Interpretation ID: aiam3952
President
Eurospec
Inc.
109 Treetops Circle
Nanuet
NY 10954;
Dear Mr. Felice: This responds to your letter of March 29, 1985, concerning tw aftermarket products you intend to import. The products, which you call the 'Super Klip' and the 'Klunk Klip' safety belt comfort devices, consist of plastic devices which attach to the upper torso belt anchorage. The belt webbing then goes through a wedge attached to your device. A belt user can then pull the webbing through the open wedge and close the wedge to introduce slack into the shoulder portion of the belt. You asked for the agency to review the devices and inform you of any comments or objections.; As background information, let me explain that the agency does not hav the authority to approve items of motor vehicle equipment, such as your devices. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards.; Your particular aftermarket products are not covered by any of ou safety belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your products. Those responsibilities are set out in sections 151-160 of the National Traffic and Motor Vehicle Safety Act, a copy of which is enclosed.; The agency is concerned that a belted occupant could use your produc to reduce the effectiveness of the upper torso belt by moving the belt so close to the edge of the shoulder that the occupant could rotate out of the upper torso belt in a crash. Likewise, your product could be used to introduce excessive slack in the upper torso belt, which would also reduce its effectiveness. The instructions you provide with the 'Klunk Klip' do include information about how much slack to introduce into the belt and warns users not to introduce excessive slack. The instructions for the Super Klip contain no information or warnings on belt slack. We urge you to include a warning in both your instructions to advise belt users about the consequences of introducing too much slack in the belt.; I am returning the samples of your products that you enclosed with you letter. If you have any further questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel