Interpretation ID: 86-5.40
TYPE: INTERPRETATION-NHTSA
DATE: 10/30/86
FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA
TO: Toshio Maeda
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, MI 48104
Dear Mr. Maeda:
Thank you for your letter of July 30, 1986, concerning the safety belt contact force provision of the comfort and convenience requirements of Standard No. 208, Occupant Crash Protection. You explained that Nissan is concerned about the requirements of S10.6 contained in the final rule published on March 21, 1986. You noted that a sentence contained in the notice of proposed rulemaking was not included in the final rule and asked whether this sentence had been inadvertently omitted.
In addition, you asked the agency to clarify the effect of the omitted sentence on belt systems which have less than 12 inches of webbing stored in the retractor once the belt is placed around the test dummy. You explained that Nissan considers the purpose of the requirement in the omitted sentence to be elimination of belt drag before measuring the belt contact force. You explained that requiring a manufacturer to pull 12 inches of webbing from the retractor before the belt connect test would require redesign of Nissan's belt systems, even though those systems meet the safety belt adjustment requirements of the standard. You asked the agency to provide that a manufacturer can pull the maximum allowable length of the belt stored on the retractor, rather than 12 inches, prior to conducting the belt contact force test.
As explained in the enclosed Federal Register notice, the sentence contained in the notice of proposed rulemaking was inadvertently omitted from the final rule. NHTSA agrees that the purpose of the belt webbing pull requirement can be adequately net by pulling our the maximum allowable amount of the belt, when the belt has less than 12 inches of available additional webbing. Pulling the belt in this way will ensure that the belt retractor is working and webbing drag is reduced. Thus, the agency has modified the requirement to provide that prior to measuring the belt contact force the agency will pull out 12 inches of webbing or the maximum amount of webbing available when the maximum amount is less than 12 inches.
If you have any further questions, please let me know.
Sincerely,
Erika Z. Jones Chief Counsel
Enclosure
JULY 30, 1986 Ref: W-187-H
Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th St., S.W. Room 5219 Washington, D.C. 20590
Dear Ms. Jones:
Re: 49 CFR Part 571.208 (Docket No. 74-14; Notice 43) REQUEST FOR INTERPRETATION AND, IF NECESSARY, PETITION FOR RULEMAKING
On behalf of Nissan Motor Co., Ltd., of Tokyo, Japan, Nissan Research & Development, Inc, herewith requests the agency's interpretation of language in the above-reference provisions of Federal Motor Vehicle Safety Standard No. 208, "Occupant Crash Protection," Further, if NHTSA cannot agree that Nissan's understanding is an acceptable interpretation of the requirement, we subsequently request your treatment of this letter as a petition for rulemaking.
1) Section 10.7 of the final rule for Docket No. 74-14, Notice 43, gives the following directions for testing seat belt contact force:
"Pull the belt webbing three inches from the test dummy's chest and release until the webbing is within 1 inch of the test dummy's chest and measure the belt contact force."
This language differs from the language in S.10.6 in Notice 42, which at first gives directions to; "pull 12 inches of belt webbing from the retractor and then release it, allowing the belt webbing to return to the dummy's chest."
(Subsequent language is consistent in both Notice 42 and 43 versions.)
Nissan's question, therefore, is: was the omission of the Notice 42 language in Notice 43 intentional or not?
2) If the omission of that language from Notice 43 was unintentional, and the language is adopted as intended in Notice 42, Nissan's interpretation is that would be acceptable to pull out the maximum allowable length of belt webbing, in the event that 12 inches of belt webbing cannot be pulled out, before measuring belt contact force. Does NHTSA agree with and accept this interpretation?
Explanation of Nissan's Interpretation
According to the preamble of Docket 74-14, Notice 37, the purpose of the S10.6 provision is to eliminate the belt drag on the belt guide components before measuring the belt contact force, and not to measure the ability to pull 12 inches of webbing from the retractor, Nissan is not aware of any reasons to support additional requirements concerning belt adjustment beyond the requirements of MVSS 208 S7.1.
In Nissan's case, the explicit requirement that 12 inches of webbing must be pulled from the retractor would necessitate a complete redesign of some belt systems for our vehicles. We therefore believe that pulling the maximum allowable length of webbing should be allowable for cases where 12 inches cannot be pulled, We believe that such an interpretation is not inconsistent with the performance requirements of the standard.
As an aside, Nissan would also like to point out that for diagonal or 3-point automatic restraint systems which lack a belt guide, there is no need to pull out 12 inches of belt webbing length to eliminate belt guide drag.
3) As stated earlier, if the agency cannot agree that the rule's final language may be interpreted to allow the maximum allowable length of belt webbing to be pulled from the retractor, Nissan requests treatment of this request for interpretation as a Petition for Rulemaking to incorporate such language into S.10.7 of FMVSS 208.
In view of the extreme importance and urgency of NHTSA's response, we ask your utmost cooperation in treating this request expeditiously. Mr. Tomoyo Hayashi of my Washington, D.C. staff is available at (202) 466-5284 if you have further questions. Moreover, I would appreciate your mailing a copy of your response to Mr. Hayashi in Washington, to ensure our quick receipt of NHTSA's answer. His address is as follows: Nissan Research & Development, Inc. 1919 Pennsylvania Ave., N.W. Suite 707 Washington, D.C. 20006
Thank you very much.
Sincerely,
NISSAN RESEARCH & DEVELOPMENT, INC.
Toshio Maeda Executive Vice President & Chief Operating Officer
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