ID: 86-3.24

TYPE: INTERPRETATION-NHTSA

DATE: 05/16/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Takeshi Tanuma

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Takeshi Tanuma Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, MI 48104

Dear Mr. Tanuma:

Thank you for your letter of February 5, 1986 (ref. W-141-H), concerning the application of Standard No. 201, Occupant Crash Protection in Interior Impact, to an inside door "pull-handle." You explained that the pull-handle is made of unpadded plastic and does not have a hard inside frame. The drawing provided in your letter shows that the pull-handle is 7.44 inches (186 mm) long, 1.12 inches (28 mm) wide, and projects 1.09 inches (27 mm) from the side of the door. I hope that the following discussion answers your questions.

You first asked if the armrest requirements of S3.5 of the standard would apply to the pull-handle if it is located within the pelvic impact area of either the front or rear passenger door. In determining whether the requirements of S3.5 apply to a structure, the agency has looked at the design and location of the structure to determine whether it is an armrest (See, for example, the agency's interpretation letter of September 21, 1983, to Mr. Suzuki of your company.). In this case, the pull-handle projects far enough from the side of the door so that it could be used to rest the arm. Further, if the pull-handle were located in the pelvic impact area, it is likely to be used to rest the arm. Thus, we would consider such a pull-handle located in the pelvic impact area to be an armrest which must meet the requirements of S3.5 of the standard.

You also asked if the pull-handle would have to meet the requirements of S3.5 of the standard if it were located outside of the pelvic impact area at the upper portion of the door. In a conversation with Mr. Oesch of my staff, Mr. Hayaski explained that the pull-handle would probably be located near the rearmost edge of the door. In this case, it appears that the pull-handle would be positioned above and to the rear of where occupants would normally be expected to rest their arms. Thus, we would not consider a pull-handle located in the upper portion of the door and near the door's rear edge to be an armrest.

If you have any further questions, please let me know.

Sincerely, Erika Z. Jones Chief Counsel

February 5, 1986 Ref : W-141-H

Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th St., S.W. Washington, D.C. 20590

Dear Ms. Jones:

Re: REQUEST FOR INTERPRETATION - FMVSS 201, "OCCUPANT PROTECTION IN INTERIOR IMPACT"

On behalf of Nissan Motor Co., Ltd. of Tokyo, Japan, Nissan Research & Development, Inc. herewith requests interpretation regarding the applicability of Federal Motor Vehicle Safety Standard 201, "Occupant Protection in Interior Impact," to an inside door "pull-handle" as shown below.

(Please insert graphics)

Material Description :

- Plastic, unpadded - Without any hard (for example, metal) inside frame

Question 1.

If such a small handle is located within the "Pelvic Impact Area" of the door of either the front or rear passenger areas, is Section 3.5 of FMVSS 201 (the armrest requirement) applicable to this kind of feature?

