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Federal Motor Vehicle Safety Standards; Occupant Crash Protection

American Government Special Collections Reference Desk

American Government Topics:  Federal Motor Vehicle Safety Standards

Federal Motor Vehicle Safety Standards; Occupant Crash Protection

Barry Felrice
National Highway Traffic Safety Administration
March 29, 1994


[Federal Register Volume 59, Number 60 (Tuesday, March 29, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 94-7351]


[[Page Unknown]]

[Federal Register: March 29, 1994]


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DEPARTMENT OF ENERGY

National Highway Traffic Safety Administration

49 CFR Part 571

[Docket No. 87-08; Notice 10]
RIN 2127-AF27

 

Federal Motor Vehicle Safety Standards; Occupant Crash Protection

AGENCY: National Highway Traffic Safety Administration (NHTSA), DOT.

ACTION: Denial of petitions for reconsideration.

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SUMMARY: The purpose of this notice is to announce the denial of two 
petitions for reconsideration of a final rule amending Standard No. 
208, Occupant Crash Protection, to require ``lap belts or the lap belt 
portion of lap/shoulder belts to be capable of tightly securing child 
safety seats.'' This requirement is referred to as the ``lockability 
requirement.'' The first petition, from Jaguar, requested a one-year 
extension of the effective date of the final rule, or, in the 
alternative, a phase-in period. This petition is denied because NHTSA 
believes the petitioner's difficulty in complying with the lockability 
requirement is surmountable. Further, granting the petition would 
needlessly delay implementation of this requirement.
    The second petition, from Toyota, requested a change in the test 
procedure to either employ a surrogate child restraint as a test device 
or to add an additional sentence about belt position before load 
application. This petition is denied because the petitioner's reported 
problem can be solved through a proper interpretation of the test 
procedure.

FOR FURTHER INFORMATION CONTACT:
Mr. Daniel S. Cohen, Office of Vehicle Safety Standards, NRM-12, 
National Highway Traffic Safety Administration, 400 Seventh Street, 
SW., Washington, DC 20590. Telephone: (202) 366-4911.

SUPPLEMENTARY INFORMATION: On October 13, 1993, NHTSA published a final 
rule amending Standard No. 208, Occupant Crash Protection, to require 
``lap belts or the lap belt portion of lap/shoulder belts to be capable 
of tightly securing child safety seats,'' referred to as the 
``lockability requirement'' (58 FR 52922). The final rule was intended 
to ensure that safety belts are capable of tightly securing child 
safety seats. The requirement was adopted as a result of questions and 
concerns on the part of the public about the safety and effectiveness 
of child seats which can move during routine driving maneuvers when 
secured by safety belts that use an emergency locking retractor (ELR). 
NHTSA received petitions for reconsideration of this final rule from 
Jaguar and Toyota.

Jaguar Petition

    Jaguar's petition requested a one-year extension of the effective 
date of the final rule, or, in the alternative, a phase-in period 
requiring 90 percent compliance for the 1996 model year and 100 percent 
compliance for the 1997 model year. This request was made because ``the 
Jaguar XJS coupe will have less than 12 months of production remaining 
prior to the introduction of a new sports model'' at the time of the 
current effective date (September 1, 1995). To support this request, 
Jaguar stated:

    The XJS coupe is a low volume 2+2 sport coupe with very limited 
rear seat accommodation. The rear seating area is more suitable for 
very small children or extra luggage. This model does not meet the 
requirements of * * * final rule regarding child seat lockability in 
those rear seating positions. The rear seat belt installation is 
unique to Jaguar in the XJS coupe and * * * (t)he expenditure of 
finite engineering resource and manpower to redesign, develop, 
retool, and recertify a new and unique seat belt system for a low 
volume model, with less than one year of production life results in 
operation difficulties.

No other automobile manufacturer has reported that it will have a 
problem in meeting the lockability requirement. In fact, many 
manufacturers have already brought many of their vehicles into 
compliance with the new requirement.
    Since its petition contained very little detail about its attempts 
to comply with the lockability requirement, NHTSA contacted Jaguar for 
additional information. Jaguar provided confidential information about 
the various possible solutions it had explored and the anticipated cost 
of each solution. Jaguar noted that it had rejected one of the lower 
cost solutions because it believed that the belt design would be 
``adult user unfriendly.'' However, the Jaguar petition indicates that 
adults are unlikely users of the rear seating positions.
    NHTSA believes that Jaguar can solve the engineering problem 
associated with the XJS coupe belt design before the effective date. 
Jaguar has not indicated that the XJS coupe belt design cannot be 
engineered to comply with the requirement, only that its preferred 
solution would have a high cost. Given Jaguar's statement that the rear 
seating area is best suited for small children, the very population 
targeted for the benefits of the requirement, NHTSA believes that it is 
very important for these seating positions to comply with the 
requirement. Since Jaguar's problem is one of cost minimization and not 
practicability, and in light of the ability of all other manufacturers 
to meet the effective date, NHTSA has determined that granting the 
Jaguar petition would needlessly delay the benefits of the final rule. 
Therefore, this petition is denied.

