Interpretation ID: nht71-2.23

DATE: 04/01/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: American Safety Belt Council, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 25, 1970, concerning Motor Vehicle Safety Standard No. 213, which was amended on September 23, 1970 (35 F.R. 14778), and Docket No. 2-15, Notice 5, which was published on the same day. In your letter you state that while S4.4 of Standard No. 213 presumes the continued availability of factory-installed seat belt assemblies, recent proposals on passive restraint systems say result in the reasonsibility for the installation of seat belts passing from the automobile manufacturer to the buyer of children's seats. You are apparently concerned that should this occur, there is insufficient guidance presently available to the customer on having installed in his vehicle a seat belt assembly for use with a child seat. While the Administration does not as a general rule comment on docket submissions, we believe you have raised an important issue, one for which a response is appropriate.

Under the recent amendment to the occupant crash protection standard, which was published March 10, 1971 (36 F.R. 4600), manufacturers will have the option of using seat belt assemblies to meet restraint requirements until August 1975. At present, we anticipate that most manufacturers will in fact continue to use seat belt assemblies until that time. Consequently, we do not believe modification of Standard No. 213, which you suggest in your letter, is presently necessary. Furthermore, there are other motor vehicle safety standards, which we intend to retain, that would eliminate much of the problem with which you are concerned. Thus, while seat belt assemblies would no longer be required as standard equipment, passenger cars would still be required pursuant to the provisions of Motor Vehicle Safety Standard No. 210, to be manufactured with seat belt assembly anchorages that provides a location designed specifically for the attachment of seat belt assemblies and that

can be used by a consumer in the installation of aftermarket seat belts. Moreover, Motor Vehicle Safety Standard No. 209, "Seat Belt Assemblies," as you know, requires each aftermarket seat belt assembly to contain attachment hardware and instructions for installing the assembly in the vehicle. These requirements together provide consumers with sufficient information and materials for them to have seat belts properly installed for use with a child seating system. If problems do arise in the future that these requirements do not fully deal with, appropriate steps will be taken at that time.

Thank you for your continued interest in motor vehicle safety.