ID: aiam4581

"Dear Mr. McDowell: This responds to your recent letter asking thi agency to 'provide guidelines for the design and installation of seat belt assemblies on large buses (over 10,000 pounds GVW).' You explained that you were interested in this information for passenger seats of large buses used in transit service, not as school buses. I am happy to be able to explain our requirements to you. Standard No. 208, Occupant Crash Protection (49 CFR /571.208) sets forth the crash protection requirements applicable to most vehicle types. Section S4.4 of that standard sets forth the requirements applicable to large buses other than school buses. That section requires large buses to have either a complete automatic protection system for the bus driver's seating position, or a seat belt assembly that conforms with Standard No. 209 at the driver's seating position. Standard No. 208 does not specify any requirements for either an automatic protection system or seat belt assemblies to be installed at any other seating positions in large buses. Standard No. 210, Seat Belt Assembly Anchorages (49 CFR /571.210) also includes requirements applicable to the anchorages for any belt assemblies installed at the driver's seating position on large buses. Specifically, section S4.1.2 of Standard No. 210 provides that: 'Seat belt anchorages for a Type 1 or Type 2 seat belt assembly shall be installed for each designated seating position, except a passenger seat in a bus or a designated seating position for which seat belt anchorages for a Type 2 seat belt assembly are required by S4.1.1.' As with Standard No. 208, Standard No. 210 exempts passenger seats in large buses from its requirements. Finally, Standard No. 209, Seat Belt Assemblies (49 CFR /571.209) sets forth requirements applicable to all seat belt assemblies for use in motor vehicles, including large buses. Thus, any seat belt assembly installed at the driver's position in a large bus would have to be certified as complying with Standard No. 209, as would any seat belt assembly voluntarily provided by a manufacturer for passenger seating positions in a large bus. In short, our standards do not require seat belt assemblies to be installed in passenger seats of large buses, but any seat belt assemblies that are installed at those positions would have to comply with Standard No. 209. Your letter indicated that you were generally aware of the fact that seat belt assemblies were not required to be installed at passenger seating positions of large buses. Nevertheless, you asked us to provide you with 'guidelines' for such installations, in response to the continuing demand for such installations by your company's customers. As a policy matter, NHTSA does not provide the sort of guidelines you have requested. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) sets forth certain specific requirements that must be satisfied by each of the Federal motor vehicle safety standards established by this agency. Among these requirements are that each safety standard shall be practicable, meet the need for motor vehicle safety, and be stated in objective terms (section 103(a) of the Safety Act) and each standard shall be reasonable, practicable, and appropriate for the particular type of vehicle for which it is prescribed (section 103(f)(3) of the Safety Act). NHTSA has determined that the current requirements of Standards No. 208 and 210, which do not apply to passenger seats in large buses, meet all of the statutory criteria. The issuance of 'guidelines' specifying measures beyond those required by our standards could readily be misinterpreted as an agency decision that these additional measures are necessary to satisfy the criteria of the Safety Act, or indirectly force manufacturers to comply with the 'guidelines,' in addition to the standards issued under the Safety Act. Either or both of these results would be inappropriate for passenger seats on large buses, because the information currently available to NHTSA indicates that no additional requirements are necessary in this area. Indeed, if the agency were to learn of additional information suggesting the current requirements no longer meet all the statutory criteria, and that requirements for the installation of seat belt assemblies at passenger seats of large school buses would meet all the statutory criteria, we would have an obligation to consider changing the applicable standards. Any such change would be required to be made through the ordinary, notice-and-comment rulemaking process, rather than through issuance of supplemental guidelines. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel";

ID: 07-002015--31 Oct 07--rls

ID: 86-4.27

TYPE: INTERPRETATION-NHTSA

DATE: 07/31/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Hubert J. Thomiszer -- Senior Mechanical Engineer, Triodyne, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Hubert J. Thomiszer Senior Mechanical Engineer Triodyne Inc. 5950 West Touhy Avenue Niles, Illinois 60648

Dear Mr. Thomiszer:

This responds to your letter asking about Federal Motor Vehicle Safety Standard No. 207, Seating Systems. You asked whether the 20 g acceleration requirement in the fore and aft direction through the center of gravity of the seat was based on a barrier impact test and, if so, at what speed. You also asked whether the 20 g acceleration was established taking into account the possibility that passengers who are unrestrained would impact the back of the seat in front of them on a frontal impact so as to add additional weight to the seat itself which would thereby increase the loading on the seat anchors. Your questions are responded to below.

The requirements to which you refer are set forth in section S4.2 of Standard No. 207. That section provides in relevant part:

S4.2 General performance requirements. When tested in accordance with S5., each occupant seat, other than a side-facing seat or a passenger seat on a bus, shall withstand the following forces.

(a) In any position to which it can be adjusted--20 times the weight of the seat applied in a forward longitudinal direction:

(b) In any position to which it can be adjusted--20 times the weigh; of the seat applied in a rearward longitudinal direction . . .

The basic requirement that occupant seats be able to withstand forces of 20 times the weight of the seat applied in both forward and rearward longitudinal directions was part of Standard No. 207 as that standard was established as one of the initial Federal motor vehicle safety standards. See 32 FR 2415, February 3, 1967. (The standard was later amended by revising certain other requirements, extending its application to additional vehicle types, adding requirements, and clarifying and restructuring the standard.)

As required by section 103(h) of the National Traffic and Motor Vehicle Safety Act, the initial Federal motor vehicle safety standards were promulgated under a tight statutory deadline and here based on existing safety standards. Standard No. 207 was based on the Society of automotive engineers' (207) Recommended Practice J879, Passenger Car Front Seat and Seat Adjuster (November 1963), and on the General Services Administration's (GSA) Federal Standard No. 515/6a, one of a number of standards which were developed for Government vehicles.