Toyota Petition

    Toyota submitted a petition concerning a problem with testing a 
front passenger lap/shoulder belt. The inboard anchorage of Toyota's 
design is a ring attached to the emergency release buckle. The problem 
arises in part from the fact that the inboard anchorage is mounted on a 
flexible stalk. Depending on how the test procedure is conducted, the 
ring through which the belt webbing passes at that anchorage can move 
up or down the belt due to the flexibility of the stalk and the 
application of the test force to the lap belt portion. The movement of 
the ring up the webbing can affect the length of the lap belt portion 
and create an apparent noncompliance, even though little or no webbing 
has spooled off the retractor at the upper end of the shoulder belt 
portion of the belt assembly. Toyota explained that:

    The problem is caused by the slipping of the webbing at the 
buckle, which leads to changes in the measuring distance between 
points A and B. However, the measuring distance between point B and 
the retractor, and the belt path itself does not change appreciably.

    The test procedure in the final rule specifies that lap/shoulder 
belts are to be tested as follows:

--Buckling the safety belt assembly,
--``Locking'' the safety belt in accordance with the manufacturer's 
instructions in the vehicle owner's manual,
--Locating any point on the safety belt buckle or emergency release 
buckle (these buckles are located on the inboard side of the lap belt 
portion),
--Locating any point on the attachment hardware on the other end of the 
lap belt portion of the safety belt assembly (this hardware is located 
on the outboard side of the lap belt portion),
--Adjusting the lap belt portion of the safety belt assembly so that 
the length of webbing between these two points is the maximum possible 
with the belt system,
--Measuring that distance,
--Readjusting the lap belt portion of the safety belt assembly so that 
the length of the webbing between these two points is at least 5 inches 
less than the previously measured distance,
--Pulling on the lap belt portion of the ``locked'' belt with a 10 
pound pre-load using a webbing tension pull device,
--Again measuring the previously measured distance,
--Pulling on the lap belt portion of the ``locked'' belt with a 50 
pound force using a webbing tension pull device, and
--With the force still pulling on the belt, measuring the distance 
between the two points again.

The difference between the third and fourth measurements shall not 
exceed two inches.
    Toyota requested a change in the test procedure to either employ a 
surrogate child restraint as a test device or to add the following 
sentence to S7.1.1.5(c)(4):

    For belt webbing that is locked by a retractor ensure that the 
distance between points A and B is at the maximum length allowed by 
the belt system during application of the 10-lb pre-load.

In a February 18, 1994 letter to the agency, Toyota suggested a third 
possible solution, changing the direction of the pre-load application 
to 45 degrees.
    NHTSA believes that Toyota's problem is caused by a 
misunderstanding of the test procedure. Section S7.1.1.5(c)(2) 
specifies that the belt should be adjusted ``so that the webbing 
between points A (on the buckle) and B (on the attachment hardware at 
the other end of the lap belt portion) is at the maximum length allowed 
by the belt system.'' As demonstrated in a video supplied by Toyota in 
a meeting with NHTSA staff on November 29, 1993, this adjustment was 
made by adjusting the webbing so that the majority of it was within the 
lap belt portion and rotating the buckle upward along the webbing 
toward the shoulder belt portion.
    Section S7.1.1.5(c)(3) then specifies readjusting ``the belt system 
so that the webbing between points A and B is at any length that is 5 
inches or more shorter than the maximum length.'' The Toyota video 
depicted two different ways in which Toyota made this readjustment. In 
the first variation, the buckle was allowed to rotate downward toward 
the lap belt portion as webbing was spooled back onto the retractor for 
S7.1.1.5(c)(3). Then, when the load was applied, the buckle rotated 
upward so that the ring on the buckle rode up along the webbing, 
increasing the length of the lap belt portion even though, as noted 
above, little or no webbing had spooled off the retractor. In the 
second variation, the buckle was not allowed to reposition itself as 
the webbing was spooled back onto the retractor for S7.1.1.5(c)(3). 
Thus, the buckle did not rotate when the load was applied. The only 
change, if any, in the length of the lap belt portion was due to 
webbing spooling off the retractor. As explained below, Toyota should 
not have allowed the buckle to reposition itself in the first 
variation.
    The specification in S7.1.1.5(c)(3) that the webbing between points 
A and B be at any length that is 5 inches or more shorter than the 
maximum length was added to ensure that the test would not indicate 
compliance only because there was no webbing left to spool off the 
retractor. Thus, the adjustment in S7.1.1.5(c)(3) should only involve 
spooling webbing back onto the retractor. If any other adjustments to 
the orientation of any other portion of the belt system are made for 
S7.1.1.5(c)(2), the adjusted portions should not be further changed. 
Thus, Toyota should not allow the buckle to rotate downward, as it did 
in the first variation. As the video demonstrated, when the buckle was 
not allowed to rotate downward in the second variation, the apparent 
problem did not occur. Therefore, the agency is denying this petition 
also.

    Issued on March 23, 1994.
Barry Felrice,
Associate Administrator for Rulemaking.
[FR Doc. 94-7351 Filed 3-24-94; 12:23 pm]
BILLING CODE 4910-59-M












[Federal Register Volume 59, Number 79 (Monday, April 25, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: X94-40425]


[[Page Unknown]]

[Federal Register: April 25, 1994]


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DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

49 CFR Part 571

[Docket No. 87-08; Notice 10]
RIN 2127-AF27

 

Federal Motor Vehicle Safety Standards; Occupant Crash Protection

Correction

    In rule document 94-7351 beginning on page 14569, in the issue of 
Tuesday, March 29, 1994, in the first column, the agency heading should 
read as set forth above.

BILLING CODE 1505-01-D


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