Interpretation ID: nht70-2.30

DATE: 10/19/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: By letter of October 1, 1970, you asked for the opinion of this office as to whether the State of California, in specifying approval procedures for seat belts to be sold within the State, must require seat belt manufacturers to produce data showing that they have performed the exact tests specified in Federal Motor Vehicle Safety Standard No. 209.

The Federal motor vehicle safety standards are not instructions for, or descriptions of, manufacturer tests, nor do they specify types and numbers of tests. They are statements of requirements that each vehicle or item of equipment must meet when tested by the Bureau. Manufacturers are required to exercise due care to ensure that their vehicles will meet the standards if tested by the Bureau, and they are at their own discretion in devising an appropriate testing program for that purpose.

If a seat belt manufacturer presents data of tests conducted on webbing taken from rolls, rather than from individual assemblies, and if you are satisfied that such data demonstrates that the webbing would comply with Standard No. 209 when tested according to the procedures of that standard, you may, in our opinion, accept such data for purposes of State approval.

I trust that your question has been adequately answered. If you need further clarification we will be glad to provide it.