With respect to the requirements at issue, section 3.1 of SAE Recommended Practice J879 provided in relevant part:

3.1 Seat Adjusters and Seat Frame Combination--Each combination of seat adjusters and seat frame, together with their attachments, shall be capable of sustaining horizontal forward and rearward static load (L) equal to 20 times the weight of the fully trimmed seat. One-half of this load (L/2) shall be applied at points 8.00 in. above the seat frame rear attaching points as shown in Fig. 1. The 8.00 in. load application points represent the approximate vertical center of gravity of a fully trimmed passenger car front seat. . .

We have been advised by our technical staff that the requirement that occupant seats be able to withstand forces of 20 times the weight of the seat applied in both forward and rearward longitudinal directions was based on the forces involved in a 30 mph barrier impact test. Moreover, this requirement does not include any adjustment to take account of the increased loading on seat anchors that could result from passengers who are unrestrained impacting the seat in front of them in a frontal impact.

You may wish to contact the Society of Automotive Engineers for information concerning the development of their recommended practice.

I hope this information is helpful.

Sincerely,

Erika Z. Jones Chief Counsel

January 17, 1986

Chief Counsel Erika Z. Jones National Highway Traffic Safety Administration Room 5219 400 Seventh Street. S.W. Washington, DC 20590

Dear Erika Jones: I was advised by Mr. Steve Oesch to forward my request for information to your attention.

I would like to know two features of the Federal Motor Vehicle Standard No. 207.

1. Was the 20G acceleration requirement in the fore and aft direction through the center of gravity of the seat based an a barrier impact test and if so at what speed.

2. Was the 20G acceleration taking into account the possibility that passengers who are unrestrained would impact the back of the seat in front of them on a frontal impact so as to add additional weight to the seat itself which would thereby increase the loading on the seat anchors.

I will appreciate receiving this information as quickly as possible. there be any questions regarding this request, please call me collect at 677-V430.

Thank you for your cooperation in this matter.

Sincerely,

Hubert J. Thomiszer, M.E., P.E Senior Mechanical Engineer

ID: aiam2668

Dear Mr. Rechlicz: This responds to your August 29, 1977, letter requesting a interpretation of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, that would permit the measurment of seat spacing at any point along the width of the seat back.; The National Highway Traffic Safety Administration (NHTSA) ha previously responded to a similar request for an interpretation of the measurement of seat spacing. I am enclosing a copy of that letter for your information. In that letter, the NHTSA stated that measurement of seat spacing must be made from the seating reference point to the surface of the seat back or restraining barrier, exclusive of portions which protrude from the basic contour of the surface. This interpretation prohibits the measurement of seat spacing from the seating reference point to the side tubing which protrudes from the basic contour of the seat.; The NHTSA has received your second letter requesting rulemaking on th issue of seat spacing. That letter is being treated as a petition for rulemaking and will be processed according to agency rulemaking procedures.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2976

Dear Mr. Knight:#This responds to your letters of July 11, 1978, an January 18, 1979, concerning Federal Motor Vehicle Safety Standard (FMVSS) 101-80, *Controls and Displays*. I regret the delay in responding to your inquiry. The answers to your questions are as follows:#1. The turn signal control lever used by Rolls-Royce is mounted on the steering column and is positioned horizontally. To operate the turn signals, the lever must rotated either clock-wise or anti-clock-wise. To label the control lever and to indicate the manner of operation, Rolls- Royce is considering placing the arrows of the turn signal symbol so that they point up and down. You ask whether the standard permits that orientation of the arrows.#The answer is no. Section 5.2.1 requires that the turn signal symbol appear perceptually upright to the driver. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle. Complying with the perceptually upright requirement instead of reorienting the symbol to serve other purposes will aid in ensuring quick and accurate identification of the turn signal control. We wish to observe that essentially the same result as that sought by RollsRoyce (sic) in reorienting the turn signal symbol could be achieved by placing curved, thinner arrows next to the symbol to indicate mode of operation.#2. (i) You noted that differing display identification requirements for safety belts appear in FMVSS 101-80 and FMVSS 208. FMVSS 101-80 does not supersede or preempt FMVSS 208 in this area. However, the agency will soon issue a notice that will provide for use of the safety belt symbol in Table 2 of FMVSS 101-80 for the purposes of both standards.#(ii) You are correct in assuming that column 3 of Table 2 should include a reference to FMVSS 105-75 for brake system malfunction displays and a reference to FMVSS 121 for brake air pressure displays. These inadvertent omissions will be corrected in the notice mentioned above. You are also correct in assuming that the options in section 5.3.5 of FMVSS 105-75 are still available.#3. You referred to the statement in the final rule preamble that the visibility requirements of 101- 80 would be deemed satisfied even if minimal movements by the driver were necessary and suggested that this interpretation be incorporated in section 6, conditions, and amplified. The agency does not believe that this step is necessary. The agency does, however, believe it appropriate to amplify its earlier interpretation. By minimal movement, the agency meant head movement of not more than a few inches. By a 'few' inches, we mean up to approximately three inches. As to your suggestion for specifying the size of the driver to be used in determining compliance with the visibility requirements, the agency will consider this suggestion and address it at a future date.#4. You should comply with the speedometer scale requirements in FMVSS 101-80 since the labelling requirements in FMVSS 127 were deleted in the response to reconsideration petitions that was published July 27, 1978 (43 FR 32421).#Sincerely, Frank Berndt, Acting Chief Counsel;

