Replacement Seatbelt - Petition

8/10/2019 Replacement Seatbelt - Petition

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October 25,20 10

Mr, Daniel C. Sm ith

Associate Administrator for Enforcement

National Highway Traffic Safely Administration

1200 New Jersey Av enue, SE

West Building

Washington, DC 20 590

RE: Petition for a Determination of Inconsequential Noncompliance with FM VSS 209

S4.1(k) Installation Instruction and

(1)

Usage and Maintenance Instructions

Dear Mr. Smith:

Pursuant to the requirements of 49 C.F.R Part 556, Mitsubishi M otors No rfi Am erica,

Inc. hereby requests exemption from the notification and remedy requ irements of the Safety

Act U.S.C Section 30118(d) and 30120(h) for failure to comply with certain provision of

FMVSS 209, which was identified in the Part 573 report dated O ctober

25,

2010 submitted

to NHTSA. Mitsubishi believes that the noncompliance in question is inconsequential as it

relates to motor vehicle safety.

ParagraphS4.1 (k) of FM VSS 20 9 requires that a service seat belt assembly, other than a

seat belt assembly installed in a motor vehicle by an automobile manufacture, shall be

accompanied by an instruction sheet providing suficient information for installing the

assembly in a motor vehicle. The installation instructions shall state whether the assembly is

for universal installation or for installation only in specifically stated motor vehicles, and

shall include at least those items specified in SAE Recommended Practice JSOOc, Motor

Vehicle Seat Belt Installations, November

1973.

If the assembly is for use only in

specifically stated motor vehicles, the assembly shall either be permanently and legibly

marked or labeled with the following statement, or the instruction sheet shall include the

following statement;

This seat belt assemb ly is for use on ly in [insert specific seating pos ition(s), e.g., firont

right ] in [insert specific veh icle make(s) and model(s)].

Paragraph S4.1(1) of FMVSS 209 requires that a seat beh assembly or retractor shall be

accompanied by written instructions for the proper use of the assembly, stressing particularly

the importance of w earing the assembly snugly and properly located on the body, and on the

maintenance of

the

assembly and periodic inspection of

all

components.
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NHTSA consider this petition and grant an exemption from the notification and remedy

requirement of the Safety Act.

Sincerel

Tom Bennett, Director, Service

Mitsubishi Motors North Am erica, Inc.

Telephone 714-372-5554

Email: [email protected]
mailto:[email protected]:[email protected]


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MOTORS

October 25,2010

Mr. Daniel C. Smith

Associate Administrator for Enforcement

National Highway Traffic Safety Administration

1200 New Jersey A venu e, SE

West Building

Washington, DC 20590

RE:

Noncom pliance Information R eport for R eplacement Seat Belt Assem blies

Dear Mr. Smith:

Pursuant to Part 573 of Title 49 of the code of Federal Regu lation, Defect and

Noncompliance R eports, Mitsubishi Motors of North Am erica, Inc. (MMNA) submits the

following information concern ing a noncompliance with the instm ction requiremen t of

FMVSS 20 9 SecUon S 4.1(K) and S4.I(1).

Sec.573.6 (c) (I) -Manufacture's name

Mitsubishi Motors Corporation

Mitsubishi Motors North of America

Sec.

573.6 (c) (2)- Potenfiallv Affected Seat Belt Assemblies

Unknown n um ber of replacement seat belt assemblies which have been delivered by

Mitsubishi for use in the U nited States did not comply with the section o f FMV SS 209 cited

above.

Sec.

573.6 (c^ f3)-Estimated Pooulaticm of Seat Belt Assemblies Potentially Affected

Mitsubishi has not been able to identify the number of affected package of replacement

seat belt assemblies for replacement parts in various model and model year of Mitsubishi

vehicles. Because mo st of these seat belt assemblies supplied for service ha ve no t been used

as warranty replacement parts, it is not possible for Mitsubishi to identify the individual

vehicle to which these p arts ha ve been installed.

Sec.

573.6 (c) (4)- Estimated P ercentage of Affected Seat Belt Assemblies w ith the condition

Unknown
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Sec. 573.6 Ccl ('5VDcscription of N on-com pliance

Paragraph S4.1(k) ofFMVSS209 requires that a service seat belt assembly, other than a

seat belt assembly installed in a motor vehicle by an automobile manufacture, shall be

accompanied by an instruction sheet providing sufficient information for installing the

assembly in a motor v ehicle. T he installation instructions shall state wh ether the assembly is

for universal installation or for installation only in specifically stated motor vehicles, and

shall include at least those items specified in SAE R ecomm ended P ractice JSOOc, Mo tor

Vehicle Seat Belt Installarions, November 1973. If the assembly is for use only in

specifically stated motor vehicles, the assembly shall either be permanently and legibly

maiked or labeled with the following statement, or the instruction sheet shall include the

following statem ent;

This seat belt assem bly is for use only in [insert specific seating position(s), e.g., fi-ont

right ] in [insert specific v ehicle make(s) and mo del(s)].

Paragraph S4.1(I) of FMV SS 209 requires that a seat belt assembly o r retractor shall be

accompanied by w ritten instructions for the properuseof the assem bly, stressing particularly

the importance of wearmg the assembly snugly and properly located on the body, and on the

maintenance of the assem bly and periodic inspection of all com ponents.

Service seat belt assem blies for various model and model year M itsubishi vehicles were

sold in the U nited States w ithout the installation, usage and m aintenance instruction

referenced in S4.1 (k) and S4.1 1)of FMVSS 209.

Sec.

573.6 (c) (7VBasis of Non-com pliance determination

Upon review of the seat belt assemblies in inventory in the Parts Distribution Center,

Mitsubishi Motors Corporation found that there is no instruction sheet regarding the

installation of the seat belt and its proper use and maintenance.

As a result oftheinvestigation, Mitsubishi determined that replacem ent seat belt assemblies

produced for use in the United States did not meet the requirements of FMVSS 209 S4,l(k)

and S4.1(l).

Mitsubishi conducted rework actions for all service seat belt assemblies in inventory in the

Parts Distribution Center, by adding the required installation, usage and maintenance

instructions.

Sec. 573.6 (c) f8iii)-N otification of Intent to file a Petition for Exem ptionfix mNotification

and remedv requirements

Mitsubishi will submit a petition for exemption from the notification and remedy

requirements of the statute withh\ 30 days on the ground that this noncompliance is

inconsequential as it does n ot present a risk to motor vehicle safety for the following reasons;


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Replacement Seatbelt - Petition