteria, then the product is considered to be an "accessory" and thus is subject to the provisions of the Safety Act. Applying these criteria to the cloth device containing baby items, it appears that your product would be an accessory and thus an item of motor vehicle equipment under the Safety Act. Based on our understanding of your device, it appears that a substantial portion of its expected use will be during the operation of a motor vehicle. In a telephone conversation with Ms. Dee Fujita of my staff, you explained that your device is intended to be sold for use in motor vehicles. In addition, it appears that your product would typically be used by ordinary users of motor vehicles.

While it appears that your device would be considered an item of motor vehicle equipment, this agency has not issued any standards setting forth performance requirements for such a device. Obviously, your device could not be determined to be in noncompliance with a safety standard if there is no applicable safety standard.

As for your concern about flammability resistance requirements, please be advised that our safety standard about this issue, Standard No. 302, Flammability of Interior Materials, (49 CFR 571.302, copy enclosed), would not apply to your device. That standard sets forth such requirements applicable to new motor vehicles and not to motor vehicle equipment.

You should be aware that, as a manufacturer of an aftermarket item of motor vehicle equipment, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. In the event that you or NHTSA determines that your product contains a safety related defect, you would be responsible for notifying purchasers of the defective equipment and for remedying the problem free of charge.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely,

Paul Jackson Rice Chief Counsel Enclosure

Ref: 302 d:3/5/92

ID: 6972

Mr. Lance Watt
Director of Engineering
The Flxible Corporation
970 Pittsburgh Drive
Delaware, Ohio 43105-2859

Dear Mr. Watt:

This responds to your letter of February 11, l992, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it relates to several scenarios regarding the wiring and use of optional brake retarder transmissions on city transit buses manufactured by your company.

In your current design, the retarder is designed so that it is electrically operated during the initial travel of the service brake pedal. As the service brake pedal is further depressed, the service brakes are activated, and this in turn illuminates the stop lamps. You have enclosed a copy of my letter of September 20. 1990, confirming that this design conforms to Standard No. 108, specifically S5.5.4 which states that "The stop lamps on each vehicle shall be activated upon application of the service brakes."

Since that time, several additional scenarios have presented themselves. First, some customers have requested that the transmission retarder be activated when the accelerator pedal is released, rather than when the brake pedal is applied. In this configuration, the stop lamps would not be illuminated, "and therefore, following vehicles may be unaware of this sudden reduction in vehicle speed", unless the service brakes were also applied. However, some customers wishing this option would like to have the stop lamps illuminated by the retarder, that is to say, when the accelerator is released. Second, some customers have also requested a retarder cut-off switch in order to disable the retarder during icy or slippery road conditions. In such a case, the stop lamps would also be activated at the time of accelerator release "with minimal if any change in vehicle forward speed, and again, potentially with no intent on the part of the driver to use the service brakes." To date, your company has resisted these requests, but these customers, without a specific NHTSA interpretation on the point, threaten to declare your company a nonresponsive bidder on transit bus procurements. You have asked whether a noncompliance with section S5.5.4 would result "if the stop lamps were activated without depressing the brake pedal as requested by our customers."

The purpose of the retarder feature is to provide supplemental braking to city transit buses. This braking results in the deceleration of the vehicle. A stop lamp is defined by SAE Standard J1398 MAY85 Stop Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width as one that indicates "the intention of the operator of a vehicle to stop or diminish speed by braking." Whenever the brake retarder is activated with the intent of diminishing speed by braking, Standard No. 108 does not require that the stop lamps be activated. The only mandate of the standard (S5.5.4) is that when the service brakes are applied, the stop lamps must be illuminated.

Nor does Standard No. 108 prohibit illumination of the stop lamps by release of the accelerator pedal followed by activation of the retarder. This is because the intention of the driver is to diminish speed by the braking action of the retarder. We distinguish this situation from the one in an interpretation provided Larry Snowhite, Esq. on January 25, 1990, in which a device activated the stop lamps whenever the accelerator pedal was released, regardless of the intent of the driver. Activation of the stop lamps initiated by release of the accelerator pedal is permissible only when the intent of the driver is to reduce the speed of the vehicle by an immediate subsequent act of braking, whether that is achieved through his use of the service brake system, use of retarders, or a combination of the two.

