Mr. Randal Busick
President
Vehicle Science Corporation
315 East Eisenhower Parkway, Suite 211
Ann Arbor, MI 48108

Dear Mr. Busick:

This responds to your letter of October 14, 1994, concerning whether a belt design would comply with S7.1.2 of Standard No. 208, Occupant Crash Protection, as amended in a final rule published on August 3, 1994 and effective on September 1, 1997 (59 FR 39472). As described in your letter, for this belt design, "the inboard lower FMVSS 210 anchorage is located on the seat frame and thus, as the seat moves fore and aft, the system allows a minimum of two seat belt adjustment positions and the distance between the two extreme adjustment positions of the system is more than 5 cm."

The August 3 final rule amended Standard No. 208 to improve the fit and increase the comfort of safety belts for a variety of different sized occupants. After the effective date, S7.1.2 will, in pertinent part, read as follows:

... for each Type 2 seat belt assembly which is required by Standard No. 208 (49 CFR 571.208), the upper anchorage, or the lower anchorage nearest the intersection of the torso belt and the lap belt, shall include a movable component which has a minimum of two adjustment positions. The distance between the geometric center of the movable component at the two extreme adjustment positions shall be not less than five centimeters, measured linearly.

As illustrated in the drawing provided with your letter, the inboard anchorage on your seat design is the "the lower anchorage nearest the intersection of the torso belt and the lap belt."

It would appear that, under the definition of "seat belt anchorage" in Standard No. 210, Seat Belt Anchorages, the seat would be considered part of the anchorage for your design. Standard No. 210 defines a "seat belt anchorage" as

any component, other than the webbing or straps, involved in transferring seat belt loads to the vehicle structure, including, but not limited to, the attachment hardware, seat frames, seat pedestals, the vehicle structure itself, and any part of the vehicle whose failure causes separation of the belt from the vehicle structure.

If the seat is part of the anchorage, and if the seat can be adjusted more than 5 cm, measured linearly, it appears that your design will meet the requirement of S7.1.2.

While not directly relevant to your question, agency technical staff raised concerns about a device in the drawing enclosed with your letter. The drawing of the system shows a device labeled "Slider Bar" to which the outboard lower end of the seat belt anchorage is attached. While no detail is provided on this device, agency staff are concerned that the device (which appears to function as the lower outboard anchorage) allows the seat belt webbing attachment to slide freely fore and aft longitudinally. If our interpretation of the drawing is correct, this device may prevent the belt system from meeting the occupant protection requirements of Standard No. 208, as well as prevent the anchorage from meeting the anchorage location requirements of S4.3 of Standard No. 210. Finally, the device may introduce slack in the belt system, preventing the belt from adequately securing a child safety restraint in the seat or providing complete protection to an adult.

I hope this information has been helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Philip R. Recht Chief Counsel

Enclosure

ref:208 d:1/5/95