J.B. - Comments

Document ID: NHTSA-2008-0149-0008
Document Type: Public Submission
Agency: National Highway Traffic Safety Administration
Received Date: September 30 2008, at 03:34 PM Eastern Daylight Time
Date Posted: October 1 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: September 12 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: November 12 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 8072f371
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I support the Notice of Proposed Rulemaking that will remove the sunset provision of FMVSS 208 regarding the lockability of seat belts for the purpose of securely anchoring child restraints. Lockable seat belts have been our standard since model year 1996; please continue to require them in all passenger seating positions. Lockable seat belts reduce injury, death & healthcare costs, are familiar to a generation of drivers, and are good public policy. Lockable seat belts are essential in seating positions where lower anchorages are provided because lower anchorages are not strong enough to secure heavier children. Correctly used restraints with 5-point harnesses are safer for vehicle occupants. High Weight Harness restraints are an excellent choice for children who exceed lower anchorage weight limits; these restraints are best secured with lockable seat belts. Lockable seat belts maximize the number of persons who can be safely restrained. In many cases, use of lower anchorages reduces the overall number of seating positions available in the vehicle (due to encroaching on adjacent seating positions). Since the leading cause of death in motor vehicle crashes is being inappropriately restrained/un-restrained, it is essential to keep lockable seatbelts in all passenger seating positions. The only change I would like to see to FMVSS208 is to require concise text or graphics on the webbing of each switchable locking retractor-type seat belt which indicates how to put the seat belt in locking mode to secure a child restraint. Thank you for continuing to engage the public in reducing the leading cause of unintentional death in children and many adults.

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