Interpretation ID: 10695

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 February 2, 1995, providing further information in response to concerns raised in a January 5, 1995, letter from our office. Our January 5 letter raised concerns about a device labeled "Slider Bar" in the drawing enclosed with a previous letter from your company. As described in your letter, the "Slider Bar" is a bar near the floor of the vehicle that allows the seat belt to be moved to facilitate ingress and egress from the rear seats. "The forward (hooked) end of the slider bar is the point at which the belt always comes to rest when in use (buckled)." Your February 2 letter provides further information about and pictures depicting the "Slider Bar." You asked if this information resolved the concerns raised by agency staff.

The drawing provided with your original letter shows the "Slider Bar" adjacent to the seat. Agency staff were concerned that this design would result in the pelvic portion of the belt lying across a person's thighs, rather than on the pelvis. The pictures accompanying your February 2 letter show that the "Slider Bar" is actually rearward of the seat and that this concern is not warranted. Therefore, we agree that, if all requirements of Standards Nos. 208, 209, and 210 are met, this design would not be a problem.

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

ref:208 d:3/22/95