ID: aiam2975

Dear Mr. Knight:#This responds to your letters of July 11, 1978, an January 18, 1979, concerning Federal Motor Vehicle Safety Standard (FMVSS) 101-80, *Controls and Displays*. I regret the delay in responding to your inquiry. The answers to your questions are as follows:#1. The turn signal control lever used by Rolls-Royce is mounted on the steering column and is positioned horizontally. To operate the turn signals, the lever must rotated either clock-wise or anti-clock-wise. To label the control lever and to indicate the manner of operation, Rolls-Royce is considering placing the arrows of the turn signal symbol so that they point up and down. You ask whether the standard permits that orientation of the arrows.#The answer is no. Section 5.2.1 requires that the turn signal symbol appear perceptually upright to the driver. The upright position of a symbol is determined by referring to column 3 of Table 1 of the standard. That table shows that the upright position for the turn signal symbol is with the arrows pointing horizontally. Thus, the arrows must point essentially horizontally in the motor vehicle. Complying with the perceptually upright requirement instead of reorienting the symbol to serve other purposes will aid in ensuring quick and accurate identification of the turn signal control. We wish to observe that essentially the same result as that sought by RollsRoyce (sic) in reorienting the turn signal symbol could be achieved by placing curved, thinner arrows next to the symbol to indicate mode of operation.#2. (i) You noted that differing display identification requirements for safety belts appear in FMVSS 101-80 and FMVSS 208. FMVSS 101-80 does not supersede or preempt FMVSS 208 in this area. However, the agency will soon issue a notice that will provide for use of the safety belt symbol in Table 2 of FMVSS 101-80 for the purposes of both standards.#(ii) You are correct in assuming that column 3 of Table 2 should include a reference to FMVSS 105-75 for brake system malfunction displays and a reference to FMVSS 121 for brake air pressure displays. These inadvertent omissions will be corrected in the notice mentioned above. You are also correct in assuming that the options in section 5.3.5 of FMVSS 105-75 are still available.#3. You referred to the statement in the final rule preamble that the visibility requirements of 101-80 would be deemed satisfied even if minimal movements by the driver were necessary and suggested that this interpretation be incorporated in section 6, conditions, and amplified. The agency does not believe that this step is necessary. The agency does, however, believe it appropriate to amplify its earlier interpretation. By minimal movement, the agency meant head movement of not more than a few inches. By a 'few' inches, we mean up to approximately three inches. As to your suggestion for specifying the size of the driver to be used in determining compliance with the visibility requirements, the agency will consider this suggestion and address it at a future date.#4. You should comply with the speedometer scale requirements in FMVSS 101-80 since the labelling requirements in FMVSS 127 were deleted in the response to reconsideration petitions that was published July 27, 1978 (43 FR 32421).#Sincerely, Frank Berndt, Acting Chief Counsel;

