DATE: 04/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Takata Kojyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 24, 1973, to Mr. Francis Armstrong, requesting various interpretations of Standards No. 208 and No. 209, with respect to safety belt systems.

Your first question, referenced to Figure No. 1 of the enclosure with your letter, relates to the required strength of the webbing in the case where two widths are connected together in an upper torso assembly. Under the webbing strength requirements of S4.2(b) of Standard No. 209, both pieces of webbing in the upper torso restraint must, individually, meet a 4,000 pound strength test. Under the assembly performance requirements of S5.3(b) of Standard NO. 209, a common pelvic and upper torso restraint must meet a 3,000 pound strength test. The latter would be true regardless of whether sewing or other means is used to make the belt assembly.

Your second question, referenced to Figure 2 of the enclosure, relates to the bolt strength required in the belt assembly anchorage. Under the provisions of S4.1(f), "equivalent hardware" is permissible in lieu of the 7/16" bolts. In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than or the individual components (bolts).

With respect to your third question, concerning the acceptability of belts that do not conform to the elongation requirements of Standard No. 209, our reply is that under the present circumstances such webbing would not conform to either Standard No. 208 or

{2} Standard No. 209. As a result of the decision by the United States Court of Appeals for the Sixth Circuit in Ford v. NHTSA, belts installed under Standard No. 208's third option in 1973 (S4.1.2.3) will have to conform to Standard No. 209. Unless Standard No. 209 is amended with respect to its elongation requirements, therefore, energy absorbing webbing of the type you describe will not be permitted in 1974 cars.

TAKATA KOJYO CO., LTD.

February 24, 1973

Francis Armstrong Director, Office of Compliance Motor Vehicle Program National Highway Traffic Safety Administration

Attention to; Mr. J. Gilkey Mr. G. Hunter

This is to request you to enlighten us upon the under-mentioned questions of ours so as to let us manufacture right seat belts assembly conforming to MVSS.

Please note, in this connection, that we have been manufacturing seat belts successfully for many years for installation in the cars destined to the United States.

Question # 1. (Please refer to the Figure # 1)

As shown on the Fig. #1, we made one shoulder belt connecting one webbing of 2" wide with another of 1" wide by pattern-stitching as the Figure. In this case, what breaking strength is required under S4.2(b) of MVSS 209? Is our belt taken as an assemblied webbings in spite of its connection by stitching? In other words, is 3,000 lbs. the required breaking strength for the said belt? How about in case the 2" webbing is connected with the 1"one with hardwares? Please clarify this case too.

Question # 2. (Please refer to the Figure # 2)

In compliance with the request of our customers, auto-manufacturers, we are preparing to use two bolts of smaller diameter than 7/16" for fastening to the anchorage. In this case, is each bolt is required to withstand the breaking strength of 5,000 lbs or more?

Question # 3.

We are planning to use an Energy Absorbent belt for 1974 cars. Our Energy Absorbent belt conforms to the requirement of MVSS 208's S.I. 1,000, but extends more than 40% at 2,500 lbs. In other words, the belt does not conform to MVSS 209. Can our belt be accepted by you, the U.S. authorities when shipped to the U.S. installed in the cars destined to the U.S. markets? Are we right in understanding that MVSS 208 takes precedence of MVSS 209 in this particular case?

Thanking you in advance for your kind guidance at your earliest convenience,

T. Hiramine, DIRECTOR

Enclosed.

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TAKATA KOJYO CO., LTD.

February 26, 1973

Francis Armstrong, Director

Office of Standards Enforcement National Highway Traffic Safety Administration, Attention to; Mr. J. Gilkey Mr. G. Hunter

Enclosed please find the two copies of sketches numbered as Figure # 1 and Figure # 2.

Kindly take a trouble to check whether the two sheets of copied sketches attached to our letter to you dated February 24, 1973 were numbered as Fig. 1 and Fig. 2, respectively.

We are afraid if we attached two copies of same number by mistake. If so, please replace the wrong ones by the correct ones enclosed herewith. Provided our originally attached ones were correct ones, please just destroy these copies enclosed herein.

Expressing our apologies for inconvenience caused by our oversight,

Sincerely yours

T. Hiramine

Enclosure.

(Graphics Omitted)

(Graphics Omitted)