Interpretation ID: aiam0280
Manager
Technical Standards Department
Renault
Incorporated
100 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Louis: This is in reply to your letter of August 4, 1971, to Mr. Clu Ferguson, requesting a clarification of certain sections of Federal Motor Vehicle Safety Standard No. 208 - Occupant Crash Protection, Docket 69-7, Notice 10.; It was our intent, under S4.5.3, to permit free substitution of Type or Type 2 passive belts for seat belt assemblies required under S4. The standard specifies in S4.5.3 that a passive belt must conform to the requirements of S7.1 and to certain requirements of Standard No. 209, but it does not specify either that shoulder belts should be detachable or that they should be non-detachable. The manufacturer may therefore choose either method of shoulder belt attachment. A detachable shoulder belt in a passive belt system must not, however, convert the system from passive to active status.; Please advise us if you need additional clarification of this point. Sincerely, Lawrence R. Schneider, Acting Chief Counsel