Federal Motor Vehicle Safety Standards; Occupant Crash Protection |
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Topics: Federal Motor Vehicle Safety Standards
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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