Interpretation ID: 77-2.42

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 24, 1977, request for an interpretation concerning the requirements for attachment hardware specified in Safety Standard No. 209, Seat Belt Assemblies. You ask about the force requirements that would be applicable to attachment hardware that is common to the left and right front safety belts and also common to the pelvic and upper torso restraints.

You are correct in your assumption that the subject attachment hardware (designated part "14" in your diagram) would be required to withstand a force of at least 6,000 pounds or 2720 kilograms without fracture of any section. However, the pertinent section is paragraph S4.3(c)(2) of the standard rather than paragraph S4.4(b)(3), as you stated. Paragraph S4.3(c)(2) specifies that attachment hardware designed to receive the ends of two seat belt assemblies shall withstand a tensile force of at least 6,000 pounds. The agency concludes that the Volvo attachment part "14" is hardware designed to receive the ends of two seat belt assemblies.

The attachment bolt, part "17", for part "14" would be required to withstand a force of 9,000 pounds or 4080 kilograms under paragraph S4.3(c)(1) of the standard.

Sincerely,

ATTACH.

March 24, 1977

Frank Berndt -- National Highway Traffic Safety Adminstration

Re: Interpretation of FMVSS #209

Dear Mr. Berndt:

Volvo requests a clarification of the applicability of the following section of FMVSS #209 to certain specific items:

Paragraph S.4.3(c)(1) states: "Eye bolts, shoulder bolts or other bolts used to secure the pelvic restraint of a seat belt assembly to a motor vehicle shall withstand a force of 9000 pounds or 4080 kilograms when tested by the procedure specified in S.5.2.(c)(1), except that attachment bolts of a seat belt assembly designed for installation in specific models of motor vehicles in which the ends of two or more seat belt assemblies cannot be attached to the vehicle by a single bolt, shall have a braking strength of not less than 5000 pounds or 2070 kilograms".

Paragraph S.4.3(c)(2) states: "Other attachment hardware designed to receive the ends of two seat belt assemblies shall withstand a tensile force of at least 6000 pounds or 2720 kilograms without fracture of any section when tested by the procedure in S.5.2(c)(2)".

Paragraph S.4.4(b)(3) states: "The structural components in the assembly that are common to pelvic and upper torso restraints shall withstand a force of not less than 3000 pounds or 1360 kilograms".

Volvo uses a front seat belt assembly where certain components are common to the pelvic and upper torso restraints for both front seats. Thus, we interpret paragraph S.4.4 (b)(3) to require that the attachment hardware which is common to the left and right front safety belts and also common to the pelvic and upper torso restraints to withstand 2 x 3000 pounds or 6000 pounds. Furthermore, because a seat belt assembly is defined as all hardware designed for installing the assembly in a motor vehicle, we interpret this requirement to include the attachment bolts. Enclosed for your information is a drawing of the Volvo safety belt system.

Are these interpretations correct? If there are any questions on this matter, please contact the undersigned.

In advance, thank you for your cooperation in this matter.

Sincerely,

VOLVO OF AMERICA CORPORATION -- Product Engineering and Development;

William Shapiro P.E. -- Pegulatory Analysis Engineer

[Enclosure Omitted]