Interpretation ID: aiam4106
B.P.T. Leisure International Ltd.
3/4 Portland Street
London
W1N 5AG
ENGLAND;
Dear Mr. Levy: Thank you for your letter of January 14, 1986, concerning the effect o our regulations on a product you may export to the United States. I hope the following discussion answers your questions.; The product, which you call a 'Klunk- Klip' safety belt comfort device consists of a plastic device which attaches to the upper torso belt anchorage. 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.; As background information, let me explain that the agency does not hav the authority to approve or endorse items of motor vehicle equipment, such as your device. 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 product is not covered by any of our safet 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 product. Those responsibilities are set out in sections 151-160 of the National Traffic and Motor Vehicle Safety Act. I have enclosed an information sheet on our defect and other regulations for your review.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel