Interpretation ID: nht87-1.44

TYPE: INTERPRETATION-NHTSA

DATE: 03/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: George Ziolo

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. George Ziolo 16182 Arena Drive Ramona, CA 92065

Dear Mr. Ziolo:

Thank you for your letter of September 19, 1986, concerning the labeling requirements of Standard No. 209, Seat Belt Assemblies. Those requirements provide that each safety belt is to be labeled with the year of its manufacture. You asked whether the yea r of manufacture can be shown in code. As explained below, the answer is no, the standard does not provide for showing the year of manufacture in code.

S4.1(j) of the standard requires each safety belt to be permanently and legibly labeled with the name of the manufacturer, distributor, or importer, the model of the safety belt model, and "the year of manufacture." The standard specifically requires the date of manufacture to be provided on the belt and does not provide for the use of a code to represent that date.

The purpose of the labeling requirement is to make it possible for the agency and consumers to identify easily the manufacturer of the safety belt for the purpose of noncompliance and safety-related defect investigations and notification and remedy campa igns. In addition, having the date of manufacture clearly marked on the belt assists consumers in determining whether a particular belt complies with the latest requirements of Standard No. 209 or some earlier version of those requirements. It also assis ts the agency in compliance testing of aftermarket and other safety belts because it enables the agency to determine easily which version of the standard should be applied to that safety belt. Having the year shown in a code can complicate the easy ident ification of which safety belts are covered by an investigation or campaign and make it more difficult to determine which version of the standard applies to the safety belt.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Office of the Chief Counsel US DOT/NHTSA SEP 19 1986 400 7th St SW Washington, DC 20590

Dear Sir:

FMVSS 209 requires that a seat belt be labeled to show:

Manufacturer's name Seat belt model Year of manufacture

My question is: Can the year of manufacture be shown in code? It seems to me that such interpretation was once given by your agency.

I thank you in advance for your kind response.

Sincerely,

George Ziolo

PS: Your response by informal endorsement hereon will suffice for my guidance.