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.
J.B. - Comments
This is comment on Rule
Federal Motor Vehicle Safety Standards; Occupant Crash Protection
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