ID: aiam4317

Dear Ms. Stevens: Thank you for your letter of March 26, 1987, asking several question about how our regulations on safety belts would apply to side and rear-facing seats in emergency medical vehicles. I hope the following discussion answers your questions.; You explained in your letter that most emergency medical vehicles hav a rear-facing seat that is typically located behind the driver's seat. The photographs you sent with your letter show that in one of the two vehicle designs you photographed, the rear-facing seat appears to be a typical vehicle seat, referred to as a 'captain's chair,' often used in a van-type vehicle. In the other emergency vehicle design show in your photographs, there is a rearward-facing, bench-type seat with a padded seat pan and back installed directly behind the driver.; You further explained that, depending on the number of stretchers th vehicle is designed to carry, there may be another seating area in the vehicle. In single-stretcher vehicles, there is a squad bench, which your photographs show is a set of storage compartments with a padded top, located next to the stretcher. You explained that emergency personnel may sit on the squad bench to attend the the(sic) patient while the vehicle is in motion. You further explained that personnel in dual-stretcher vehicles sit on the empty stretcher to attend to the patient. You said that use of a safety belt in those positions is too restrictive to allow emergency personnel to provide acute care to patients during transports.; Standard No. 208, *Occupant Crash Protection*, sets requirements fo the installation of occupant restraints in motor vehicles. The emergency medical vehicles shown in your photographs would be classified as multipurpose passenger vehicles under our regulations since they are designed to carry 10 or fewer persons and are built on a truck chassis. Standard No. 208 requires manufacturer of new multipurpose passenger vehicles to install a safety belt for each designated seating position. Part 571.3 of our regulations defines, impart, a designated seating position as:; >>>any plan view location capable of accommodating a person at least a large as 5th percentile female, if the overall seat configuration and design and vehicle design is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats.<<<; The agency considers the two types of rearward-facing seats in th emergency medical vehicles you photographed to be designated seating positions. Those seats are designed and built in the same manner as conventional vehicle seats in that they have a padded seat pan and a high padded seat back. In fact, the one seat appears to be a conventional 'captain's chair' which has been mounted in a rearward-facing position. The two rearward-facing seats are also designed to be used on a routine basis by an emergency medical personnel as the vehicle travels to its destination.; In contrast, the agency does not consider as squad bench or a stretche to be a designed or built in the same manner as a conventional vehicle seat. Although they have the equivalent of a seat pan, they do not have a seat back. Most importantly, both the squad bench and stretcher are meant to be used on a temporary basis as auxiliary seating position by emergency medical personnel as they provide treatment to a patient. Thus, as an auxiliary seating area, they would not be considered a designated seating position and therefore not subject to the safety belt installation requirement of Standard No. 208.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel

ID: nht71-1.43

DATE: 07/16/71

FROM: ROBERT L. CARTER -- NHTSA MOTOR VEHICLE PROGRAMS

TO: LOUIS C. LUNDSTROM -- DIRECTOR AUTOMOTIVE SAFETY ENGINEERING GENERAL MOTORS ENVIRONMENT ACTIVITIES STAFF

COPYEE: C.R. SHARP

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in response to your request of June 14 for an interpretation of several provisions of Standard No. 101, Control Location, Identification and Illumination.

You asked first whether "redundant" controls must be identified, such as the windshield washer control that is located in the end of the column mounted shift lever. The standard does not distinguish between required and redundant controls, and redundant controls must be identified. As this agency observed of controls designed to be operable by touch "their function is not clear to a operator unfamiliar with the vehicle in which they are installed, and their identification is necessary" (36 F.R. 8297, May 4, 1971).

Secondly, you pointed out to us the virtual impossibility of requiring identification of intermediate positions in rocker-type and push-pull type heating and air conditioning system controls. We agree with your point, and I enclose an order of the Administrator amending paragraph S4.2 to exclude intermediate positions on these types of controls from the identification requirement.

Finally, you ask whether the identification requirement in S4.2 for "manually operated" controls extends to a floor mounted windshield washer control. Since a manually operated control is, by definition, a control that is operated by hand, a foot-operated control need not be identified.

Sincerely,

Enclosure

DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

[Docket No. 1-18; Notice 5]

Summary Statement

MOTOR VEHICLE CONTROLS STANDARD - amendment of motor vehicle controls standard (Standard No. 101), to clarify control identification and illumination requirement and control location test condition, effective January 1, 1972, and September 1, 1972.

Title 49 - TRANSPORTATION

Chapter V - National Highway Traffic Safety Administration Department of Transportation

PART 571 - FEDERAL MOTOR VEHICLE SAFETY STANDARDS Control Location, Identification, and Illumination

The purpose of this notice is to amend Motor Vehicle Safety Standard No. 101 to clarify control identification, and illumination requirements, and the control location test conditions.

Standard No. 101, Control Location, Identification, and Illumination, was amended on January 14, 1971 (36 F.R. 503) and, as a result of reconsideration petitions, was amended again on May 4, 1971 (36 F.R. 8296). General Motors Corporation has asked for a clarification of the requirement in S4.2 that "Each position of . . . a heating or air conditioning system control shall be identified." It points out the virtual impossibility of identification of intermediate positions for rocker-type and push-pull-type switches. The NHTSA agrees that intermediate positions for these types of switches are difficult to identify, and consequently has amended S4.2 to exclude them from the identification requirement.

