Interpretation ID: 20391.ogm

Mr. Gil De Laat
Manager, Governmental Affairs
Subaru of America
Subaru Plaza
P.O. Box 6000
Cherry Hill, NJ 08034-6000

Dear Mr. De Laat:

This responds to your letter asking for our interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 207, Seating systems, as it applies to the seat belt web guide attached to the seatback of a rear center seat. I apologize for the delay in our response. You describe the web guide as a plastic extrusion that forms a loop to guide seat belt webbing. Your letter further states that the guide does not have any structural benefit for the purposes of seat or seat belt performance, but instead acts to position the seat belt for user comfort. You ask that we provide our opinion of the applicability of S4.2 of FMVSS No. 207 to the seat belt guide.

FMVSS No. 207 is intended to ensure that seats and their attachments are strong enough not to fail as a result of "forces acting on them as a result of vehicle impact" (S1). S4.2 sets forth the general performance requirements for occupant seats and specifies that a seat shall withstand certain forces in a forward direction (S4.2.(a)), certain forces in a rearward direction (S4.2.(b)), and certain forces applied to the seatback (S4.2(d)). In addition, if a seat belt assembly is attached to the seat, the seat shall simultaneously withstand the loads specified in S4.2.(a) or (b) and the belt anchorage loads of S4.2 of FMVSS No. 210, Seat belt assembly anchorages.

We assume your question is not whether the seat would be subject to S4.2, which it undoubtedly is, but rather whether the addition of the seat belt webbing guide to the seat back requires that the seat be tested in accordance with the requirements of S4.2(c). We note that S4.2(c) applies in those instances where a seat belt is "attached" to the seat. The use of a webbing guide that is permanently attached to the seat raises the question of whether such a guide is an "attachment" for the purposes of S4.2(c).

Your letter states that the web guide "does not have any structural benefit for the purposes of seat or seat belt performance, but rather acts to position the seat belt webbing for user comfort." Under the conditions you describe, it is our opinion that the web guide is not an "attachment" of the seat belt assembly to the seat for the purposes of FMVSS No. 207. A seat that has no seat belt anchorage attached to it will not experience the load from the seat belt in a crash. You have represented that the web guide serves no structural purpose and will not transfer seat belt loads to the seat itself. Since the seat will not be loaded in a crash by the forces generated by the safety belt, it is not necessary that the seat be capable of withstanding the load from the belt. Thus, the use of the web guide you describe does not require that the seat be subjected to the seat belt anchorage loads of FMVSS No. 210.

I hope that this is responsive to your inquiry. If you have any questions, please contact Otto Matheke of this office at (202) 366-5253.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:207
d.7/10/00