nht74-3.11 | NHTSA

DATE: 06/28/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

COPYEE: ING. Hans-Jurgen Sassor -- AUDI NSU Auto Union Germany

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 22, 1974, question whether Volkswagen's passive belt system may be equipped with a "comfort clip," and whether an optional Type I lap belt may be offered in conjunction with the passive system. Your passive system consists of an upper torso restraint and, in place of a lap belt, knee padding under the dashboard.

A vehicle which satisfies Standard No. 208, Occupant crash protection, may be equipped, at the option of the manufacturer, with additional safety belts which conform to Standard No. 209, Seat belt assemblies. Additional belts, like any required belt, must conform to the S7.2 requirements for latch mechanisms.

S7.2 Latch mechanism. A seat belt assembly installed in a passenger car shall have a latch mechanism --

(a) Whose components are accessible to a seated occupant in both the stowed and operational positions;

(b) That releases both the upper torso restraint and the lap belt simultaneously, if the assembly has a lap belt and an upper torso restraint that require unlatching for release of the occupant; and

This requirement assures that the occupant crash protection provided under Standard No. 208 is not diminished by a complicated and slow series of belt latch mechanisms which could otherwise be introduced into the vehicle.

Volkswagens' passive upper torso restraint and a separate active lap belt do not violate S7.2(b) in combination. Simultaneous release is required only "if the assembly has a lap belt and an upper torso restraint that require unlatching for release of the occupant." As described, Volkswagen's upper torso restraint does not require unlatching for release of the occupant.

With regard to our regulation of "comfort clips", we approved the use of a clip in a March 9, 1973, letter to General Motors, to relieve belt tension in limited circumstances. A copy of that letter is enclosed. In that case, the lap belt provided could be independently and firmly adjusted to limit occupant movement, providing protection in the event of lateral and rollover crashes. Until we have further details on the functioning of the Volkswagen clips, however, which we urge you to submit, we are unable to determine whether it would conform to the adjustment requirements of S7.1.1 of Standard No. 208, Occupant crash protection.

May 22, 1974

Lawrence R. Schneider Chief Counsel National Highway Traffic Safety Administration

Subject: MVSS 208, Occupant Protection - Request for Clarification

With the publication of Docket 74-4, Notice 2 (39 FR 14593), Volkswagen believes that MVSS 208 now adequately addresses the basic requirements covering passive belt systems, such as the Volkswagen passive shoulder belt/knee bolster restraint described in our petition of October 1, 1973.

However, in the final development phase of our passive belt system the possible inclusion of two ancillary devices came under consideration:

(1) the addition of an active lap belt,

(2) the addition of a "comfort clip" to the passive shoulder belt to relieve the belt force against the occupant during non-impact conditions.

Volkswagen respectfully requests NHTSA clarification of the current Federal requirements covering each of these items, which are discussed in more detail below.

1. Additional Active Lap Belt

Here we are interested in the requirements for the installation of active lap belts together with passive restraints, where the requirements of MVSS 208 are met by the passive restraints alone.

To our knowledge, the last published NHTSA statement addressing this matter appeared in 35 FR 16928 (Preamble to Docket 69-7, Notice 7): "Under the standard as adopted manufacturers will be free to supply seat belts as optional or standard equipment, but may not use them to satisfy the requirements of the standard. Standard No. 210 will continue to require seat belt anchorages to be installed by manufacturers, so that persons who wish to have seat belts installed in their vehicles, for their own use or for use with child seating systems, will be able to do so."

Specifically, we would like to know if a Type 1 lap belt (conforming to MVSS 209) can be installed in addition to the Volkswagen passive shoulder belt/knee bolster system, under either of the following circumstances:

a) where a vehicle equipped with the passive belt system alone meets the requirements of S4.1.2.2 and S4.5.3 of MVSS 208 (second option for passenger cars manufactured from Sept. 1, 1973 to the time when this option expires);

b) where a vehicle equipped with the passive belt system alone meets the requirements of S4.1.3 (a) through (d) (1) proposed in Docket 74-14, Notice 1, and S4.5.3 of MVSS 208.

Our main area of concern in this matter is in regard to the latch mechanism. The passive shoulder belt would have a latch mechanism conforming to S7.2 of MVSS 208, as required under S4.5.3.3(a). If the active lap belt is not governed by MVSS 208, the application of S7.2(b) of MVSS 208 for simultaneous release of lap and upper torso restraint is questionable.

2. Addition of "Comfort Clip"

We are aware that certain vehicles equipped with upper torso restraints with emergency-locking retractors incorporate belt force relief devices ("comfort clips") to make wearing of the belt more comfortable. Although the specifications governing these devices have not been incorporated into the Safety Standards, we understand that correspondence between individual manufacturers and the NHTSA has addressed the guidelines for their use. Since such a "comfort clip" could be applied to the VW passive belt, NHTSA clarification of the regulations relating to this specific usage is requested.

Your early attention to these inquiries would be greatly appreciated, in view of the lead-time constraints we would be facing for possible incorporation of the described items in 1975 model vehicles.

J. W. Kennebeck

Manager

Emissions, Safety & Development

Interpretation ID: nht74-3.11