Ford Motor Company has petitioned for a clarification of the requirement in S4.3 that ". . . A control shall be provided to adjust the intensity of control illumination variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify the control under conditions of reduced visibility." Specifically, Ford wishes an interpretation

that a simple on-off switch is a sufficient variable control.

The NHTSA has determined that a motor vehicle operator should be able to set control illumination levels according to his own, eye comfort and the specific condition of reduced visibility that requires control illumination. Additionally, it is important for a driver to reduce control illumination when the illumination is reflected in the windshield creating a glare condition. The NHTSA intended in the January 14 issuance that a continuously variable "rheostat"-type control be provided, and is amending S4.3 to reflect this intention.

The NHTSA is also amending the restraint test condition of S5.2 to correspond with the recent amendment to Standard No. 208, Seat Belt Installations, (36 F.R. 9869) that requires Type 1 seat belt assemblies in, among other vehicles, walk-in van-type trucks, and multipurpose passenger vehicles with a gross vehicle weight rating of more than 10,000 pounds.

In consideration of the foregoing, 49 CFR 571.21, Federal Motor Vehicle Safety Standard No. 101, Control Location, Identification and Illumination, is amended as follows:

1. The third sentence in Paragraph S4.2 is amended to read: "Each position of an automatic vehicle speed control and a heating and air conditioning system control, other than an intermediate position of a rocker-type or push-pull-type control, shall be identified."

2. The last sentence of Paragraph S4.3 is amended to read: "A control shall be provided to adjust the intensity of control illumination, continuously variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify controls under conditions of reduced visibility."

3. Paragraph S5.2 is amended to read: "The person seated at the controls of a multipurpose passenger vehicle or truck with a gross vehicle weight rating of more than 10,000 pounds, convertible, open-body type vehicle, walk-in van-type truck, or bus is restrained by a nonextending pelvic restraint fastened so that there is no slack between the lap belt and the pelvis."

Effective date: January 1, 1972, Paragraph S4.2 for passenger cars; September 1, 1972, Paragraph S4.2 for vehicles other than passenger cars, Paragraph S4.3 and Paragraph S5.2.

This amendment is issued pursuant to sections 103 and 119 of the National Traffic and Motor Vehicle Safety Act of 1966, and the delegation of authority from the Secretary of Transportation to the National Highway Traffic Safety Administrator, 49 CFR 1.51.

Issued on JUL 9 1971

Douglas W. Toms

Acting Administrator

ID: 2255y

Mr. Scott K. Hiler
Manager, R & D Lab
The C.E. White Co.
417 N. Kibler Street
New Washington, OH 44854

Dear Mr. Hiler:

This responds to your letter seeking an interpretation of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR /571.210). Specifically, you asked if the strength test set forth in that standard requires simultaneous testing of all the safety belt anchorages for a passenger seat in school buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less, when those anchorages are installed on the seat frame, or whether those anchorages can be tested individually. The answer is that such anchorages are tested individually under the current provisions of the strength test in Standard No. 210.

Standard No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222) establishes the occupant protection requirements for passenger seating positions in school buses. Section S5(b) of Standard No. 222 provides that school buses with a GVWR of 10,000 pounds or less shall meet the requirements of Standard No. 210, among other standards. Section S4.2 of Standard No. 210 sets forth the strength test for anchorages. Section S4.2.4 reads as follows: "Except for common seat belt anchorages for forward-facing and rearward-facing seats, floor-mounted seat belt anchorages for adjacent designated seating positions shall be tested by simultaneously loading the seat belt assemblies attached to those anchorages."

Note that the only anchorages subject to a simultaneous testing requirement are floor-mounted anchorages. The anchorages described in your letter and shown in the photographs enclosed with that letter are mounted on the seat frame. Therefore, those anchorages would not be tested simultaneously to determine compliance with Standard No. 210.

I should also point out that NHTSA has proposed to amend section S4.2.4 of Standard No. 210 so that all seat and floor-mounted anchorages common to one seat would be tested simultaneously during the strength test. I have enclosed a copy of that proposal for your information. The interpretation in this letter may no longer be correct after the effective date of any final rule adopting that proposal.

Sincerely,

Stephen P. Wood Acting Chief Counsel

Enclosure

/ref:210 d:l/l2/90