Interpretation ID: aiam1135
Director
Automotive Safety Office
Ford Motor Company
Dearborn
MI 48121;
Dear Mr. Eckhold: By petition for rulemaking dated November 15, 1973, the Ford Moto Company requested an amendment of Motor Vehicle Safety Standard No. 210 with respect to the strength required of the anchorages for the pelvic portion of a Type 2 seat belt assembly. After considering the merits of the requested amendment, we have decided to deny your petition.; As stated in your petition, the anchorages for the pelvic portion of Type 2 assembly are presently subject to two strength requirements under Standard 210. Section S4.2.2 provides that, when tested in conjunction with the upper torso anchorage, the pelvic anchorages must withstand a force of 3,000 pounds applied through the seat belt assembly. Section S4.2.1 provides that, when tested separately from the upper torso anchorage, the pelvic anchorages must withstand a force of 5,000 pounds applied through the seat belt assembly.; It is Ford's position that the 5,000 pound requirement of S4.2.1 wa intended to be applicable to anchorages used with Type 2 assemblies having detachable shoulder belts, and that it was not intended for use with integral Type 2 assemblies. Although the NHTSA would agree that the most widely used Type 2 assembly at the time of the standard's adoption had a detachable shoulder belt, the agency does not agree that the 5,000 pound requirement should be limited to anchorages used with such belts.; The 1974 model year will be the first in which integral Type 2 belt are installed in all passenger cars. We anticipate that a measurable percentage of persons riding in cars with the new belts will somehow avoid using the shoulder belt, thereby placing the lap belt under the same potential stress as any other lap belt when used by itself. In light of this possibility, and in consideration of the fact that keeping the pelvic anchorage force at the currently required level of 5,000 pounds will not impose additional manufacturing costs on manufacturers, we do not consider it advisable to grant the requested amendment at this time.; The petition of Ford Motor Company for an amendment of S4.2.1 of Moto Vehicle Safety Standard No. 210 and for a complementary amendment to the test procedures of S5.1 of the standard is therefore denied.; Sincerely, James E. Wilson, Associate Administrator, Traffic Safet Programs;