Interpretation ID: nht75-4.36

DATE: 11/10/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Takata Kojyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Takata Kojyo's ctober 1, 1975, questions whether a Type 2 seat belt assembly with non-detachable shoulder belt (1) may be labeled in accordance with S4.1(k) of Standard No. 209, Seat Belt Assemblies, in only one location on either the upper torso or pelvic portion (A-I), (2) must be submitted (with the labeling modification) to a test laboratory or other facility as the basis for continued certification to the standard (A-II), (3) must be retested after a change is made to webbing length as the basis for continued certification to the standard (B-I), and (4), if testing is not required, must be submitted to a test laboratory or other facility as the basis for continued certification to the standard (B-II).

One label on either portion of a Type 2 seat belt assembly with non-detachable shoulder belt may be used to satisfy the requirement of S4.1(k) of Standard No. 209.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) requires manufacturers, to produce products covered by standards in compliance with those standards, as set by the National Highway Traffic Safety Administration (NHTSA), and to certify the products. It leaves the choice of testing methods up to the manufacturers. The NHTSA does not require retesting or submission to test laboratories as a basis for certification. A company like yours is free to choose any method that assures you that your products will conform if they are tested by the NHTSA as specified in the standard. This may take the form of tests, engineering calculations, or other means necessary to provide this assurance.

The answers given above pertain only to the Federal requirements for seat belts. It may be necessary to contact other regulatory authorities as to the effect of these changes under their regulations.

SINCERELY,

TAKATA KOJYO CO., LTD.

October 1, 1975

Frank A. Berndt U.S. Department of Transportation NHTSA

Re: Questions of alternation of labelling and webbing length on a safety seat belt assembly

We would like to appreciate sincerely for your previous kind and fine response to our questions of July 29, 1975.

We are very sorry to trouble you again but here are second times our questions underneath as follows referring the caption. So we shall be very pleased if you could let us have your instructions responsive to them.

(A) As you see and can realize a sketch in the figure attached here, in present system of a Type II seat belt assembly where both sections of webbing restraining upper torso and pelvic are sewed together with a tongue to result in no releasing of it from them, each of fabric labels indicating date of production, maker name, model expression and so on is stitched respectively on the torso section and pelvic section of webbing.

Our questions

(A-1) Can it be permitted that any one of above two fabric labels is deleted (for example; One for upper torso section will be expected)?

(A-2) In present usual case, we have been submitted from U.S.T.C. the test approval on a seat belt assembly attached with two labels. Even if above (A-1) is realized, are we required to submit new sample to the authorizer of U.S.T.C. and AAMVA (American Association of Moter Vehicle administrators in each State) in advance?

(B) In the case that in connection with the above seat belt assembly, we wish to alter the webbing length on it,

(B-1) Are we required to take a new approval test additionally for the assembly sample provided with altered length of webbing?

(B-2) If no new approval test be required at above (B-1), can we be permitted to do it only with submitting the new altered sample to the test authorizer of U.S.T.C., E.T.L. or so on?

ALTERATION we wish:

FROM:

TO:

upper torso restraint webbing, 1130+/- 5(Illegible) mm no change pelvic restraint webbing, 1100+/- 5(Illegible) mm 1130+/-5(Illegible) mm

We would be very happy to have your yes or no in so earlier time you could.

Mitsuru Masada

October 1, 1975 75-TD-424 attached to,

(Graphics ommitted)