Interpretation ID: nht78-3.13

DATE: 02/13/78

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Emil M. Mrak

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 12, 1977, to Secretary of Transportation, Mr. Brock Adams, concerning the seat belts in your automobile.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, requires that the distance between the lap-shoulder belt intersection and the vertical centerline of a 50th percentile (164 pounds, 5 feet 8 inches) adult male occupant must be at least six inches when the seat is in its rearmost position. The purpose of this requirement is to reduce the risk of the occupant "submarining" out from under the belt and to reduce the possibility of the shoulder belt pulling the lap belt up onto the abdomen where it could cause serious injury in a crash.

The possibility of submarining increases as the intersection of the lap-shoulder belt is moved toward the occupant's center-line and/or as seat cushion rigidity is reduced. In other words, the closer the intersection of the lap-shoulder belt is to the centerline of the occupant, and the softer the seat, the more the danger of "submarining" in a crash. The standard does not limit the maximum distance from the occupant's centerline to the lap-shoulder belt intersection because of varying degrees of seat rigidity and installation configurations. Thus, contrary to what you may have been told, manufacturers who provide belt systems with distances greater than six inches do so by choice and not because they are required to do so by Federal standards.

Thank you for informing us of your problem.

SINCERELY,

December 12, 1977

The Honorable Brockman Adams The Secretary of Transportation

Dear Mr. Adams:

Sometime ago I wrote the Ford Company complaining about the inaccessibility of the short portion of the seat belt to a person who is up in years. I pointed out that because of the extreme difficulty of hitching these up, more and more people are failing to use seat belts. Furthermore, the twisting and squirming required could very well result in backbone injuries to elderly people.

I was astounded to receive a letter from the Ford Company indicating that the Federal Standards required such a belt. This is hard for me to believe. In any event, I would appreciate knowing if what they told me is the truth, and if it is, then, the truth, I would strongly recommend that this requirement be revised. If it is not a requirement, then I think the Ford Company should be told to take the blame off the Department of Transportation.

If Congressional help is needed to make such a change, I would be glad to pursue it.

I am enclosing copies of my letter to Mr. Wilson of the Ford Company and also his reply, which as indicated above, astonished me.

Emil M. Mrak

ENCLS.

December 12, 1977

A. S. Wilson Ford Parts and Service Division Ford Motor Company

Dear Mr. Wilson:

I am enclosing a copy of a letter I have written to the Secretary of Transportation, Brockman Adams, which is self-explanatory.

I feel so strongly in this matter that I would go to certain of my friends in Congress, if need be, and as much as I dislike most of the things that Nader does, I would even be willing to go to him.

Emil M. Mrak

ENC.

Ford Parts and Service Division Ford Motor Company

November 23, 1977

Emil M. Mrak

Dear Mr. Mrak:

We are sorry to learn of the problem you are experiencing using the seat belts in your Cougar Brougham. As you probably know, the Ford Motor Company has been an active proponent of the use of seat belt systems for many years. Ford does not have complete freedom, however, in selecting the design of the seat belt system since the Federal government does impose requirements that seat belt systems must meet. An explanation of certain of these requirements may be helpful in giving you a better understanding of why present seat belt systems are different than those you may have been accustomed to using.

For all passenger vehicles built after January 1, 1972, Federal safety standards require the installation of a three-point seat belt system; that is, a combination lap belt and shoulder harness. The Federal standard also requires that the intersection or attaching point of the shoulder harness to the lap belt be at least six inches from the centerline of an average size adult male. In the opinion of the Federal authorities, this intersection point offers the best protection to occupants using the shoulder harness. In order for Ford to satisfy this requirement, it is necessary to limit the length of the buckle portion of the lap belt.

It is clear from your letter that shortening the buckle portion of the lap belt has created a problem for some people. We regret the inconvenience but hope that it will not deter you from continuing to use the seat belt system when operating your vehicle.

We appreciate the interest you have shown in this matter and thank you for giving us the opportunity to respond to your questions.

A. S. Wilson Owner Relations

November 10, 1977

A. S. Wilson Ford Parts and Service Division Ford Motor Company

Dear Mr. Wilson:

In May I wrote to you concerning problems with my seat belts in the new Cougar Brougham we had just purchased. You replied on May 17 indicating that I should return to the selling dealer with the complaint.

First of all, I thought I made it clear in my letter that I was not complaining. I was asking for an improvement. In any event, I had the dealer refer to Ford Technical Service Bulletin 100, Article 1290, as indicated in your letter, and this advice was completely useless, and the dealer, as far as I'm concerned, was helpless.

The real problem with the seat belt is that the part attached to the seat is so short that a person of my age finds it literally impossible, or at least very difficult, to squirm around and get it attached.

I am taking the liberty of writing this second letter to you because I have read that fewer and fewer people are using seat belts. I am certain it is because of the fact that it is so difficult to use them. In order to use the belt I must squirm and fuss and work and finally I get it attached. Some day I may well injure a spinal disk.

I think this is a problem for the Ford engineers. When I wrote to you I was asking for an extension so it would be easier to attach them, but I did not get an iota of help from you.

I feel that if anyone not using the belt because of this difficulty should get into an accident and be injured, that person would have a case for suit against the Ford Company because of the inadequacy of the belt hook-ups.

I have felt like writing to the Transportation Department and also to Senator Eagleton, but since I am a stockholder in Ford, I thought I had better wait until I get another reply from you.

Emil M. Mrak

cc: BRUCE WILLIAMS