United States Department of TransportationInterpretation ID: aiam3531
Specifications Manager
Indiana Mills & Manufacturing
Inc.
120 West Main Street
Carmel
IN 46032;
Dear Mr. Lawler: This responds to your recent letter requesting an interpretatio concerning paragraph S4.3(c)(1) of Safety Standard No. 209, *Seat Belt Assemblies*. You ask for clarification of the cases in which a 5,000-pound attachment bolt may be used in lieu of a 9,000-pound bolt.; Paragraph S4.3(c)(1) of Standard No. 209 specifies that attachmen bolts used to secure the pelvic restraint of a seat belt assembly to a motor vehicle shall withstand a force of 9,000 pounds, 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 breaking strength of not less than 5,000 pounds.' The intent of the requirement in S4.3(c)(1) is to assure that inadequate attachment bolts will not be used to attach seat belt assemblies to a vehicle. A 5,000- pound bolt may be used only if the belt assembly is designed for use in specific models of vehicles in which only one end of a belt assembly can be attached by a single bolt.; In answer to your question, the agency does not 'have in mind' certai brands or models of vehicles which would qualify under this exception, and the exception is not limited to single-seat vehicles. Further, the requirement does not mean that a seat belt assembly that can be used in more than one application must be installed with a 9,000-pound bolt. If a particular assembly is designed for use in several different models in all of which only one end of the belt assembly can be attached by a single bolt, then a 5,000- pound bolt is sufficient. The distinction is that an aftermarket belt for universal application must be accompanied with a 9,000- pound bolt, because in some vehicle models it would be possible to mount two ends of seat belt assemblies with a single bolt.; You should note that paragraph S4.1(k) of Standard No. 209 requires th manufacturer of seat belt assemblies for after-market use to furnish an instruction sheet stating whether the assembly is for universal installation or for installation only in specifically stated motor vehicles. If you provide 5,000-pound bolts for any of your assemblies, the instruction sheet required by S4.1(k) should specify that the assemblies are to be used only in the vehicle models you list.; I hope this has answered all your questions. Sincerely, Frank Berndt, Chief Counsel