Interpretation ID: 86-1.4

TYPE: INTERPRETATION-NHTSA

DATE: 01/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. R. C. Attwood

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. R. C. Attwood ASE (UK) Ltd. Norfolk Street Carlisle, Cumbria ENGLAND CA2 5HX

Dear Mr. Attwood:

Thank you for your letter of October 8, 1985, concerning the safety belt: anchorage requirements of Standard No. 210, Seat Belt Assembly Anchorages. You asked a question about the anchorage requirements that would apply to a two point automatic safety belt, which has a separate manual lap belt. You asked if it is permissible for the two anchorages of the automatic belt and the two anchorages of the manual lap belt to be located outside of the zones specified in Standard No. 210, if three additional anchorages are located within Standard No. 210's zones. As explained below, the design you described would be permissible, assuming that you are voluntarily providing the manual lap belt.

Section S4.1.1 of the standard requires anchorages for a Type 2 safety belt to be provided at each front outboard seating position. Sections S4.3.1 and S4.3.2 set out the location requirements for Type 2 belts. However, S4.3 provides that the anchorages for automatic restraints which meet the frontal crash protection requirements of Standard No. 208, Occupant Crash Protection, do not have to meet the location requirements of the standard.

In interpreting the location requirement, the agency has said that all of the anchorages for an automatic belt may be located outside of the zones specified in Standard No. 210, as long as there are the three anchorages for a Type 2 safety belt located within the zone. Since your design for the automatic belt would provide three anchorages within the required zone, it would be permissible as long as the anchorages meet the strength requirements of the standard.

If you are voluntarily providing the manual lap belt, then its anchorages would not have to comply with Standard No. 210 as long as the use of the lap belt would not degrade the ability of the automatic lap belt to comply with Standard No. 208. However, if you are providing the lap belt to comply with the requirements of S4.1.2.1(c) of Standard No. 208, then the lap belt would have to have anchorages complying with Standard No. 210.

I hope this information is of assistance. If you need further information please let me know.

Sincerely, Erika Z. Jones Chief Counsel

Our Ref: RCA/EC 8th October, 1985

The Chief Counsel U.S. Dept. of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington D.C. 20590 U.S.A.

Dear Sir,

FMVSS 208 a Seat Belt Anchorages

We seek your assistance in resolving a query about the location and number of anchorages in a passenger vehicle fitted with a two point automatic seat belt (passive restraint), and an active lap belt.

We wish to know if it is permissible for both anchorages of the two point automatic belt and both anchorages of the active lap belt to be situated outside the zones stipulated in FMVSS 210 on condition that three additional anchorages are provided in the zones specified in FMVSS 210.

Your early response to our questions will be very much appreciated.

Yours faithfully, R. C. Attwood Quality Assurance Director