However, a configuration where the stop lamps operate in the absence of service brake application or activation of a retarder system (as appears to occur when a retarder cut off switch has been activated) would be subject to S5.1.3 of the standard. This prohibits the installation of motor vehicle equipment that impairs the effectiveness of the lighting equipment required by Standard No. 108. In this instance, the retarder cut off feature would permit the stop lamps to send the false signal that the operator intended to stop or reduce vehicle speed when, in fact, there was no intent to do so.

I hope that this answers your question.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:4/10/92

ID: 6973

Dr. Carl C. Clark
Safety Systems Company
23 Seminole Avenue
Baltimore, MD 21228-5638

Dear Dr. Clark:

This responds to your request for an interpretation of Standard No. 205, Glazing Materials (49 CFR 571.205). More specifically, your letter indicated your belief that Standard No. 205 permits a prime glazing material manufacturer to designate an item of glass-plastic glazing that it manufactures as "Item 14" glazing if that glass- plastic glazing item passes all the tests specified for Item 14 glazing. It is your view that it is irrelevant whether the individual glass layers in the glass-plastic glazing are tempered or annealed glass. Your understanding is correct.

Standard No. 205 specifies the performance requirements for Item 14 glazing, through a series of 14 tests designated for that item of glass-plastic glazing material. No test applicable to Item 14 glazing specifies that any individual layer, either glass or plastic, of this laminated glazing is to be tested separately. Instead, the 14 tests applicable to Item 14 glazing set forth performance levels that must be achieved by the glazing as a laminate.

One of the 14 tests designated for Item 14 is Penetration Resistance, Test No. 26. You are correct in noting that, effective September 23, 1991, Test No. 26 specifies the glass-plastic specimen is to be clamped into a test fixture before the specimen is tested. If an item of glass-plastic glazing passes each of the 14 tests applicable to Item 14 glazing, including Test No. 26, with clamping, and complies with Standard No. 205's labeling and certification requirements, the prime glazing material manufacturer of the material may designate that item of glass-plastic glazing as Item 14 glazing.

You were also correct in your understanding that Standard No. 205 permits Item 14 glazing to be used for passenger car glazing in any position except the windshield of convertibles.

I hope this information is helpful. Please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:205 d:3/5/92

ID: 6975

Mr. R. Wendell Moore
Acting Chief Counsel for Advocacy
U.S. Small Business Administration
Washington, D.C. 20416

Dear Mr. Moore:

Thank you for your letter concerning a petition for rulemaking on Federal Motor Vehicle Safety Standard No. 106, Brake Hoses. While your letter did not identify the petitioner by name, your concerns relate to issues raised in Philatron International's petition to the agency.

Philatron requested that the National Highway Traffic Safety Administration (NHTSA) remove Standard No. 106's oil resistance requirement for "air brake tubing." Philatron believed that there was no safety need for the requirement and that it impeded new developments in technology. The petitioner asked that the agency conduct rulemaking to remove the requirement without first providing notice or seeking public comment.

Your letter supports Philatron's petition. Further, it endorses the idea of our issuing an interim final rule which removes the oil resistance requirement from the standard, and then asks us to study the merits of the requirement, pending issuance of a final rule.

This agency is, of course, sensitive to the concerns of small businesses and currently is carefully reviewing its regulations pursuant to the President's recent directive. As required by NHTSA's regulation for rulemaking petitions (49 CFR Part 552), we are evaluating Philatron's petition to determine whether there is a reasonable possibility that the requested order would be issued at the conclusion of a rulemaking proceeding. Please note that NHTSA views the issues and facts relevant to the petition as being more involved than the information available to you may suggest. In addition, please note further that, if a proceeding were commenced, it would be a normal notice and comment proceeding as required by the Administrative Procedure Act.

We appreciate your interest in this matter and will carefully consider your views as part of the petition evaluation process.

Sincerely,

Jerry Ralph Curry

ref:106 d:3/10/92

ID: 6977

Mr. Jeff Ruff
Director of Fleet/Government Sales
The Braun Corporation
1014 S. Monticello
P.O. Box 310
Winamac, IN 46996

Dear Mr. Ruff:

This responds to your letter of February 10, 1992 requesting advice regarding the location of the upper anchorage for the front passenger seat shoulder belt.

