Interpretation ID: nht73-5.14

DATE: 09/17/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Toyota Motors Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 24, 1973, concerning Toyota's use of a clip to prevent the shoulder belt from rubbing the occupant's neck. Your questions are (1) whether a clip of this type is permitted by Standard No. 208 and (2) whether the clip would be considered a part of the anchorage under Standard No. 210.

Your description of the clip indicates that it does not restrict the free travel of the webbing. The clip would therefore not inhibit the ability of the belt to adjust automatically to fit the occupant, as required by S7.1.1 of Standard No. 208. It is our opinion that such a clip is permitted by Standard No. 208.

We have also concluded that a plastic guide clip designed so as not to affect the basic geometry of the belt during a crash is not a seat belt anchorage for purposes of Standard No. 210. The clip you describe would therefore not be required to meet the strength of location requirements of that Standard.

TOYOTA MOTOR SALES, U.S.A., INC.

August 24, 1973

Dr. James B. Gregory, Administrator National Highway Traffic Safety Adm.

For the purpose of encouraging our customers to use the seatbelt system, Toyota has been striving to minimize the possible discomfort or irritation which they may experience when wearing the upper torso belts, and we have developed a clip which is attached to the upper portion of the seat back as shown in the enclosed photo.

This clip is used to prevent the shoulder harness from contacting the occupant's neck and does not affect the retractive movement of the seatbelt shoulder harness. This clip, which is made of plastic, is designed so as not to hinder the performance of the seatbelt system during an accident.

Toyota believes the above-mentioned clip meets the intent of FMVSS No. 208 and the requirements of paragraph @ 7.1.1 of that standard. Toyota does not consider a clip of this nature to be an anchorage to which the requirements of FMVSS No. 210 apply.

As soon as we receive your favorable reply regarding this interpretation, we would like to install the clip on some of our models to improve the comfort of the seatbelt system.

Your prompt response to this matter would be greatly appreciated.

Keitaro Nakajima Director/General Manager Factory Representative Office

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