Interpretation ID: nht80-3.23

DATE: 07/29/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT:

JUL 29 1980

NOA-30

Mr. Roger Maugh Automotive Safety Director Ford Motor Company The American Road Dearborn, Michigan 48121

Dear Mr. Maugh:

This is in response to your request for our comments concerning the prototype automatic belt system on the demonstration vehicle you brought to the agency several weeks ago. You were particularly concerned about past agency comments regarding automatic belt designs of this type that are so easily disconnectable.

We are concerned about automatic belt designs whose release mechanisms are so similar to those of current manual belts that they may actually encourage disconnection by motorists. By the same token, however, we realize that an automatic belt design that is extremely difficult to disconnect could lead to frustration of a motorist who does not wish to use it and to permanent defeat of the belt system. This, of course, is also not desirable since it would deprive a subsequent vehicle occupant who wanted to use the belt of protection. We hope manufacturers will develop innovative systems that will minimize these conflicting concerns.

Regarding the particular design that you demonstrated at our meeting, the release mechanism appears to be in compliance with the current provisions of Safety Standard No. 208. This is not to say, however, that additional features to discourage disconnection of the system are not desirable.

We were also concerned with other aspects of your automatic belt. For example, when the vehicle door was open the belt webbing lay on the vehicle seat, making entry into the vehicle both confusing and difficult for a vehicle occupant. Since such a design requires the occupant to lift the belt webbing, it could prove to be very inconvenient, particularly if the occupant is carrying an object like a bag of groceries. As you are aware, the recent proposal concerning seat belt comfort and convenience included a specification for 3-inch webbing/seat clearance. Even more than three inches may be needed to insure that automatic belts are in fact automatic and convenient (I am enclosing a past agency interpretation on this subject). You should consider these points when making a final decision concerning this type belt design.

Finally, I would like to emphasize that this letter only represents the agency's opinion based on the brief examination of the belt system during our recent meeting. It is up to the vehicle manufacturer to determine whether its vehicles are in compliance with all applicable safety standards and to certify that compliance.

Thank you for bringing this prototype automatic belt system to the agency for inspection.

Sincerely,

Frank Berndt Chief Counsel