By now, you should have received our reply (dated February 14, 1992) to your previous letter (dated October 30, 1991). In that letter, I explained that NHTSA will not conduct any crash testing of vehicles modified for operation by persons with disabilities while the agency reviews the petition from the Recreation Vehicle Industry Association to exclude these vehicle from the dynamic crash test requirement. Because this is now a pending rulemaking, the agency cannot discuss what requirements the agency will propose for these vehicles prior to the publication of the notice of proposed rulemaking (NPRM). However, as explained in our previous letter, NHTSA is aware of the need of manufacturers such as yourself and your customers to have this matter addressed as soon as possible. Therefore, the agency is proceeding with preparation and publication of the NPRM as quickly as possible.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:208 d:5/3/92

ID: 6978

Mr. Douglas Kubehl
Safety Engineering Associates, Inc.
2798 S. Fish Hatchery Rd.
Madison, Wisconsin 53711-5398

Dear Mr. Kubehl:

This responds to your letter of February 4, 1992, concerning the requirements of Federal motor vehicle safety standard No. 209, Seat belt assemblies. You asked for verification of your understanding of the requirements of two sections of Standard No. 209. Your discussion of these two sections and our response follows.

In 209-S.4.4a(1), it is clearly stated that a loop force of 5000 pounds is required to produce a force of 2500 pounds on each structural component. However, part 209-S4.4b(4) seems to be a bit ambiguous. It states: "The length of the pelvic restraint between anchorages shall not increase more than 20 inches or 50 centimeters when subjected to a force of 2500 pounds". My interpretation of this statement is that one must employ a loop force of 5000 pounds to achieve 2500 pounds of force on each component, as specified in S4.4a(1). I am concerned that one could misinterpret the above statement as requiring a 2500 pound loop force, rather than the intended value of 5000 pounds.

Your statements indicate a common misunderstanding of the requirements of S4.4 of Standard No. 209. A seat belt assembly would not be subject to the requirements of S4.4(a) and to the requirements of S4.4(b). If the seat belt assembly is a Type 1 seat belt assembly, defined in S3 as "a lap belt for pelvic restraint," the assembly is subject to the requirements of S4.4(a). Section S4.4(a)(1) requires a Type 1 seat belt assembly loop to withstand a force of 5,000 pounds. Section S4.4(a)(2) states that the length of the assembly between the anchorages shall not increase more than 14 inches or 36 centimeters when the load required in S4.4(a)(1) is applied.

If the seat belt assembly is a Type 2 seat belt assembly, defined in S3 as "a combination of pelvic and upper torso restraints," the assembly is subject to the requirements of S4.4(b). Section S4.4(b)(1) requires the pelvic portion of a Type 2 seat belt assembly to withstand a force of 2,500 pounds. Section 4.4(b)(4) states that the length of the pelvic portion of the assembly shall not increase more than 20 inches or 50 centimeters when the load required in S4.4(b)(1) is applied.

Part 209-S5.3a, which addresses the performance of the belt assembly, refers to Figure 5 and requires a tensile force of 2500 pounds. It goes on to say that this force is equivalent to a 5000 pound force being applied to an assembly loop. Figure five is referred to several times throughout the passage, each reference requiring a specific force. Again, because the relationship of the tensile force to assembly loop force is not explicitly stated, we are concerned that one may mistake the tensile force to be the total loop force applied.

The test procedure to determine compliance with the requirements of S4.4 of Standard No. 209 is found in S5.3 of that standard. The test procedure for seat belt assemblies subject to the requirements of S4.4(a) (a pelvic restraint) is found in S5.3(a). As you have correctly stated, a force of 2,500 pounds is applied to each component of the pelvic restraint, or a force of 5,000 pounds to the entire loop. The test procedure for seat belt assemblies subject to the requirements of S4.4(b) (a combined pelvic and upper torso restraint) is found in S5.3(b). The pelvic portion of such a seat belt assembly is tested by applying a total force of 2,500 pounds to the entire loop.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:209 d:3/16/92