Interpretation ID: nht92-9.23

DATE: February 5, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: William A. Boehly -- Associate Administrator for Enforcement, NHTSA

COPYEE: Associate Administrator for Rulemaking; Director, Office of Vehicle Safety Compliance

TITLE: Subject: ACTION: OVSC's Request for Legal Interpretation, FMVSS 210

TEXT:

This responds to the December 20, 1991, request from the Director of the Office of Vehicle Safety Compliance for an interpretation of the phrase "the nearest contact point of the belt with the hardware attaching it to the anchorage" in S4.3.1.1 of Standard No. 210 as it applies to a conversion van manufactured by Glaval, Inc.

These Glaval vans have seats in which a rigid metal bracket is attached to the anchorage by means of a bolt on one end and the webbing of the belt passes through the rigid metal bracket at the other end. The rigid metal brackets can pivot around the bolt, depending on how tightly the bolt is fastened down. Regardless of how much the bolt is tightened, it would seem that the bracket would pivot if the belt system were restraining an occupant in a crash.

S4.3.1.1 of Standard No. 210 requires a line from either the seating reference point or another point to the nearest contact point of the belt with the hardware attaching it to the anchorage to form an angle with the horizontal of not less than 20 degrees and not more than 75 degrees. The issue in this instance is whether the "nearest contact point of the belt with the hardware attaching it to the anchorage" should be determined with reference to where the webbing passes through the upper end of the rigid metal bracket or with reference to the bolt on the lower end of the rigid metal bracket.

Previous agency interpretations have defined the "nearest contact point of the belt with the hardware attaching it to the anchorage" as the contact point between the webbing and the metal or rigid plastic hardware which is nearest the SgRP. Applying this concept to the design in question would result in the nearest contact point being determined with reference to the upper end of the rigid metal bracket through which the belt webbing passes.

An exception to this general rule is belt designs with flexible wire stalks. Even though these stalks are typically plastic-coated metal, the wire stalks are more akin to webbing (because of their flexibility) than to metal or rigid plastic hardware. Because of this flexibility, NHTSA has said that the nearest contact point for these wire stalks is not the upper end of these stalks where the webbing contacts it, but the lower end of the stalk where it is anchored to the vehicle.

In addition, NHTSA said in a February 15, 1973 letter to Mr. Kato of Nissan that, if a rigid bracket can be rotated around its attachment bolt, the centerline of the attachment bolt would be considered the "nearest contact point" for the purposes of S4.3.1.1 of Standard No. 210.

It is my opinion that the letter to Nissan is of general applicability to safety belt systems in which the terminal hardware on the belt is free to pivot around the anchorage bolt. The purpose of the anchorage location requirement is to ensure that the webbing crosses an occupant's body at an angle that is neither too shallow or too steep. The effective angle of the webbing is determined by the nearest point on the vehicle that does not alter its location under the influence of non-crash stresses on the webbing. In the case of the Glaval vans, as in the Nissan situation, the anchorage bolt is the fixed point around which the belt and its related hardware pivot and should be used as the "nearest contact point" under S4.3.1.1 of Standard No. 210.

You should note that my opinion is premised on the assumption that the metal bracket used by Glaval is free to pivot around the anchorage bolt. If the bracket were fixed in place, the "nearest contact point" for purposes of S4.3.1.1 would be the point at which the webbing contacts the upper end of the bracket.