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

Dear Mr. Busick:

This responds to your letter of February 2, 1995, asking three questions regarding the anchorage location requirements in Standard No. 210, Seat Belt Assembly Anchorages.

Your first question concerns S4.3 of Standard No. 210 which states, "(a)nchorages for seat belt assemblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208 ... are exempt from the location requirements of this section." You asked whether a manual 3-point belt installed at a seating position with an air bag is considered a seat belt assembly that meets the frontal crash protection requirements of S5.1. Assuming that the vehicle is certified to the requirements of Standard No. 208 using the air bag, the answer is yes.

Your second question asks what is meant by the phrases "belt bears upon the seat frame" and "does not bear upon the seat frame" in S4.3.1.1 and S4.3.1.2 of Standard No. 210. You stated that examples would be useful. NHTSA has previously said that the phrase "bears upon the seat frame" "refers to seat belt assemblies in which the seat belt presses or rests directly on the main structural frame of the seat." If a more specific answer is needed in the context of a specific design, please send us information on the design in question.

Your third question asked whether the anchorage in a drawing which accompanied your letter complies with the location requirements in S4.3.1.1(a) of Standard No. 210. Section S4.3.1.1(a) states:

If the seat is a nonadjustable seat, then a line from the seating reference point to the nearest contact point of the belt with the anchorage shall extend forward from the anchorage at an angle with the horizontal of not less than 30 degrees and not more than 75 degrees.

As your letter correctly explains, prior to a recent amendment, this section in referring to "anchorage," referred to the "nearest contact point of the belt with the hardware attaching it to the anchorage." That amendment was a result of an amendment of the definition of "seat belt anchorage" to include hardware in the definition. Thus, the amendment was not intended to change the location of the "nearest contact point." In reviewing your drawing, the part labeled "belt and buckle assy." appears to be the belt for purposes of S4.3.1.1(a). While it is somewhat unclear in your drawing, it appears that the "nearest contact point" is either the part labeled "belt and buckle pivot/fixing" or the oval part around that part and adjacent to the part labeled "belt and buckle assy." In either case, the "line from the seating reference point to the nearest contact point" would be within the permissible range of angles.

I hope you find this information 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

ref:210 d:4/3/95 August 25, 1981, letter to Mr. Roger E. Maugh, Ford Motor Company. This letter, a copy of which is enclosed, discusses one example of a design which did not bear upon the seat frame.