Interpretation ID: nht76-5.3
DATE: 04/12/76
FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA
TO: Masoaka-Ishikawa and Associates, Inc.
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your February 24, 1976, request for affirmation that a particular Takata Kojyo test procedure for applying force to a continuous loop Type 2 belt system "meet[s] the requirements set forth in Standard 209, Seat Belt Assemblies."
Section S4.4 of Standard No. 209 sets forth the requirements of the standard for assembly performance. Section S5.3(b) sets forth test methods that would be used in a determination of whether a Type 2 seat belt assembly conforms to the requirements of S4.4. Takata Kojyo's obligation as a manufacturer is to ensure that its certification of compliance is not false or misleading in a material respect, and that it has exercised due care in manufacturing to conform to Standard No. 209 (15 U.S.C. @ 1397(b)(2)). A manufacturer is not required to follow specifically the test procedures of the standards, but to ascertain, in the exercise of due care, that its product will conform to the standard's requirements when it is tested by the stated methods.
From your description, you have modified the existing procedures by use of a clamp to ensure that all force is applied to the lower torso webbing and hardware or, alternatively, to the upper torso webbing and hardware. While it appears that the comtemplated test procedure may evidence the exercise of due care to certify compliance with S4.4, the NHTSA cannot approve a manufacturer's test procedure as the basis of due care in advance of the actual events that underlie certification. It is the manufacturer's responsibility to utilize sound engineering judgement in the exercise of due care.
MASOKA-ISHIKAWA AND ASSOCIATES, INC.
February 24, 1976
Dr. James B. Gregory Administrator National Highway Traffic Safety Administration U.S. Department of Transportation
On behalf of Takata Kojyo Co., Ltd., a manufacturer of seat belt assemblies whose products are used in automobiles marketed in the United States, we seek affirmation from the National Highway Traffic Safety Administration that the testing procedures for "continuous-loop" seat belt assemblies as shown in the attached illustrations meet the requirements set forth in Standard 209, Seat Belt Assemblies.
The proposed Takata Kojyo test procedures as shown in Figures 3 and 4 are specifically designed for Takata Kojyo's newly developed energy-absorbing/conventional webbing, continuous-loop seat belt assembly.
Figure 1 shows Takata Kojyo's continuous-loop seat belt assembly. Figure 2 illustrates the manner in which Takata Kojyo's combination energy-absorbing/conventional seat belt webbing is manufactured in an unique continuous weaving process. The continuously type webbing for the lap portion and the energy-absorbing webbing for the upper torso portion in an especially advanced continuous-loop seat belt assembly which provides markedly improved occupant protection.
Takata Kojyo Co., Ltd., No. 10 Mori Building, 28 Sakuragawa-cho, Nishikubo, Shiba, Minato-Ku, Tokyo, Japan, is a privately held Japanese corporation engaged in the manufacture of seat belt assemblies. Takata Kojyo does not directly market its automotive safety products in the United States. Its products are sold to manufacturers whose automobiles are sold in the United States. Japanese automobiles which use Takata Kojyo seat belt assemblies include, but are not limited to, Toyota, Datsun, Mazda, Dodge Colt and Honda. Takata Kojyo is the largest supplier of seat belt webbing in Japan, accounting for the more than 80 per cent of the market.
We respectfully request your prompt reply to our inquiry as to whether the test procedures shown in the attached illustrations fulfill the requirements of Standard 209.
T. Albert Yamada
CC: S. ISHIKAWA
Fig. 3 Proposed test method. Takata Kojyo Type II Bedt System (Continuous Loop)
Fig. 4 Proposed test method. Takata Kojyo Type II Seat Belt (Continuous Loop)
(Graphics omitted)
Fig. 1 Takata Kojyo Continous Loop Seat Belt Assembly
Fig. 2 Takata Kojyo Energy-absorbing webbing. Manufactured in a continuous weaving process.
(Graphics omitted)