Interpretation ID: nht89-1.82

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/89

FROM: JOHN WOODDELL

TO: CHIEF COUNSEL NHTSA

TITLE: INTERPRETATION OF STANDARD 208 AS APPLIED TO 1978 DODGE RAMCHARGER

ATTACHMT: ATTACHED TO LETTER DATED 06/21/89 FROM STEPHEN P. WOOD -- NHTSA TO JOHN WOODDELL; REDBOOK A33; STANDARD 108 [A][1][A]; STANDARD 108 [A][2][A]; STANDARD 108 [B][1]; STANDARD 208

TEXT: Dear Sir:

I was referred to your office for a written interpretation of Standard 208 by Mr. Guy Hunter, in the Crashworthiness Division. Mr. Hunter was kind enough to go over the Standard with me by telephone and reported his opinion concerning the application of the Standard to the vehicle with which I am concerned.

The question for consideration is:

What type of seat belt assembly should have been installed in a 1978 model Dodge Ramcharger?

The subject vehicle was manufactured in November 1977. It is a four wheel drive vehicle, with a gross vehicle weight of approximately 6,000 lbs. It is a two door vehicle with a hard top and enclosed sides. In general appearance, it would be comparable to the Chevrolet Blazer or the Ford Bronco. We understand that it fits within the designation "multi purpose passenger vehicle" for purposes of Standard 208.

Based on my conversation with Mr. Hunter, I arrived at the following interpretation of the standard:

Section S4.2.2 is controlling, and that said section requires that the vehicle comply with one of the three options set out in Section S4.1.2. The "first option" and "second option" refer to passive type restraint systems; those would be sufficient f or this vehicle, but were, as a matter of custom and practice not used in the time periods involved here. The "third option" requires either (1) a lap and shoulder belt assembly, or

(2) a lap belt system designed to withstand a special test requirement relative to crash protection and injury force criteria, set out in Section S5.1. Of these two alternatives, the lap belt and special test criteria option was seldom or never used i n the time period involved here. Accordingly, as a practical matter, the subject vehicle would be expected to have a lap and shoulder belt assembly.

If the interpretation arrived at from my discussion with Mr. Hunter is accurate, I would appreciate receiving a letter from your office confirming that interpretation.

If further information is needed or I can be of assistance in expediting this request, please do not hesitate to contact me.

Thank you for your assistance.

Very truly yours,