Interpretation ID: 86-1.3

TYPE: INTERPRETATION-NHTSA

DATE: 01/02/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ms. Patricia Hill

TITLE: FMVSS INTERPRETATION

TEXT:

Ms Patricia Hill 2150 Hacker Road Howell, Michigan 48843

Thank you for your letter of September 19, 1985, asking about the effect of our regulations on a safety belt design you have seen. You explained that the design uses "a rigid member to support a webbing guide near the shoulder of a front seat occupant. This rigid member was rigidly attached to the roof of the vehicle." You asked several questions about this design, which are answered below.

You first asked whether the rigid member would be considered a seat belt anchorage, a piece of attachment hardware or a common component for the purposes of our standards. We cannot provide a definitive answer without having further details about and preferably a drawing of the structure. Based on the information you have provided, it appears that the rigid member would be an anchorage.

Standard No. 210, Seat Belt Assembly Anchorages, defines an "anchorage" as a device that transfers safety belt assembly load to the vehicle structure. Since the rigid member is attached to the roof at one end and to a safety belt webbing guide at the other, it appears to be intended to transfer loads to the vehicle structure. Thus, it would have to meet the strength and location requirements of the standard.

You also asked if one or both ends of the rigid member are required to meet the upper torso restraint location requirements of S4.3.2 of Standard No. 210. If, as discussed above, the rigid member is intended to transfer loads, then it would have to meet the location requirement of S4.3.2. That section states that the "anchorage for the upper end of the upper torso restraint shall be located within the acceptable range" shown in Figure 1 of the standard. The purpose of the requirement is to specify the angle at which the shoulder belt crosses the occupant's chest. Thus, the portion of the anchorage that controls the angle of the shoulder belt must be within the zone specified in Figure 1.

I hope this information is of assistance to you. If you have further questions, please let me know.

Sincerely, Erika Z. Jones Chief Counsel

2150 Hacket Road Howell, Michigan 48843 September 19, 1985

Mr. Jeffrey R. Miller Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, D.C. 20590

Dear Mr. Miller:

This requests an interpretation of the requirements of FMVSS Nos. 209, Seat Belt Assemblies and 210, Seat Belt Assembly Anchorages.

Recently a proposed Type 2 continuous loop seat belt installation was inspected that used a rigid member to support a webbing guide near the shoulder of a front seat occupant. This rigid member was rigidly attached to the roof of the vehicle.

I am aware two previous requests for interpretation (Ford and Toyota) have been made that have some measures of similarity to the present issue. However, both the Ford and Toyota cases differed significantly from the subject seat belt assembly; webbing was used vice a rigid member to locate a webbing guide near the shoulder of a front seat occupant.

Following are my specific requests for interpretation.

1. Is the above described rigid member a seat belt anchorage, a piece of attachment hardware, or possibly a common component?

2. Are one or both ends of the rigid member required to meet the upper torso restraint location requirements of FMVSS No. 210, Section 4.3.2? Sincerely, Patricia Hill