Replacement Seatbelt - Petition
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8/10/2019 Replacement Seatbelt - Petition
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M i ts u b i s h i M o r o n N o r th A m e r tc o ,f n c .
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Cyprasa CA 90630
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Bffi^' . S O P c R W l O N S
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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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M i ts u b i s h i M o t o r s N o r th A m e r i c a , I n c .
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Oy p re s i CA 9 0 0 3 0
TelflfiAQno: 7M-372-aOOO
WT S UBiS HI www.mlt8Ub)8h icar6 jm
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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