Interpretation ID: aiam2943
Mercedes-Benz of North America
Inc.
One Mercedes Drive
P. O. Box 350
Montvale
NJ 07645;
Dear Mr. Gerth: This responds to your letter of December 19, 1978, asking whether manually adjustable seat belt anchorage for the upper torso portion of a 3-point safety belt is permissible under Safety Standard No. 210, *Seat Belt Assembly Anchorages*. You state that this new anchorage is adjustable over a certain range and is intended to increase wearing comfort by providing a better 'fit' for all occupants.; We have reviewed the drawings and specifications enclosed with you letter and determined that the proposed adjustable anchorage design would not be precluded by Safety Standard No. 210 if the design meets the following two conditions: (1) the anchorage complies with the zone location requirements of the standard in any of the positions to which it can be adjusted, and (2) the anchorage complies with the strength requirements of the standard at all times, even when the adjusting mechanism (bolt) is in its loosened status. There is nothing in the standard that prevents the use of adjustable anchorages, per se.; From discussions with your engineers, we found that the proposed desig would require the use of a tool to tighten the adjusting bolt. We are concerned that this feature could reduce potential increases in belt use. For example, if driver A adjusts the belt anchorage to its lowest position, will driver B readjust the belt when he enters the car if the two drivers are of different sizes and the lowest position is uncomfortable for driver B? If the readjustment requires the use of a wrench to loosen and retighten the anchorage bolt, will driver B simply choose not to wear the belt? We believe that a manually adjusting anchorage that does not require the use of tools would be a preferable design in terms of potential seat belt use.; The agency is of course very interested in any seat belt design tha will increase comfort and convenience and, thereby, seat belt use. Therefore, we encourage innovative designs. Please keep us informed about the progress of your work on your new anchorage system.; The National Highway Traffic Safety Administration hereby grants you request for confidential treatment of the drawings included in your letter (enclosures 1, 2 and 4). We have preliminarily determined that the drawings and specifications contain privileged commercial information that is exempt from disclosure under 5 U.S.C. 552(b)(4).; Sincerely, Joseph J. Levin, Jr., Chief Counsel