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Interpretation ID: key-like object

    Gerald Plante, General Manager
    Fuji Heavy Industries USA, Inc.
    PO Box 6000, Subaru Plaza
    Cherry Hill, NJ 08034-6000

    Dear Mr. Plante:

    This responds to your inquiry regarding the definition of "key-like object" in relation to the buckle release requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant crash protection. Specifically you asked if the tongue from a safety belt buckle would be considered a "key-like object" for purposes of the standard. As explained below, a buckle tongue would conform to the definition of "key-like object" under the system you described.

    On December 8, 2004, we amended FMVSS No. 208 to require all designated seating positions in rear seats, other than side-facing seats, be equipped with Type 2 integral lap/shoulder safety belts (69 FR 70904). For certain folding and removable seats, the standard permits use of a release mechanism that detaches both the lap and shoulder portion at either the upper or lower anchorage point, but not both (See S4.1.5.5.2, S4.2.7.2, S4.2.7.4, and S4.2.7.5 of FMVSS No. 208). The standard also specifies that detachment must be by means of a "key or key-like object".

    In a phone conversation with Mr. Chris Calamita of my staff, you asked how the agency defines "key-like object". In a follow-up letter you specifically asked whether a tongue from an adjacent buckle would meet the definition of "key-like object".Your letter described a "release mechanism in which the shoulder belt portion [of a safety belt] is detached by inserting the tongue from another belt into a narrow slot".The photographs you provided illustrate a buckle with a narrow slot on the side that would accept the corner of a tongue from another belt.

    In specifying the requirement for a "key or key-like object," we were concerned about the potential for inadvertent release of a safety belt. This potential is particularly acute with typical push-button releases, which can be released with the push of a finger. We stated that manufacturers may choose to use the door or ignition key since these keys are always likely to be in the driver's possession when the belt needs to be detached. However, to provide flexibility in design we also permitted use of a "key-like object".

    The standard does not define "key-like object", but the preamble to the December 2004 final rule notes that a design in which an object must be inserted into a small hole in order to release a latch would comply with the requirement (69 FR 70908). Although your system has a slot as opposed to a hole, it also requires use of an object other than an occupants finger to release the latch. Under your system, a buckle tongue (or similarly shaped object) must be placed in the appropriate slot to release the latch, and therefore functions as a "key-like object".

    The system you described, therefore, would comply with the "key-like object" requirement in S4.1.5.5.2, S4.2.7.2, S4.2.7.4, and S4.2.7.5 of FMVSS No. 208. If you have any additional questions, please contact Mr. Calamita of my staff at (202) 366-2992.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:208
    d.616/05